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“SDVOSB” – Mark Consulting Group Registers as Service Disabled Veteran Owned Small Busines August 3, 2012

Posted by Chris Mark in News.
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I have finally completed the Department of Veterans Affairs and the SAM (formerly CCR etc.) registration process to have Mark Consulting Group certified as a Service Disabled Veteran Owned Small Business (SDVOSB).  Hopefully, the VA will complete verification within a few days.  If you are in need of information services please consider The Mark Consulting Group.

According to the United States Code of Federal Regulations, a Service Disabled Veteran Owned Small Business (SDVOSB) is formally defined thus:“A service-disabled veteran-owned small business concern is a business not less than 51 percent of which is owned by one or more service-disabled veterans, or in the case of any publicly owned business, not less than 51 percent of the stock of which is owned by one or more service-disabled veterans; the management and daily business operations of which are controlled by one or more service-disabled veterans, or in the case of a veteran with a permanent and severe disability, a spouse or permanent caregiver of such veteran. In addition, some businesses may be owned and operated by an eligible surviving spouse. Reservists or members of the National Guard disabled from a disease or injury incurred or aggravated in line of duty or while in training status also qualify.”

“The Fortress Mentality & Data Compromises” – Chris & Heather Mark in August 2012 TransactionWorld Magazine July 31, 2012

Posted by Chris Mark in cybersecurity, Data Breach.
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This month’s TransactionWorld magazine includes an article by me (Chris Mark) titled: “The Impact Of the Fortress Mentality and Today’s Compliance Strategies”.  The article discusses, among other things, the Global Payments breach, PCI DSS compliance, and provides an overview and opinion on today’s focus on compliance with static standards as opposed to risk based information security.  One important note. I neglected to send an updated BIO to the editor so it still references my position at ProPay.  I have not worked at ProPay for over a year 😉  You can read more about my company Mark Consulting Group at www.MarkConsultingGroup.com.

Heather Mark is also in this month’s TransactionWorld with an article titled: “After the Compromise: Incident Response Plans and Mitigating the Damage”  Heather speaks about data compromises and provides good insight into strategies companies can employ to minimize the impact of such breaches.

“NSA Says – Largest Transfer of Wealth…EVER”; CyberAttacks rose 44% in 2011 July 10, 2012

Posted by Chris Mark in cybersecurity, Industry News.
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Parroting what many in the payments industry have known for years, the NSA released a statement about the dire state of cybersecurity.  According to the head of the National Security Agency cyberattacks increased 44% in 2011 and now account for the largest “transfer of wealth in history”.    According to FoxNews: 

“NSA chief Keith Alexander was speaking Monday at an American Enterprise Institute event in Washington, D.C.  He said that for every company that knows it has been hacked, another 100 do not know their systems have been breached. (emphasis added) The warning came on the same day that thousands of computer users were at risk of losing Internet access, due to malware that spread more than a year ago. Citing public and unclassified statistics, Alexander said Monday there are now 75 million unique pieces of malware on the loose.”

Those of use who have been in the industry for years have said that we are ‘losing the war’. I have personally been chastised for making such doom and gloom statements.  The facts are the facts however.  Hiding our head in the sand will not change the fact that “The criminals are absolutely ripping us to shreds,” and that “We’re losing the battle…That’s the reality of it.” (Chris Mark quoted in Salt Lake Tribune...pic at top).  In yet another push at self promotion..you can read one reason we are losing the battle in the IDGA research brief: “A Failed State of Security”.

“Are You Eating a Rotten Apple?” – Personal Data May have Been Exposed in Global Payments Breach July 9, 2012

Posted by Chris Mark in cybersecurity, Data Breach, Industry News, InfoSec & Privacy, PCI DSS, Risk & Risk Management.
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Let me preface this post by saying this is not intended to take shots at either Global Payments or the PCI DSS.  Rather, this post is intended to generate discussion and discourse on the topic of compliance and risk management.

According to reports, it seems that the Global Payments data breach may have exposed more than payment card data.  n a June 12 update posted to its breach microsite, Global says hackers may have gained access to servers containing personal information collected from a subset of merchant customers.

“The company will notify potentially affected individuals in the coming days with helpful information and make available credit monitoring and identity protection insurance at no cost,” Global says. “The notifications are unrelated to cardholder data and pertain to individuals associated with a subset of the company’s U.S. merchant applicants.”

Based upon this statement it seems fair to assume that Personally Identifiable Information (PII) such as Social Security number and Bank Account information may have been exposed, as well.

This situation exposes the danger of using a narrowly focused, static standard as a baseline of security management rather than adopting a risk based approach to data security.   I have personally conducted over 100 PCI DSS audits and have seen first hand the resources consumed by the standard.  Companies often appear so laser focused upon protecting payment card data that other systems and data may take a back seat in the pursuit of “PCI DSS compliance.”  As there are significant penalties associated with non-compliance that it is difficult to blame the merchant or service provider. The penalties are designed to compel compliance with the standard.  As such, companies are going to give precedent to the PCI DSS over any other standard that does not have equivalent penalties associated with non compliance.

As a reminder, the PCI DSS is ONLY focused protection of Cardholder Data.  Surely some are going to say that the PCI should be applied across all systems etc.etc.  This is great in theory but does not happen in practice.  Companies take great pains to minimize their cardholder data environment specifically to lessen the compliance burden.

I am sure we will continue to see breaches of payment card companies having PII exposed as companies focus on PCI to the exclusion of risk based security management.

COMTEC 2012 – Chris Mark Training on PCI & Payment Card Security July 6, 2012

Posted by Chris Mark in Industry News, Uncategorized.
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2012 is the year for COMTEC once again and the fine folks at TouchNet have invited me to conduct a training on Payment Card Security & PCI DSS at their October COMTEC event.  COMTEC is a great event for TouchNet’s clients.  The name comes from Commerce and Technology..  The session will be titled:

PCI Training: Full Cycle Compliance – Crisis – Recovery

“During this unique pre-conference workshop, you’ll investigate the full spectrum of PCI compliance and readiness. Attendees will better understand everything PCI, from the basics of PCI compliance to planning for the real-world impact of a breach and what to do in its aftermath.”

It is always positive to see that in 2012 there are still organizations that are taking a leadership role to educate their own customers on the importance of information security.