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

Morey Haber, September 7th, 2017

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 29th, 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.