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Four Lessons Learned From High Profile Credit Card Breaches

Payment Card Assessments

The media has been filled with stories of high profile credit card breaches, including those from Target, Neiman Marcus, P.F. Chang’s and most recently Home Depot. Details on the Home Depot breach are still emerging, but the details around the Target and Neiman Marcus breaches are well known and causing the public to ask if it will happen again?

However, the real question we should be asking ourselves is when will it happen again?

 Experienced Qualified Security Assessors (QSAs) will acknowledge that securing the cardholder data environment by meeting PCI DSS requirements provides a certain baseline level of security; however, it would be naïve to say that this alone will protect an organization from an attack. It is important to note there are areas where a merchant should realize the PCI DSS is an important start, but is only the foundation. One example is event logging.

The detailed requirements for event logging (section 10.6) assume that a merchant or service provider will utilize the documents for investigative purposes. That said, having a process to review audit logs on a daily basis does not guarantee that the employees responsible for reviewing logs and alerts will appropriately identify important or suspicious events in a timely and accurate manner. Similarly, during a PCI DSS assessment, QSAs are tasked with validating that daily log review processes and/or the use of log harvesting technologies are implemented. However, QSAs will not critique the details of the log review process or evaluate the robustness of log parsing tools.

So, how does this pertain to recent breach events?

It has been reported that many relevant security log events pertinent to the breaches were generated, but either ignored, or not acted upon in a timely manner, perhaps lost in the myriad of audit logs.

To go beyond the baseline standard, we can ask more probing questions such as:

  • How do log events ensure correct action?
  • How quickly should they be addressed?
  • Does the team responsible for reviewing these events and alerts have sufficient training and tools necessary to identify possible attacks?

Verizon’s 2014 data breach investigation reported that 1% of data breaches were discovered by a review of audit logs. Surely, a much higher number of breaches could have been detected through an effective internal review of audit logs. What does that say about our ability to detect breaches as they occur?

I have four thoughts for consideration:

1. Devote to training.
Individuals responsible for reviewing security events and alerts need to develop the skills to identify and act upon suspicious events that may indicate unauthorized activity.

2. Invest in good tools.
Does the organization currently have sufficiently capable log monitoring and file integrity monitoring tools? These tools should allow an organization to scan large amounts of information, but be able to extract specific events that could impact the organization.

3. Be proactive.
Understanding how alerts are generated, what data is contained in the alert and who reviews them is paramount. A careful plan can avoid finding out that a critical system is missing logs which may result in an incomplete view of an incident and potentially unnecessary future expenditure

4. Prepare drills.
In a variety of specialties, including the military, medicine, and airline industry, exercises in handling emergency events have made many lives safer. Although we try to prevent a breach from happening, if it does happen, it can be resolved quickly and effectively. Reviewing audit logs and alerts can be a tedious activity at times. Make it interesting by staging mock attacks. Consider making this exercise a component of incident response plan tests and penetration tests.

Organizations face an ever expansive landscape of threats, vulnerabilities, and risks, not to mention an ever rising mountain of logs to review and manage. Bringing thoughtful consideration to security log management will enable an organization to take action where needed, understand important events, and address potential security threats when identified.

About ERIC SAMPSON

Eric Sampson is a Director at Schellman. Eric began his professional career in 2005 while working as an IT auditor in Philadelphia. Eric executed several critical projects for clients in the areas of information security and Service Organization Controls (SOC) reporting projects. To date, Eric has provided services to clients in the healthcare, information technology, and financial services industries, among others.