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Compensating Control Refresher

From time to time, organizations find themselves in the predicament of not being able to meet a PCI DSS requirement due to business or technical constraints. To address that situation, the PCI SSC has provided the compensating control worksheet (CCW) as a way to work around those requirements that cannot be met directly as stated in the PCI DSS. When the CCW was updated back in 2010 for v1.2, I wrote about those changes and how to write a CCW. However, here we are at v3.1, five years down the road and I still see a lot of poorly and improperly written CCWs. As a result, I think it is time to take people through a refresher on the CCW.

First and foremost, the writing of any CCW is your organization’s responsibility. Your QSA can provide input and guidance, but the origination of the CCW is up to the organization. Once developed, your QSA can review it and make suggestions to enhance and improve the CCW. Once that has been completed, you will then want your acquiring bank to review it to ensure that they will accept it as part of your self-assessment questionnaire (SAQ) or Report On Compliance (ROC) filing.

Secondly, the format of the CCW is dictated by the Council and that format is provided in Appendix B of the SAQ D or in Appendix C of the ROC. Failure to use the proper format will create issues with your QSA, your bank and with the Council, particularly if you are doing a ROC. So please use the Council supplied format and not develop something on your own.

Finally, the PCI SSC has stated that any requirement can have a CCW. In the past, the Council instructed QSAs and ISAs that requirement 3.2 [Do not store sensitive authentication data after authorization (even if encrypted). If sensitive authentication data is received, render all data unrecoverable upon completion of the authorization process] was not allowed to have a CCW. At the 2014 Community Meeting, the Council backed away from that restriction and said that any requirement can have a CCW with no restrictions. However, as a QSA I would have a serious problem accepting a CCW for requirement 3.2 because storing sensitive authentication data (SAD) is the whole reason why the PCI DSS was created to stop.

To remind everyone, the CCW is broken into seven sections.

  • Identification of the PCI DSS requirement(s) being compensated.
  • The constraint or business justification for needing the CCW.
  • The original objective of the requirement(s) being compensated.
  • Identification of any additional risks because of the CCW
  • The compensating controls.
  • The procedures your QSA/ISA followed to confirm that the compensating controls are in place and functioning.
  • The procedures followed by your organization to maintain the compensating controls.

While the Council tells everyone to have an individual compensating control for each requirement, there are some places where a compensating control is the same for a number of requirements. This most often occurs for requirements in section 8 around the various user management requirements or 6.1, 2.2, 11.2 and the processes of vulnerability management. I would highly recommend using one CCW per requirement, but I can understand why you might combine some. Just be judicial in combining them. Also, list not only the number of the requirement(s), but also the text of the requirement from the Requirements column in the PCI DSS. While your QSA might have memorized the PCI DSS requirements, bankers and others that will read the CCW have typically not committed to that level of detail and it will help them with the context of the CCW.

The business justification needs to be more than just “we don’t want to” or “it was too hard”. Believe it or not, I have had a lot of organizations provide just such simplistic and silly reasons for justifying a CCW. Proper justifications can involve budgetary constraints, timing (e.g., not enough time to complete remediation by the end of the assessment period), application requirements (e.g., the application requires XP to run) and/or vendor requirements (e.g., the vendor requires a hardware upgrade to correct the issue). If you do have a target date for addressing the CCW, this is where you want to provide that information so that readers know that the CCW has some time limit.

The original objective is the easiest part of the CCW to develop. The Council has provided the “Guidance” column in the PCI DSS for each requirement and it is the verbiage in that Guidance column that you should use to explain the original objective of the requirement. If you are using the CCW for multiple requirements, this section can get rather lengthy and I would recommend identifying the Guidance information with its requirement to help understanding of the information.

The next section can sometimes be the toughest to develop and that is identification of any additional risks because you are using a CCW. In some cases, there may actually be no additional risk perceived by using a CCW. One such example is when organizations have a separate system management VLAN where network and system administrators can use telnet, SNMPv2 and other “unsecure” protocols in addition to SSH, RDP and other secure protocols to manage devices/systems. These system management VLANs typically require the use of an out of band (OOB) to gain access, administrator credentials different from the administrator’s user credentials and two factor authentication to name just a few of the controls you see in this example. These management/administrative VLANs are no more risky than using only secure protocols.

However, if you are compensating for having to keep Windows XP running, that will likely be a very different story and depending on the compensating controls put in place, the risk could be moderately higher than not have XP around. The key here is that it is that the risk should be assessed and then honestly discussed in the CCW. If you think you are going to say that having XP does not increase risk to your cardholder data environment (CDE), I would seriously think again regardless of your compensating controls in place because any outdated Windows implementation is a security problem waiting to happen regardless of how you think you have mitigated the risk.

The compensating controls section is where the rubber finally meets the road. It is here that you document each individual control that compensates for your organization’s inability to meet the requirement(s) in question. I recommend that people either bullet point or number list each individual control. The reason is that in the next two sections, you need to tie the validation and maintenance items to the controls in this section and doing some sort of list makes it easy for people to ensure they have covered all controls in each section.

The most common mistake made in this section is organizations state that they have a project to remediate the issue(s). Sorry, but this is NOT a control. It is nice information, but it is not a control that can be relied upon. QSAs never want to ever see such statements made about future projects ever in this section. This section is all about what you are doing from a controls perspective to manage the fact that you cannot meet the requirement(s).

Valid controls in this section must also go “above and beyond” what is required by the PCI DSS. Examples of “above and beyond” include:

  • Reviewing log data in real time for a particular condition that would indicate an out of compliance condition on a control. This is above and beyond because log data only needs to be reviewed daily for such conditions.
  • Using whitelisting to identify applications that do not belong on a PC and generating an alert in real time if such applications are found. Such technology is above and beyond because it is not currently required by the PCI DSS.
  • Using critical file monitoring to identify rogue applications that do not belong on a PC and generating alerts in real time if found. Critical file monitoring is a PCI requirement, but this goes above and beyond because monitoring is only required on a weekly basis.

The list here can go on and on, but hopefully I have given you some ideas of how to create compensating controls that can actually compensate for your inability to comply with the requirement(s).

One key point though is that you cannot use a requirement in the same requirement group to compensate for a different requirement in the same group. For example, requirement 6.4 has bunches of sub-requirements under it. You cannot write a compensating control for one sub-requirement in 6.4 and then use a different sub-requirement under 6.4 as one of your compensating controls regardless if it is above and beyond.

The next section will list how the controls were assessed by your QSA/ISA to prove they have been implemented. So using our previous bullet list, here is what the control validation bullets would look like.

  • Observed the system information event management (SIEM) solution and verified that alerts are generated in near real time for [control failure condition] and that the alert is followed up by the security analyst to determine if the alert is valid. If valid, the security analyst opens a service ticket and assigns that ticket to the appropriate area for further investigation.
  • Observed the [whitelisting solution name] and verified that if rogue applications are loaded on a workstation a near real time alert is generated back to the [whitelisting solution name] master console and that the alert is followed up by the security analyst to determine if the alert is valid. If valid, the security analyst opens a service ticket and assigns that ticket to the appropriate area for further investigation.
  • Observed the [critical file monitoring solution name] and verified that if rogue applications are loaded on a workstation a near real time alert is generated back to the [critical file monitoring solution name] master console and that the alert is followed up by the security analyst to determine if the alert is valid. If valid, the security analyst opens a service ticket and assigns that ticket to the appropriate area for further investigation.

Finally, you need to document what your organization will do to ensure that the controls remain implemented and effective. This is where most compensating controls fall apart. The organization gets through their assessment and then neglects to keep the compensating controls working. Using our list from the compensating controls section, the maintenance controls would look something like this.

  • [Organization name] reviews on a [weekly/monthly/quarterly] basis the SIEM and test that the alerts for the [control failure condition] are still functioning as designed.
  • [Organization name] reviews on a [weekly/monthly/quarterly] basis the [whitelisting solution name] and test that the alerts for rogue applications are still functioning as designed.
  • [Organization name] reviews on a [weekly/monthly/quarterly] basis the [critical file monitoring solution name] and test that the alerts for rogue applications are still functioning as designed.

A good idea in the maintenance section is to set timeframes for remediating any control testing failures.

One other important item of note about the controls, validation and maintenance lists. Notice that there are no “forward looking” statements made such as someone “will” perform or “will” review. CCWs must be shown to be in place and operating. A promise of implementing a control is NOT a control either. The control must be shown to be operating and maintained. That is an important point a lot of organization miss. It means that CCWs cannot be created at the last minute and then be operational past the filing of your SAQ or ROC. If you are going to have to use a CCW, that means you will need to identify the situation early and then get the compensating controls implemented, validated and through at least one maintenance cycle before it can be accepted.

CCWs can buy organizations time while they address issues that will take longer to address than their PCI assessment period. Unfortunately, there are organizations that see the CCW as a way to be judged PCI compliant without addressing their serious security shortcomings. It is not unusual for large organizations to have a number of CCWs particularly if they have legacy applications and hardware. However, I would highly recommend that all organizations only rely on CCWs if there are no other options to achieving PCI compliance.

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5 Responses to “Compensating Control Refresher”


  1. October 6, 2015 at 8:06 AM

    Hi – great article; do you have any link to back up the following statement: “…was not allowed to have a CCW. At the 2014 Community Meeting, the Council backed away from that restriction and said that any requirement can have a CCW with no restrictions.”

    I searched but I can’t find any formal document covering CCW and 3.2.

    • October 6, 2015 at 8:20 AM

      The comment about requirement 3.2 and compensating controls was made during one of the many question and answer sessions during that Community Meeting. I would post a question to the Council on this topic and get them to respond.

      • 3 eliotn
        October 6, 2015 at 8:22 AM

        Thank you.

  2. 4 JJ
    July 25, 2015 at 7:17 PM

    In practice, is there any limit to the number of compensating controls that show up in a ROC? We’ve heard that it can range from just a few to less than a dozen because the acquirer understands that a compensating control can be really onerous to implement and actually make work. So a number above a few means that the entity being assessed really has no plans to do anything beyond writing them down.

    • July 27, 2015 at 7:30 AM

      The Council has never issued any guidance regarding any limit on compensating control worksheets (CCW) that can be in a ROC or SAQ. So in theory, you could have as many CCWs as there are requirements. However, as you point out, the more CCWs the more onerous it becomes to manage and maintain all of those controls. That said, CCWs do not necessarily mean the organization is not going to do something, just that they have issues meeting the original requirements as intended.


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