Using Amazon EC2 for PCI DSS compliant applications

Compliance and regulatory concerns are often voiced when it comes to Cloud Computing, and often many of the interesting types of applications organisations would like to deploy to the cloud are  often those governed by some form of regulatory standard. Lets look in more details at one of these.

PCI DSS is a set of comprehensive requirements for enhancing payment account data security and was developed by the founding payment brands of the PCI Security Standards Council, including American Express, Discover Financial Services, JCB International, MasterCard Worldwide and Visa Inc. Inc. International, to help facilitate the broad adoption of consistent data security measures on a global basis.

The PCI DSS is a multifaceted security standard that includes requirements for security management, policies, procedures, network architecture, software design and other critical protective measures. This comprehensive standard is intended to help organizations proactively protect customer account data.

So, is it possible to create a PCI DSS compliant application that can be deployed to EC2 ?

In order for an application or system to become PCI DSS compliant requires an end to end system design (or a review if pre-existing) and implementation.  In the case of AWS customer’s attaining PCI compliance (certification), they would have to ensure they met all of the prescribed requirements through the use of encryption etc. very much like other customers have done with HIPAA applications.  The AWS design allows for customers with varying security and compliance requirements to build to those standards in a customized way.

There are different levels of PCI compliance and the secondary level is quite a straight forward configuration, but requires additional things such as 3rd party external scanning (annually).  You can find an example here of the PCI Scan report that is done on a quarterly basis for the Amazon platform.  This isn’t meant to be a replacement for the annual scan requirement. Customers undergoing PCI certification should have a dedicated scan that includes their complete solution, therefore certifying the entire capability, not just the Amazon infrastructure.

 The principles and accompanying requirements, around which the specific elements of the DSS are organized are:

 Build and Maintain a Secure Network

Requirement 1: Install and maintain a firewall configuration to protect cardholder data

Requirement 2: Do not use vendor-supplied defaults for system passwords and other security parameters Protect Cardholder Data

Requirement 3: Protect stored cardholder data

Requirement 4: Encrypt transmission of cardholder data across open, public networks Maintain a Vulnerability Management Program

Requirement 5: Use and regularly update anti-virus software

Requirement 6: Develop and maintain secure systems and applications Implement Strong Access Control Measures

Requirement 7: Restrict access to cardholder data by business need-to-know

Requirement 8: Assign a unique ID to each person with computer access

Requirement 9: Restrict physical access to cardholder data Regularly Monitor and Test Networks

Requirement 10: Track and monitor all access to network resources and cardholder data

Requirement 11: Regularly test security systems and processes Maintain an Information Security Policy

Requirement 12: Maintain a policy that addresses information security

Many of these requirements can’t be met strictly by a datacenter provider, but in Amazon’s case, they will be able to provide an SAS70 Type 2 Audit Statement in July that will provide much of the infrastructure information needed to meet PCI DSS certification.  The Control Objectives that the Amazon Audit will address are:

 Control Objective 1: Security Organization:  Management sets a clear information security policy. The policy is communicated throughout the organization to users

 Control Objective 2: Amazon Employee Lifecycle:  Controls provide reasonable assurance that procedures have been established so that Amazon employee accounts are added, modified and deleted in a timely manner and reviewed on a periodic basis to reduce the risk of unauthorized / inappropriate access

 Control Objective 3: Logical Security:  Controls provide reasonable assurance that unauthorized internal and external access to data is appropriately restricted

Control Objective 4: Access to Customer Data:  Controls provide reasonable assurance that access to customer data is managed by the customer and appropriately segregated from other customers

Control Objective 5: Secure Data Handling:  Controls provide reasonable assurance that data handling between customer point of initiation to Amazon storage location is secured and mapped accurately

 Control Objective 6: Physical Security:  Controls provide reasonable assurance that physical access to Amazon’s operations building and the data centers is restricted to authorized personnel

Control Objective 7: Environmental Safeguards:  Controls provide reasonable assurance that procedures exist to minimize the effect of a malfunction or physical disaster to the computer and data center facilities

Control Objective 8: Change Management:  Controls provide reasonable assurance that changes (including emergency / non-routine and configuration) to existing IT resources are logged, authorized, tested, approved and documented.

Control Objective 9: Data Integrity, Availability and Redundancy:  Controls provide reasonable assurance that data integrity is maintained through all phases including transmission, storage and processing and the Data Lifecycle is managed by customers

Control Objective 10: Incident Handling:  Controls provide reasonable assurance that system problems are properly recorded, analyzed, and resolved in a timely manner.

Many thanks to Carl from Amazon for his help with this information.

Update: Since this post was published Amazon updated their PCI DSS FAQ. You can find that here.

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9 thoughts on “Using Amazon EC2 for PCI DSS compliant applications

  1. Pingback: #25 – 2009

  2. Hi Cloudiquity

    I am looking at how to get a company PCI DSS compliant.

    This seems like a big headache for companies who want to offer card payment options to customers – I am a cloud advocate so I was wondering if there are any ‘all in one’ cloud services a company could subscribe to to manage card payments so that no cardholder data is required to be stored at the company and the cloud provider can meet the PCI CSS requirements?

    I envision embedding a card payment service in to whatever webapp triggers the need to collect some card holder data.

    Apologies if I am a little ignorant – I am new to the PCI DSS reqs and the technology to meet them

    thanks
    Demi

  3. One of the requirements to be PCI DSS compliant is

    Requirement 12.8.2 Maintain a written agreement that includes an acknowledgement that the service providers are responsible for the security of cardholder data the service providers possess.

    Testing Procedure12.8.2 Verify that the written agreement includes an acknowledgement by the service providers of their responsibility for securing cardholder data.

    Reference: https://www.pcisecuritystandards.org/security_standards/download.html?id=pci_dss_v1-2.pdf page 56

    A service provider is defined as
    “Service Provider Business entity that is not a payment brand, directly involved in the processing, storage, or transmission of cardholder data. This also includes companies that provide services that control or could impact the security of cardholder data. Examples include managed service providers that provide managed firewalls, IDS and other services as well as hosting providers and other entities. Entities such as telecommunications companies that only provide communication links without access to the application layer of the communication link are excluded.”

    Reference: https://www.pcisecuritystandards.org/pdfs/pci_dss_glossary.pdf page 12

    I am not a lawyer but Amazon does not provide any written guarantee to the above affect.

    See another blog discussion
    http://www.mckeay.net/2008/11/02/pci-compliance-in-the-cloud-get-it-in-writing/

    I don’t think any other general Cloud company provides the above guarantee. So the solution to look for SaaS PCC DSS client service rather than running your own service in the cloud infrastructure.

  4. You mentioned in the post that Amazon will be able to provide a SAS70 Type 2 Audit Statement in July. Do you know whether they’re still on track to achieve that?

  5. Thank you for the great post

    You inspired me to directly confront Amazon on where they stand with PCI compliance which led to Amazon confirming that you cannot in fact be PCI Level 1 compliant using AWS services:

    http://developer.amazonwebservices.com/connect/thread.jspa?threadID=34960

    Some highlights:

    “It is possible for you to build a PCI level 2 compliant app in our AWS cloud using EC2 and S3, but you cannot achieve level 1 compliance.”

    “we recommend that you do not store sensitive credit card payment information in our EC2/S3 system because it is not inherently PCI level 1 compliant”

    2nd response:

    “We do not and will not provide a written agreement attesting compliance and assuming responsibility for cardholder data.”

    “we recommend customers not to store sensitive credit card payment information on EC2/S3 systems as they are not inherently PCI level 1 compliant”

  6. Many AWS services (EC2, S3, EBS, & VPC) are now PCI Level 1 compliant.

    “Our PCI Service Provider status means that customers who use our services to store, process or transmit cardholder data can rely on our PCI compliance validation for the technology infrastructure as they manage their own compliance and certification, including PCI audits and responses to incidents. Our service provider compliance covers all requirements as defined by PCI DSS for physical infrastructure service providers. Moving the entire cardholder environment to AWS can simplify your own PCI compliance by relying on our validated service provider status.”

    Ref.: http://aws.amazon.com/security/pci-dss-level-1-compliance-faqs/

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