PCI Auditing Difficulties Number 1

Systems and System Boundarieshad to re-think our definition of what a "System" is,
This series of white papers is presented as a publicbut the thought process freed us to expand our
service by Mindteck Consulting as part of its ongoingthoughts about exactly what constitutes a computer
effort to help businesses achieve a higher informationsystem.
security posture. Each article is written to focusA client was looking for a pre-PCI audit. They were a
specifically on one topic to be as specific and usefulsmall shop and it was obvious that they were very
as possible.concerned about controlling their IT costs. They ran a
System Auditing, Security Assessment, C&Adozen servers, all with Virtualization Software
and even PCI Audits have many things in commoninstalled, so that these 12 physical servers actually
despite some notable differences. All these processeshoused 31 different Operating Systems. The
start from a common point, normally a snapshot ofparticular server which housed the database with
an organization at a particular point in time. They allcredit card information also had 2 additional instances
then evaluate the enterprise and its electronic assetsof the virtualization software, thus one server
to arrive a final point, whether that point is a Passactually housed 3 separate OS's. (A word of
Fail or a numerical score or a Risk Rating is irrelevantexplanation about software virtualization is needed
for our purposes. A problem common to all thesehere. There are a bewildering array of virtualization
assessment methodologies is Defining Systems andproducts on the market that can virtualize everything
System Boundaries.from a single internet session to the entire Operating
A "System" is defined as "a regularly interacting orSystem. Our client used this latter type of software,
interdependent group of items forming a unifiedvirtualizing two Windows XP's and one Redhat Linux
whole " and also as a "any network component,installation. This type of virtualization solution is called
server, or application included in or connected to the"native" or "full virtualization".) One of the Windows
... data environment ." Using these definitions works inXP Server instances housed the client's Point of Sale
about 90% of instances that we are likely to(POS) software and database of credit card
encounter. The remaining 10% is tough. The difficultinformation. Access to this particular server was
part comes when we are faced with technology thatcontrolled by a firewall Access Control List (ACL) as
introduces situations that don't easily fit our commonwell as 2 factor authentication by the user. The pool
notions of what a "System" is. And without a crystalof potential users was very small at only 3 individuals.
clear idea of what systems exist within a particularInitially this seemed like a very easy case and it
organization, it is next to impossible to define theirlooked like it would easily fall within the PCI DSS
boundaries. It is in these areas of uncertainty, or greyStandards. However, the server virtualization is the
areas, that we prove our worth as Information"fly in the ointment" because the PCI DSS Council
Security Professionals. Some examples of particularlyhad not yet fully addressed virtualization. We sought
difficult instances, along with the ways that we havesome guidance from the PCI forums as well as
dealt with them, follow.relying on our own experience in evaluating this
Virtual Machinesmachine more closely. We audited each logical
There was a day not so long ago where a computerinstance of a computer "system" on the server, but
was either a server or a workstation. One computer,tempering this evaluation with the knowledge that
one function (server or workstation), one OS andthese logical instance do not exist in a vacuum and
therefore one "System". But these lines beganthat each one is deeply dependent on the hardware
blurring a few years ago with the release ofand software resident on the box.
VMWare, Xen, Windows Virtual Machine and the like.Once we replaced our traditional ideas of "systems"
Now it was possible for one computer to holdequating to one physical computer, we began to
multiple Operating Systems each running in its own,think in terms of "logical instances". While this method
protected and isolated instance (or so the storyof dealing with computer systems is not without
went). This situation posed and continues to poseproblems, it has helped our practice immensely with
perhaps the greats problem to defining systems thatour auditing assignments.
IS Professionals face today. For this first example we