PCI DSS POS breach: Do you allow 3rd party access to your systems or provide IT services to customers with Governance, Risk Management and Compliance responsibilities?

Every Password is a Prize

The interesting thing about the breach reported by Vancouver-based Information Systems & Supplies Inc. is that it highlights the responsibility now borne by 3rd party suppliers to PCI merchants. Remote access services such as LogMeIn or TeamViewer provide superb levels of functionality equivalent to a direct Remote Desktop session, and, naturally, are highly secure in their architecture and operation.

But if account credentials are stolen, direct access to Customer Systems is then afforded to the password thief and all of a sudden, the feature-rich, easy-access remote access service will be providing the ultimate hacker portal to the customer’s sensitive data. Full remote control with two-way file transfer makes things way too easy!

Details of this particular incident are sketchy as always, but it could be inferred from what we do know that a simple phishing attack struck lucky with one of the employees at IS&S. This, in turn, led ultimately to their LogMeIn account credentials being abused. IS&S provide POS systems to a large number of hospitality/restaurant businesses and seemingly have LogMeIn access to customer sites for support. It is not yet clear if customers have been affected by any data loss.

3rd Party Service Provider or Hacker-Portal Provider?

If your business involves providing remote IT systems support to your customers this serves as a gentle reminder that you are responsible for maintaining unassailable standards of security. More to the point, you have almost certainly agreed in your contract with your customer that you will indemnify them from any breach resulting from your side. If you have provided an ‘SAQ-D for Service Providers’ then you are absolutely responsible for operating security best practices determined by the PCI DSS. Conversely, if you are a PCI Merchant or Payment Provider then now is the time to make sure that your IT Service Providers have provided an appropriate indemnification to you.

No escape for the SOX, NIST 800-53, and HIPAA club either

Now, even if PCI Compliance isn’t relevant to you in either context as a consumer or provider of 3rd Party IT Services, then this still should resonate with most organizations, for example,

• Healthcare providers (with respect to HIPAA compliance)
• Federal organizations (with respect to NIST 800-53)
• Listed Companies or Accounting firms (subject to SOX)

All of these governance, risk management, and compliance (GRC) standards require the highest levels of security to be maintained, including device hardening, vulnerability management, and file integrity monitoring, and in turn, making adherence to equivalent levels of security mandatory for 3rd party service providers too.

Time to check the small print on those contracts…