SSL Wars: A New Hope

A few months ago, I wrote a blog regarding some of the vulnerabilities I see in SSL implementations. In that blog I spoke about SSLv2 and Weak Encryption settings. The blog primarily addressed how these vulnerabilities could be used to compromise the confidentiality SSL can provide. Other than confidentiality, SSL also can be used to provide authentication, non-repudiation, and integrity.

Many of the vulnerabilities I encounter undermine the authentication that SSL provides. Examples of these vulnerabilities include X.509 MD5 Signature Collisions, Self Signed Certificates, and Subject Common Name does not Match FQDN vulnerabilities. In this blog I want to address the significance of the authentication SSL provides. Many times we take for granted the authentication portion of SSL, but in reality we use on a regular basis the authentication that SSL provides.

When you connect to a site like https://www.PayPal.com, how do you know that you are not actually connecting to an evil hacker’s website which they also named https://www.PayPal.com? How can you be sure that an attacker has not poisoned the DNS server that you use to look up the IP address associated with PayPal’s website and you have actually been redirected to a hacker’s site that looks like PayPal? How can you be sure that when you enter your username and password into this site that an attacker is not capturing your credentials and is planning on using them to compromise your PayPal account? In order to help address these issues, an Internet-based public key infrastructure (PKI) has been developed. SSL uses this infrastructure in order to help provide you with a level of protection.

A PKI incorporates public key encryption (also named asymmetric encryption). In public key encryption a device uses two keys in order to provide encryption. The first key is called the private key. This key the device keeps secret and does not disclose to the public. The second key is called the public key, which the device sends to anyone who wishes to communicate with the device over an encrypted channel. Information encrypted with the device’s public key can be decrypted only with the private key, and information encrypted with the device’s private key can be decrypted only with the public key. When client side software such as a web browser attempts to connect to a device using public key encryption such as a secure web server, the public key is used by the client side software in order to establish a secure connection.

In order to tie the identity of an organization with its public key, a public key certificate is created. This association is performed through something called a digital signature. The public key certificate basically says that the website https://www.test.com is owned by Test Corp. and is associated with the public key of 12345. A public key certificate can be self signed or endorsed by a third party. Self signed certificates basically say “I am Test Corp., I own https://www.test.com, and the public key of this website is 12345, because I said so.” The second way the public key can be associated with its identity is through endorsements. This is when a third party validates that a particular public key is associated with an identity. This can be explained as follows. In order to provide authentication, a website can send its public key certificate to a trusted Certificate Authority (CA) such as VeriSign. The CA verifies that the organization is who they claim to be (VeriSign basically asks to see the organization’s driver’s license). Once the CA has verified that the organization is who they claim to be, and they do own the website they are asking the CA to validate, the CA will sign the public key certificate of the website.

The most common place to find SSL being implemented is on the World Wide Web. Today’s web browsers (Such as Internet Explorer and Firefox) are given a list of trusted CAs. When the web browser connects to a web server, the web server will present the browser its public key certificate. The browser will check the certificate to see who the CA was who signed it. The browser will look through its list of trusted CAs to see if it trusts the organization who signed the server’s public key certificate. If the website’s public key certificate was signed by a CA that the browser trusts, then the browser shows the user the website without complaining to the user. The web browser will in most cases provide a pretty little lock icon to the user in order to show that the site is secure (Isn’t this nice of the web browser?). If the CA is not trusted by the browser, the browser will start shouting that it does not trust the site (This is accomplished through warning messages the browser shows the user).

Let’s use a real world Example of how SSL is used. A site like https://www.PayPal.com wants to prove to everyone that they are really owned by PayPal. In order to provide this proof, PayPal will contact a trusted CA like VeriSign and ask them to tell everyone that they are really owned by PayPal (Because everyone trusts VeriSign). VeriSign will work with PayPal in order to verify their identity (Basically VeriSign asks PayPal for their Driver’s License). Once VeriSign has verified PayPal’s identity and that they own https://www.PayPal.com, they will “sign” the websites public key certificate. This signature shows that VeriSign has verified the website’s identity.

Along comes a user named Joe. Joe wants to use his web browser in order to connect to PayPal in order to purchase a new video game (Notice that Joe is cool, because he is not purchasing stuff like clothes). In order to prove to Joe that https://www.PayPal.com is really who they claim to be, PayPal shows the browser its public key certificate. The browser checks to see the CA who signed the public key certificate and sees that it was signed by VeriSign. The browser looks through its list of trusted CAs and sees that VeriSign is a trusted CA. The web browser shows Joe PayPal’s website without showing any warnings. The web browser also shows the proverbial lock on the web browser which makes everyone feel warm and fuzzy. Isn’t this story wonderful? It has the makings of a wonderful movie . . . suspense, trust, and victory . . . but I digress.

Now let’s see what happens if an attacker makes a fake website named https://PayPal.com. An evil hacker named Franz (I think Franz is a good name for a hacker) wants to capture Joe’s PayPal credentials. In order to do this, the evil hacker creates a site named https://www.PayPal.com. Franz cannot contact a trusted CA to have them verify his identity, because he does not own the domain for PayPal (He does not have PayPal’s driver’s license). Instead, the hacker signs his own public key certificate. Franz signs the public key certificate for https://www.PayPal.com and essentially says “I am PayPal, I own https://www.PayPal.com, and my public key is 12345, because I said so.” Franz now redirects Joe’s browser to his site which is named https://www.PayPal.com. Joe’s web browser checks to see who signed the certificate of the website. The browser does not see the signer of the public key certificate on its list of trusted CAs. The web browser tells Joe that something is wrong with the website’s certificate. If Joe is smart, he will be alarmed by these error messages and will drop his connection with the website.

Researchers at Carnegie Mellon University found that the majority of users will ignore these SSL warnings and continue to the website anyway. This paper can be found at the following link: http://www.usenix.org/event/sec09/tech/full_papers/sunshine.pdf.

So, in conclusion, before you go clicking through those SSL warnings, I encourage you to take a second and really consider the risk involved in these actions. If you do not wish to share the information you are sending with the entire world, I would suggest not sending your information to sites with these SSL warnings. It is important that you actually trust the site that you are connecting to before you give your credentials, SSN, Credit Card, etc.

-Gary McCully

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Brand Evolution

Evolution is key to survival in this business climate. That’s why SecureState has undergone a total rebranding effort and new website launch.

Overhauling your entire image is not necessary to rebrand. Simple tweaks to spruce up an image is often all that’s needed. And that’s what SecureState has done. There were already great ‘bones’ to the SecureState brand, so all we needed to do was freshen our image and allow our image to reflect the growth we’re experiencing. The changes have been integrated over a period of time and are now visible in every aspect of customer-facing material, from our Twitter page to client proposals and presentations to, of course, our brand new website, which has just been launched.

Speaking of our new website, be sure to check it out at www.securestate.com! A lot of hard work went in to ensure that our website is now in line with the image we wish to portray. Our website is also much more informative and user friendly, and showcases what’s best about our services and offerings.

One of the things you’ll probably immediately notice is that all of our rebranding has been incorporated throughout the website. We’ve also added a new Media Center–it’s a one-stop shop to find all of our new case studies, whitepapers, blog entries, events, social media outlets, and much more. Our homepage has been updated to allow easier access to our industry-specific service offerings and to highlight our client success stories, which scroll across the bottom.

The strength of our company is now better reflected in our brand. As SecureState continues to provide the best service possible, we’ll also continue to portray that in our identity.

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iPad - A PC Buddy

So it's day four (4) with the new gadget and along with the countless others that have reviewed the iPad I figured I would make it one more.

I am looking at the iPad from a business perspective, somewhat similar to the iPhone: can/should a business look at adopting the iPad? What have I found to be effective in my normal day in life as a CEO?

Waiting for the 3G? You will have to buy another data plan; the sim card in the iPad is a micro version, smaller than your iPhone. I was hoping I could switch sim cards, when using the iPad and not iPhone.

Typing. Hmm, lots of people are giving the iPad a thumbs down on typing; however, I typed this blog on my iPad. One thing you definitely need if you are going to type is the iPad case, $39. The case fits your iPad very nicely, and has a flap that folds under it, positioning the iPad at a 30' position for your hands to type (it also doubles as a picture frame). You cannot rest your hands on the key pad, but it helps in typing still. If you have typed on your iPhone before, the iPad is 100 times better!!

Tablet? Nope. It's not even close. I have a colleague that has been using a tablet PC for years and we both agree, if you want a working tablet the iPad is not for you. Others are referring to the iPad as a tablet PC; this is definitely not the case. In fact, when you first get the iPad you have to connect it to iTunes; it cannot "be useful" by itself.

First, it needs a buddy to work; you have to connect it to your PC before you can start to use it.

Second, you cannot access file shares or network drives; the only way (besides e-Mail) to transfer files is through iTunes.

Third, for those looking for handwriting recognition, it's not included. There are some apps that claim to do it, but the reviews are pretty poor. Also, the iPad doesn't come with a stylus (of course) so writing with your finger is a little awkward.

Video out. I purchased the VGA adaptor for the iPad, and was disappointed in a few things.

First, the video out doesn't display your entire iPad; only certain apps were written to output to the VGA adaptor.

Second, when using an app that does display via the VGA adaptor, the screen goes black, therefore you cannot see what you are displaying. I am also an adjunct professor and this really sucks for interactive presentations. On the bright side there is a built in laser pointer; if you hold down your finger, a red dot appears--pretty cool.

Pages, Keynote, Numbers. These applications have been rewritten specifically for the iPad. I am impressed with the functionality of the applications. Clearly when I want to do some heavy lifting with numbers I use my PC with Excel. You don't have to buy these applications to view Word, Excel, PowerPoint or other formats, similar to your iPhone. However, they are necessary if you are going beyond reading a document. One downside to Pages is that you cannot access the menu screen in landscape mode (which is the default with using the case).

Goodbye, Kindles. I haven't read a newspaper in years. I don't watch the news, either (see the Yes book by Jeffrey Gitomer), so I was amazed when I downloaded the USA Today app and read the paper! It is really nice to read and very interactive. In fact, reading anything on the iPad is a dream. When reading legal contracts or SOW I would prefer to print rather than read on my PC screen. Not the case with the iPad.

IPad for Kids. I bought two iPads, in the hopes of giving one to my kids (twins), who are seven. They have iPhones and Macbook Pros, so another Apple gadget would be perfect for them. I let my son use my iPad; the first thing he did was to go visit Club Penguin. "Bummer," he said, "just like my iPhone, I cannot download this thing called Flash". I chuckled; yep, Apple is still trying to figure that one out. Unfortunately this excludes me from moving the kids to the closed architecture of the iPad, which would be easier for them to use and keep up to-date.

Misc. As an FYI you can use the power cord extender if you have other Apple products; you will definitely need this with the iPad. The iPad power requirements are much greater than the iPhone; therefore, it charges really slowly when connected to your PC. Also the standard iPhone charger for your car doesn't work either; not enough juice.

There are no USB ports on the iPad, which again limits the functionality and ability to do "other" things with it.

Apps. The iPad can use iPhone apps, but you will definitely want to use apps tailored specifically to the iPad.

Mail. I am using the iPad for email (Exchange), my University email (Gmail), Calendaring, and of course web browsing. The interface for the email is really nice. I like to position the iPad in the landscape mode (which is how the iPad case does also).

To wrap up, if you are looking for a companion for your PC or a buddy to carry around, then the iPad is for you. I have been carrying mine around, and it is nice to use as described above. Where I used to use my iPhone to browse and access email, I now use my iPad. You definitely will find the iPad next to me at home and work, and if it's not being used by me, someone almost always is touching it.

by Ken Stasiak, CEO, President and Founder, SecureState

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The Prospect Theory Problem

At its essence, the decision to (or not to) implement information security policies or procedures is just a bet on odds. Anytime you risk anything of value on the outcome of something involving chance, you are gambling. No matter how you look at it, information security is, by definition, a gamble. This undeniable fact adds an interesting twist to the business decision-making process utilized by security decision makers when it comes to purchasing information security products and services.

Whether we realize it or not, we information security consultants frequently find ourselves outside the world of simple business logic and standard economics and more a part of the mysterious realm of game theory, prospect theory and probability transformations.

Let me explain.

In 1738, a Swiss mathematician named Daniel Bernoulli wrote a paper entitled Exposition of a New Theory on the Measurement of Risk, which introduced a new idea. The Idea was that economic risk is relative based on the perceived utility of the money by its recipient. In other words, an amount of money has less value to an already wealthy person than it has to a poor person. Using a mathematical function, Bernoulli theorized, one could correct the expected value based on variables like risk aversion, risk premium, payout level, etc. Bernoulli's paper was the first formalization of “marginal utility”, which was widely accepted and continues to have broad application in economics even today.

A couple hundred years later in 1979, two psychologists named Daniel Kahneman and Amos Tversky began expanding on the idea of Marginal Utility theory by conducting a series of experiments in Israel, the University of Stockholm and the University of Michigan on how the prospect of gaining versus losing money affected intrinsic risk calculation. It was from these experiments that “Prospect Theory” developed. Prospect Theory differs from Marginal Utility theory in a number of important respects.

First, it replaces the notion of “utility” with “value.” Whereas utility is usually defined only in terms of net wealth, value is defined in terms of gains and losses (deviations from a reference point). Moreover, they found that the value function for losses is significantly different than the value function for gains. In short, the loss of $X is always felt more than the gain of $X.

Kahnemann and Tversky came to their conclusions through uncovering an interesting and shockingly consistent pattern that they referred to as the reflection effect.

In a nutshell, here’s what they did: Test subjects were offered two choices, the first involving a potential loss, and the second, a potential gain.

Scenario One- The test subject was asked to pick between:
Option A: A 100% chance of losing $3000 or
Option B: An 80% chance of losing $4000, and a 20% chance of losing nothing.

Scenario Two - Next, choose between:
Option C: A 100% chance of receiving $3000 or
Option D: An 80% chance of receiving $4000, and a 20% chance of receiving nothing.

What the study showed was that 92% of the subjects chose option B in the first scenario, while only 20% chose option D, the seemingly equivalent choice, in the second scenario. They found that a similar pattern held regardless of positive and negative prizes, and probabilities. This led Kahnemann and Tversky to conclude that when decision problems involve not just possible gains, but also possible losses, people's preferences over negative prospects are more often than not the inverse of their preferences over positive prospects. Simply put – human beings are risk-averse when it comes to potential gains, but for some reason we become risk loving when faced with scenarios involving potential losses. Daniel Bernoulli didn’t account for that back in the 16th century.

The challenge for the information security professional is how to manage the Prospect Theory problem of an organization (or decision maker within the organization) that is normally fiscally cautious, becoming risk loving when discussing the potential impact of security failures. To some degree, regulatory compliance has forced large portions of the private sector to invest in risk management and mitigation activities whether they like it or not. However, there are still many organizations that require convincing, and Prospect Theory tells us that selling the idea of risk aversion in a loss-focused scenario will not be easy.

One way to approach this problem is through the pseudocertainty effect. The pseudocertainty effect demonstrates that people’s choices can be easily affected by simply reframing the descriptions of the outcomes without changing the actual utility or any of the facts. In other words, we transform what appears to be a potential loss into a potential gain. For example, ask yourself the following question:

Scenario One:
An epidemic breaks out that is likely to kill 600 people if left untreated.

Treatment strategy A: will save 200 people.

Treatment strategy B: has 1/3 chance of saving 600 people and 2/3 chance of saving nobody.

Which approach would you choose?

Scenario Two:
An epidemic breaks out that is likely to kill 600 people if left untreated.

Treatment strategy C: 400 people will die.

Treatment strategy D: there is a 1/3 probability that nobody will die, and a 2/3 probability that 600 people will die.

Which approach would you choose?

If you’re like most people, you recommended Treatment Strategy A in the first scenario. Most people (almost 3/4) prefer the definite positive outcome of saving 200 people, to the conditional but larger positive outcome of saving 600 people.

However, in the second scenario the same number of people choose Treatment Strategy D and are willing to accept the risk of a larger negative outcome (600 people dying) to have a chance of averting an otherwise definite negative outcome (400 people dying).

The fascinating thing about the two scenarios and the treatment options presented above is that the information in both of them is identical in every way. Treatment A is the same as Treatment C, and Treatment B is the same as Treatment D with no variation. The only difference is in the presentation, the wording. Everything else is identical and yet respondents consistently reach opposing conclusions for each scenario.

What this tells us is that we can lead our risk loving clients through important decisions about risk by framing the outcomes in a way that will satisfy their sense of value, and in turn, convert the risk-loving into the risk-averse; which is what good security management is all about. By understanding the client’s mindset, and framing our solution appropriately using Prospect Theory, we can increase the perceived value of information security services exponentially… even if the client didn’t realize we did it.

By Charles P. Braman, VP of Consulting

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Law and Disorder

When I look at our client base, there are two industries that are suspiciously low in the amount of security risk assessment work that we do. Typically, we have a relationship with law firms for forensics or CPA firms to assist with audits. It's rare that they actually have us perform risk assessments for their organizations. Mind you, it's not like they don't have a ton of sensitive information. In fact, you'd think 99% of their information is sensitive because another organization needed to share it with them for legal or audit purposes. One would think that sensitive information needs protection, especially if it isn't "yours." So my question is, "What makes these industries think they don’t need to conduct security risk assessments?", or more to the point, "What makes you so special?"

Part of the problem lies in the adage that "Nobody does security unless they have to." Translated, it means most organizations won't have a decent security program unless they get hit with compliance issues or a breach. What's that, you ask? “Aren't these firms subject to compliance?” I'm glad you asked that! These groups have a tendency to slip under the radar with a somewhat 'holier than thou' attitude. For example, let's look at the FTC Red Flags Rule to protect against ID theft. It's supposed to apply to companies that extend credit to persons or corporations, although the term 'creditor' is very broad in scope. When the American Bar Association realized it applied to them, they responded by suing the FTC and were granted exemption. They did the same thing when the Gramm-Leach-Bliley Act (GLBA) was passed for financial institutions and applied to lawyers who did financial planning. About the same time, the American Institute of CPAs also petitioned for Red Flag exemption. They have lobbied for exemption from the Consumer Financial Protection Agency Act of 2009 as well.

Of course, there are problems with the 'it’s not my problem' approach and we really need to read between the lines here a bit. If you look at something as basic as the FTC Red Flags Rule, it really isn't asking for all that difficult of a program - basic security, privacy, and notification. It's not like they are being asked to be ISO 27001 or PCI compliant. So why did the ABA and AICPA push back so hard? They both claim that due to the nature of their business, ID theft is very low risk. Of course, I believe they would not have pushed back if they had enough of a security program to meet the Red Flags Rule. Therefore, I'd bet most of them don't have one. They also said these things could be cost prohibitive to small CPA firms. But when it came time for an exemption to SOX 404(b) for small businesses that the CPA firms assess, the Center for Audit Quality, associated with the AICPA, fought it because that might hurt the investors that are supposed to be protected. So are we supposed to conclude they want to help the investor, but not the consumer?

Today, however, these firms are running of out wiggle room. There is an onslaught of compliance that sooner or later will be inevitable. For example, with the HITECH Act in ARRA, firms now realize they are pretty much stuck with HIPAA compliance if they handle PHI from a client as a Business Associate. They also realize that private standards, like PCI, that are enforced through contract now are unavoidable. Additionally, if firms have clients in states like Massachusetts and Nevada which have new trends in breach laws that include prevention, and not just notification, they likely are subject.

Of course, some of these compliances allow for risk-based decisions in which the firms may decide , like they did with Red Flag, that they think the organization still is low risk. I suppose it just will take some breaches to create a more sobering atmosphere. There is almost no industry that can really afford to adopt the 'it would never happen here' mentality, as we see breaches aren't just focused on financial institutions. Don't forget that the bad guys are both highly organized as well as lazy. If they recognize that there are 'soft spots' here, it could lead to some serious concentration of efforts on these gold mines of sensitive information.

The point is not to say that all law and CPA firms are ignorant of security risks and ripe for a breach. It's more to state that there is a general attitude problem that needs a big reality check. Eventually, these organizations need to increase their security posture and incorporate assessments for quality management. The early adopters will reap the benefits of understanding their risks sooner so they can minimize their risks earlier, or have more time to do so before being confronted with compliance deadlines.

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Changing the Landscape of Pentesting

Though I believe penetration assessments to be important in assessing an organization’s overall security posture, I think they are 1) being performed poorly and 2) the results from them are being disseminated in a wrong way. The goal of any security assessment is to help an organization become MORE secure than they were before the assessment was performed thus reducing their overall risk. Many penetration assessments are performed by identifying vulnerabilities and breaking into as many systems as possible by exploiting these vulnerabilities. The report is then issued which has the list of these vulnerabilities, a perceived risk rating, and finally recommendations on how to remediate the vulnerabilities. What many pentesters lose sight of is the objective for performing the penetration assessment to begin with: to help the client become MORE secure. This type of penetration assessment provides absolutely no value to the client and certainly does not make them any more secure.

Many pentesters don’t see an unencrypted service enabled on a firewall which protects an organization’s PCI zone and wonder “why” this service is allowed but rather how I can use this service to break into this system. The recommendation for such vulnerability would be to use a more secure service; however, what is lost is “why” the vulnerability occurred in the first place and the impact to the business if such vulnerability was exploited especially with regard to the environment in which it was discovered. A penetration assessment needs to be just as much interview based (if not more) as it does technical. Without understanding the underlying reasons as to why such vulnerabilities occurred in the first place, it is impossible to provide any other recommendations other than tactical to the client. The client will then tactically remediate the vulnerability maybe by updating a system with a specific patch or shutting down a specific service and then a year later vulnerabilities of a similar nature will resurface. Why? Because the underlying reasons as to why such vulnerabilities occurred in the first place are unknown. Is it a patch management problem? Is it a change management problem? Are there no policies and procedures or minimum security baselines preventing such vulnerabilities? Is it a management problem? Is it a line-of-business problem? Is it a combination of the above? The list goes on and on, but without trying to understand the “why” it is impossible to truly help the client. It is no longer acceptable to report that the entire compromise of an organization’s Windows domain was obtained without at least attempting to
understand “why” it was possible and how to protect against future occurrences.

Today’s market has become so diluted with companies and individuals claiming they can perform penetration assessments (if you don’t believe me attend Defcon one year). Organizations need to have a better understanding as to how these hired service providers are actually performing these assessments. If a company performs security assessments with little or no interaction with their client, be very skeptical of using this company. As the old cliche goes, you get what you pay for. Bottom line is, penetration testing is no longer for the geeky technical guy who only cares about breaking into systems or for someone who knows how to run a vulnerability scanner. It’s for professionals who truly understand security and are interested in really helping an organization reduce their overall risk.

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Periodic PCI Compliance Activities

I am often asked what are the activities companies must perform between PCI assessments in order to remain compliant with the PCI standard. Many people would be surprised to find out that the PCI DSS outlines the specific tasks companies must be doing all the time. The following activities were taken directly from the PCI DSS Version 1.2.1 and outline the periodic procedures companies must take to stay compliant:

Annually

3.6.4 Periodic cryptographic key changes:

• As deemed necessary and recommended by the associated application (for example, re-keying); preferably automatically
• At least annually

6.6 For public-facing web applications, address new threats and vulnerabilities on an ongoing basis and ensure these applications are protected against known attacks by either of the following methods:

• Reviewing public-facing web applications via manual or automated application vulnerability security assessment tools or methods, at least annually and after any changes.
• Installing a web-application firewall in front of public-facing web applications.

9.5 Store media back-ups in a secure location, preferably an off-site facility such as an alternate or backup site or a commercial storage facility. Review the location’s security at least annually.

9.9.1 Properly maintain inventory logs of all media and conduct media inventories at least annually.

11.3 Perform external and internal penetration testing at least once a year and after any significant infrastructure or application upgrade or modification.

12.1.2 Annual process that identifies threats, vulnerabilities, and results in a formal risk assessment.

12.1.3 Perform a Security Policy review at least once a year and update when the environment changes.

12.6.1 Educate employees upon hire and at least annually.

12.6.2 Require employees to acknowledge at least annually that they have read and understood the company’s security policy and procedures.

12.9.2 Test Incident Response Plan at least annually.

Bi-Annually

1.1.6 Review firewall and router rule sets at least every six months.

Quarterly

8.5.5 Remove/disable inactive user accounts at least every 90 days.

8.5.9 Change user passwords at least every 90 days.

9.1.1 Use video cameras or other access control mechanisms to monitor individual physical access to sensitive areas. Review collected data and correlate with other entries. Store for at least three months, unless otherwise restricted by law.

11.1 Test for the presence of wireless access points by using a wireless analyzer at least quarterly or deploy a wireless IDS/IPS to identify all wireless devices in use.

11.2 Run internal and external network vulnerability scans at least quarterly and after any significant change in the network (such as new system component installations, changes in network topology, firewall rule modifications, product upgrades).

Weekly

11.5 Deploy file integrity monitoring software to alert personnel to unauthorized modification of critical system files, configuration files or content files; and configure the software to perform critical file comparisons at least weekly.

Daily

10.6 Review logs for all system components at least daily. Log reviews must include those servers that perform security functions like intrusion detection system (IDS) and authentication, authorization, and accounting protocol (AAA) servers (for example, RADIUS).

12.2 Develop daily operational security procedures that are consistent with requirements in this specification (for example, user account maintenance procedures, and log review procedures).

Immediately

8.5.3 Set first-time passwords to a unique value for each user and change immediately after the first use.

8.5.4 Immediately revoke access for any terminated users.

12.3.9 Activation of remote-access technologies for vendors only when needed by vendors, with immediate deactivation after use.

Not specified, but suggest annually

12.8.4 Maintain a program to monitor service providers’ PCI DSS compliance status.

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