The Equifax Data Breach and PCI DSS: Let’s Be Blunt

Let’s be blunt: If you accept, store, process, or use credit card data in your business, you are subject to PCI DSS compliance requirements. This is true for all types of organizations, from retail to healthcare. Depending on the number of transactions you process and how you process electronic payment data, you are required to undergo ASV or QSA assessments to gauge how secure you are compared to PCI DSS standards. And you are required to sign off on the results, submit them, and remediate any pending findings in a timely fashion.

Recently, Verizon published a report indicating that organizations are more likely to be breached if they are not maintaining PCI DSS standards on at least a quarterly basis. While that seems obvious, many security professionals have refuted the claims in the report as biased to Verizon’s own services.

This brings me back to my point: I wonder what Equifax’s last assessment looked like? Were they compliant? Who audited them?

The Equifax data breach, as noted by CNBC, affected approximately 143 million U.S. consumers and included names, birthdates, credit card numbers (209,000 of the total lot), social security numbers, and potentially driver’s license numbers. The breach was discovered on July 29^th, 2017 and the attackers “exploited a U.S. website application vulnerability to gain access to certain files.”

So, I’ll (bluntly) ask some honest questions:

• Was the web application known, or was it a zero-day exploit? If it was known, how old was it and why wasn’t it remediated? If it was a zero-day, please educate the security community so we can protect our own websites!
• PCI DSS requires File Integrity Monitoring (FIM). Were the sensitive files being monitored? Is that how Equifax discovered the breach? This implies monitoring only and no prevention.
• How did Equifax determine the breach, and were the systems in question within PCI Scope? I certainly believe so, since credit card information was obtained and they appear from initial reports to be complete PANs.

These facts, and many more, are critical to understand what happened. I hope they come to light soon, and as with any larger breach involving payment card data, it remains to be seen what monetary and punitive damages Equifax will face from the PCI council.

BeyondTrust will be reviewing the facts in this breach as they become available and report back with any new developments.

Morey J. Haber

CISO at BeyondTrust

Morey J. Haber is Chief Technology Officer and Chief Information Security Officer at BeyondTrust. He has more than 25 years of IT industry experience and has authored three Apress books: Privileged Attack Vectors, Asset Attack Vectors, and Identity Attack Vectors. In 2018, Bomgar acquired BeyondTrust and retained the BeyondTrust name. He originally joined BeyondTrust in 2012 as a part of the eEye Digital Security acquisition. Morey currently oversees BeyondTrust strategy for privileged access management and remote access solutions. In 2004, he joined eEye as Director of Security Engineering and was responsible for strategic business discussions and vulnerability management architectures in Fortune 500 clients. Prior to eEye, he was Development Manager for Computer Associates, Inc. (CA), responsible for new product beta cycles and named customer accounts. He began his career as Reliability and Maintainability Engineer for a government contractor building flight and training simulators. He earned a Bachelor of Science degree in Electrical Engineering from the State University of New York at Stony Brook.