Compliance-based security doesn't always provide protection against determined attacks. This was the unfortunate case in the recent breaches of Target, Neiman-Marcus, and Michaels Stores. According to the investigation, the retail chain was aware that such a breach could happen, but it still ignored warnings.

“Michaels knew that its POS systems were vulnerable to attack. Dr. Neal Krawetz, a cyber-security expert, published a white paper in August 2007 alerting major retailers, including Target, to the risk of POS cyber-attacks,” said Tom Loeser, a Hagens Berman partner and former federal prosecutor in the Cyber and Intellectual Property Crimes Section of the U.S. Attorney's Office in Los Angeles, in a statement.

The firm has filed a case against Target in the U.S. District Court for the Northern District of California, alleging the company is liable for consumers' losses. That complaint states that Krawetz alerted Target and other major national retail chains about their vulnerability to attack in a white paper outlining POS security issues.

“There are at least two compelling common facts among Target, Neiman Marcus and now Michaels,” Loeser said. “The first is that the method of attack and the tools used were not unknown. In addition to being warned as early as 2007 of the risk of this type of attack, the particular type of malware the attackers used was known to cyber-security experts as early as 2011, and a version very similar to the version in the Target data breach was known to experts as early as January 2013.”

“Second, none of these companies apparently had any clue that their network systems and security had been breached for quite some time after payment card data was flowing to the attackers,” Loeser continued. “Adequate monitoring of system traffic and data exfiltration is a rudimentary element of any reasonable network security protocol and early detection in these recent attacks could have prevented millions of consumers from having their financial and personal information stolen.”

Compliance requirements like the Payment Card Industry (PCI) Data Security Standard (PCI/DSS) give the illusion of security, according to Information Week. These requirements reduce risk, however they are incomplete because they fail to provide flexibility to adjust according to a company's true security needs. Security is another business risk, so executives must look at the best information they can find in order to make the smartest decisions possible.

Recent court decisions demonstrate that meeting an industry-compliance requirement, like PCI, is insufficient in meeting the standard. The courts want to know whether corporations have done what is reasonable for their companies versus whether they have they met a compliance prerequisite. The challenge for security professionals is how to bridge this gap.

Many CIOs are faced with two directives: Adopt the ISO 27000 framework and improve PCI compliance. PCI is a subset of ISO 27000 security controls focused on the credit card payment zone, generally defined as anywhere on a network credit card information traverses and is stored. The answer to connecting the two seems to lie in the origins of PCI. ISO 27000 breaks information security into ten areas of focus and labels them from four to fourteen. Each of these has multiple security controls that provide guidance to reduce an organization's risk profile.

This combination will allow an organization the flexibility of ISO 27000 and still meet the requirements of PCI.

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