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Property of the University of Notre Dame
Copyright David Seidl, Bob Winding, Mike Chapple, Bob Richman, 2008. This work is the intellectual property of the author. Permission is granted for this material to be shared for non-commercial, educational purposes, provided that this copyright statement appears on the reproduced materials and notice is given that the copying is by permission of the author. To disseminate otherwise or to republish requires written permission from the author.
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The Data Center Within A Data Center:
Building A Secure Environment For Compliance
EDUCAUSE Security ProfessionalsMay, 2008
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Why Are We Here Today?
• Universities are dealing with increasing compliance burdens.– HIPAA, FERPA, GLBA, PCI DSS, FDA, and more
• Management is more open to solutions that spend up front money to control staff and infrastructure costs over time.– Simplification of compliance efforts is key.
• Current technology allows new approaches.– Virtualization and segmentation
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Agenda
• PCI DSS Background• Notre Dame’s Environment• Payment Card Environment Design• Networking Infrastructure• Deployment: Departments and Decentralized IT
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Payment Card IndustryData Security Standard(PCI DSS)
Visa CardholderInformation Security Program (CISP)
PCI DSS History
Mastercard SiteData Protection Program (SDP)
Discover InformationSecurity ComplianceProgram (DISC)
American ExpressData Security Standard (DSS)
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Compliance Requirements: the Digital Dozen
Build and Maintain a Secure Network
Install and maintain a firewall configuration to protect cardholder dataDo not use vendor-supplied defaults for system passwords and other security parameters
Protect Cardholder DataProtect stored cardholder dataEncrypt transmission of cardholder data across open, public networks
Maintain a Vulnerability Management Program
Use and regularly update anti-virus softwareDevelop and maintain secure systems and applications
Implement Strong Access Control Measures
Restrict access to cardholder data by business need-to-knowAssign a unique ID to each person with computer accessRestrict physical access to cardholder data
Regularly Monitor and Test Networks
Track and monitor all access to network resources and cardholder dataRegularly test security systems and processes
Maintain an Information Security Policy Maintain a policy that addresses information security
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Who Must Comply?
• “Payment Card Industry (PCI) Data Security requirements apply to all Members, merchants, and service providers that store, process or transmit cardholder data.”
• “Additionally, these security requirements apply to all system components which is defined as any network component, server, or application included in, or connected to, the cardholder data environment.”
That Probably Means You
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Merchant Levels
Merchant Level Description
1 Any merchant who processes over 6,000,000 transactions annually.Any merchant designated Level 1 by Visa
2 Any merchant who processes between 1,000,000 and 6,000,000 transactions annually.
3 Any merchant who processes between 20,000 and 150,000 e-commerce transactions annually.
4 Anyone else
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Merchant Levels
• All merchants, regardless of level, must comply with all elements of the PCI DSS standard!
• Merchants at different levels have different validation requirements– Higher merchant levels cost significantly more to
meet validation requirements.
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Consequences• Reputational Risk
– What will the impact be on your institution’s brand?– Mandatory involvement of federal law enforcement in
investigation
• Financial Risk– Merchant banks may pass on substantial fines– Up to $500,000 per incident from Visa alone– Civil liability and cost of providing ID theft protection
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Consequences• Compliance Risk
– Exposure to Level 1 validation requirements
• Operational Risk– Visa-imposed operational restrictions– Potential loss of card processing privileges
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Agenda
• PCI DSS Background• Notre Dame’s Environment• Payment Card Environment Design• Networking Infrastructure• Deployment: Departments and decentralized IT
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Notre Dame’s Environment, Circa 2006
• Over 70 merchant accounts, 15 applications• No central oversight• One day all of that changed…
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• (Campus payment diagram)
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Notre Dame’s Approach• First, we conducted a risk assessment in
conjunction with a PCI consulting firm
• From that, launched a credit card security program– First Goal: Minimize on-campus card processing– Second Goal: Migrate existing systems to a dedicated,
isolated network
• Then we worked to reduce our footprint and then secure what was left
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Reducing Our PCI Footprint
• Identify merchant accounts and payment locations.
• Assess which systems can be moved to 3rd party vendors.– Non-specialized systems are the low hanging fruit.
• Simplify environments where possible.
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Design Concept
• PCI compliance requirements apply by contagion: anything that touches it becomes infected.
• Separating using acceptable methods decreases your compliance footprint.
• VPN, firewalling, and dedicated infrastructure make control simpler.
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Agenda
• PCI DSS Background• Notre Dame’s Environment• Payment Card Environment Design• Networking Infrastructure• Deployment: Departments and decentralized IT
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The Datacenter Within A Datacenter
• Identify all services needed for the card processing systems:– Management systems– Infrastructure support– Compliance systems– Monitoring systems
• Scope and size systems• Set standards for those systems
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Design: ND’s PCI Architecture
• Architecture diagram not included for public release.
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System and Security Components
• Secure Computing Firewall• Cisco VPN• Two factor Safeword authentication to
infrastructure (VPN)• Tripwire server integrity assurance• Juniper IDS• Qualys vulnerability scanners – inside, campus
perspective, and off-campus viewpoints.– PCI compliance module
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System and Security Components
• Infrastructure – NTP, AD, ePO AV, monitoring, IP KVM, central logging, update servers, etc.
• POS clients and servers– Device configuration standards
• WebInspect• HighTower SIM device for log and event
analysis and monitoring.
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Firewall and IDS design
• Firewall isolates all PCI traffic• Single external physical interface• Single internal interface with multiple VLANs• Zones organized by function• Some special zones for campus systems• Remote Sites connected through VPN concentrator• Passive IDS (tried IPS) monitors all internal traffic
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Sidewinder Firewall
• Application proxy firewall• Default deny inbound and outbound• Group based VPN, access restricted by job
function• Least privilege rule base • All access explicitly controlled
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Key Internal Zones
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Key Internal Zones
DMZ BURB (192.168.5.0/24)
POS BURB (192.168.3.0/24)
Application Servers
Public Web Servers
DNS
NETMGT BURB (192.168.6.0/24)
Network gear interfacesIDS/IPS Sensor -
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Key Internal Zones
192.168.7.0/24 – Odyssey Private
192.168.58.240/29 – Odyssey Public
Backup BURB (192.168.8.0/24)
Odyssey Burbs
ScribeScanner BURB (192.168.15.0/29)
scanner
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Isolating Systems
• Diagram not provided for public release.
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Isolating SystemsInternet/Campus
`
VulnerabilityScanner
DatacenterFirewall
`
Odyssey
`
Central Backup
Private
Private
Public
PCI Firewall
PCI Interface
Datacenter
All system interfaces are on dedicated logical firewall
interfaces
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Agenda
• PCI DSS Background• Notre Dame’s Environment• Payment Card Environment Design• Networking Infrastructure• Deployment: Departments and decentralized IT
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Network Design
From the PCI Standards Document:1.Encryption of data over open, public networks2.Follow change control procedures3.Review logs for all system components daily
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Challenges
Encryption of data over open, public networks.• Required over ‘secure’ vlans?
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Challenges
Follow change control procedures.– Initial design thoughts incorporated ‘secure’ vlans
that we present at each endpoint on campus.– This would have involved implementing change
control on more than 150 network devices, including access layer switches.
Review logs for all system components daily.– Workload for 150 devices would have been high
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Devices requiring change control with ‘secure’ vlan
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Our solution: Remote site VPNs
• Utilizes Cisco 3015 VPN concentrator with Cisco 851 VPN routers for endpoints.
• Extends the PCI network where we need it.• We provide user subnet space based on
customer need:– Stand-alone credit card terminals– POS devices– Single use computers
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Additional Benefits of VPN
• The VPN tunnel provides a secure method of managing network devices.
• Provides a means of remote access for system administrators
• Fewer devices to manage.• Provides for easier additions to the PCI
network.
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Agenda
• PCI DSS Background• Notre Dame’s Environment• Payment Card Environment Design• Networking Infrastructure• Deployment: Departments and decentralized IT
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Deployment: Departments and Decentralized IT
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Two Types of Support• Central IT
– Fewer technical users.– Existing payment
solutions are often inherited.
– Responsibility for payment system is often not clearly defined.
• Departmental IT– Internal processes and
procedures.– Often very small staff,
broad responsibilities.– Payment solutions are
often provided by external vendors.
– Responsibility for payment system is often inherited.
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Existing systems• Food Services
– Many terminals– Other services blended
in: vending machines, food service displays, and campus “Domer Dollars”
– Many locations– Blend of commercial and
custom software– Departmental IT
• Theater Ticketing and Events– Single location– Mobile and static
workstations– Web driven– Single commercial
software package– Only standard
transactions– Central IT
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Deployment Steps
• Review existing architecture• Design solution• Build required resources• Test• Migrate into production
– Often in phases– Often unexpected hurdles due to legacy systems
and applications
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Challenges
• Process: creating a controlled system for adding new systems and handling changes.
• Lack of vendor documentation of protocols – many large high port groupings, reliance local broadcast for discovery, etc.
• Split system administration• DR for systems designed without DR
capabilities.
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Lessons Learned
• Review vendor documentation and current implementation.– Historic designs are often still in use.
• Dataflow diagrams are crucial.• Provide a fast troubleshooting process and a
defined support team. • Provide a single point of responsibility with
backup for migrations.
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Questions
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