Thursday, March 5, 2009

And so begins everyone's claim for Cloud Compliance

Today's blog entry at Mosso Blog

Cloud Sites, Mosso|The Rackspace Cloud’s Flagship offering, is officially the very first cloud hosting solution to enable an Internet merchant to pass PCI Compliance scans for both McAfee’s PCI scans and McAfee Secure Site scans.

While I am all about helping companies meet compliance with whatever technology they are trying to implement there are some facts that seem a little skewed here.

1) They only passed the ASV scan. A scan of the external facing ip addresses as required by requirement 11.2.b. This is great but it's not PCI DSS compliance - it is in fact only one very small piece.
11.2.b Verify that external scanning is occurring on a quarterly basis in accordance with the PCI Security Scanning Procedures, by inspecting output from the four most recent quarters of external vulnerability scans to verify that: Four quarterly scans occurred in the most recent 12-month period; and The results of each scan satisfy the PCI Security Scanning Procedures (for example, no urgent, critical, or high vulnerabilities); The scans were completed by an Approved Scanning Vendor (ASV) qualified by PCI SSC.
2) They aren't processing credit cards - they call an API (SSL wrapper and encryption) and let credit cards flow through to someone else's non-cloud network. Their marketing material shows the API. It sure is neat but again we are still only talking about a piece of the PCI DSS compliance. I am happy that you are not storing credit cards.

3) I don't believe they would be able to PASS an onsite assessment for a RoC but since it looks like they are only a L3 merchant - a SAQ is all they need to fill out.

So why don't I believe they could pass?

Until someone can present a clear picture of the demarc point between the application, virtualization and the physical layers and the controls offering protection between those layers; no QSA will be able to say they are compliant. I have discussions just about the idea of a demarc point between the Dom0/DomU. We haven't even begun to drill into the other layers.

So in this case the merchant's argument might be that they are using a shared hosting provider: (language borrowed from multiple posts in SPSP forum)

A shared hosting refers to a hosting service where many hosted servers reside in a date center connected to the Internet. In shared hosting, the provider is generally responsible for managing servers, installing server software, security updates, technical support, and other aspects of the service.

PCI compliance is the responsibility of the organization who owns the data. In a shared hosting environment where it is truly shared hosting and the client can upload whatever they want, then the client is responsible for ensuring they are using a hosting provider that meets their needs. Simply having merchants that house data in a hosting environment does not impose the requirements upon the hosting provider. There are two basic paths here. 1) the merchants need to ensure they are using a hosting provider that complies with the PCI DSS or 2) the merchants need to ensure they can manage their own systems in accordance with PCI DSS.

I haven't met a Shared Hosting provider yet who is willing to accept the liability of PCI DSS compliance in the cloud - this isn't to say that they aren't all working towards it. So this leaves the merchant responsible for managing their own system - and we fall back to my Dom0/DomU comment and the current problems with providing enough evidence of compliance.

Most QSA's are struggling with the idea of virtualization in general - they either get stuck on the 1 service per server or their view of virtualization is based on their use of VMware or Parallels. QSAs are going to have to either take deep dives into Architecture or they are going to fail companies all over the place.

Finally as I said at CloudCamp last weekend - want to be compliant in the cloud today, treat all information that is stored in the cloud with the highest level of encryption, then it only becomes random bits and it doesn't matter if you suffer a breach.

Friday, February 27, 2009

Me - diving into the deep end and drowning

So this post all got started because I had a hard time with comments someone made about the Kindle. As I type this I see where the term "fanboy" came from. I was reading a post by the Hoff about the Kindle and his Security Thoughts.
To some degree I agreed that the device was missing stuff. I then proceeded to read the comments that followed the post and I took offense. I still don't know why - if I figure it out I will share the news.
I took 4 pages to write this or as Hoff pointed out to me "Um, you know nobody will read that much...that's my point, I think you're going off the deep end... ;0"

So here's what follows...

After some debate with Hoff on twitter - I figured I should bring my comments here. I was moaning about FUD (Fear Uncertainty & Doubt) with regards to the comments made about the Kindle.

I feel like his comments are FUD because with a little research he could very easily have discovered that the holes he decided were there had mitigations or were misguided because they needed some research to see how things really worked.

Both Hoff and Roland support the idea that “security versus convenience trade-offs are getting more slippery these days.” This is a valid argument for dozens of consumer devices – iPhone, iTouch, U3 USB Keys all come to mind immediately.

I feel that Hoff highlights security flaws that are inherent to the device’s individual operational specs. The device doesn’t lock, you can’t control content, etc. Roland chooses to argue that the device is insecure because of the device’s operation on the network. In Roland’s case I had some trouble swallowing them:

1. Amazon now have a copy of any document you convert. Who knows who can see it, if it's been stored somewhere it can be accessed, etc.?

Amazon only has a copy of your documents if you opt to go with the method of sending them docs via email. It costs money. Amazon as well as multiple articles all within a google search show how easy it is to use mobi pocket creator to convert word, and pdf files over – and then with a easy drag and drop right into the kindle. BTW most pdfs just don’t look that goood – it’s a problem with the standard that Amazon chose.

Your response might be that’s too hard, who is going to do the research – if you are actively using the Kindle as a doc repository for docs that shouldn’t be out of your sight then you deserve what you get.

2. Everything on the Kindle apparently runs as root; the device itself is accssible via USB/serial console during boot, and the filesystems are mountable via plugging the device into a computer via USB. Very easy to trojan (or even bot!) someone's Kindle.

I can’t really argue this. I don’t understand it. I don’t know why they did it that way. Seems foolish for multiple reasons.

Now I will debate the statement Easy to Trojan (or even bot!) – hmm well I would not say easy – the preferred vector here would actually be to send you a doc through kindle email and attack that way. But then you need to know my kindle email for that - again with research I am sure you would have me. So now we are relying on Amazon to protect me – well since they have to open the doc/pdf to convert it – you are more likely to compromise them – doubtful first.

3. If you use the Whispernet MVNO service carried across Sprint's EVDO network, note that when you browse the Internet using the Kindle browser, all of your traffic is apparently proxied via Amazon proxy servers (which is totally unnecessary, as EVDO uses routable IP addresses, unlike GSM 3G networks). So, Amazon are MITMing you

Hmm Amazon MITMing me – I like that. Oh wait I am buying their product on their network and reading it on their device (I own it yes but the device is only for Amazon content – much to my dismay). Were I to hazard a guess the only time I ever leave the Amazon network is when I launch the web browser. So yes they are proxying my traffic – they are seeing all my google reader traffic.

4. People can see what you're reading, or planning on reading. People can plant potentially damaging documents/images/audio on the device in order to frame you, given that there's no security when the device is mounted via USB

Hunh, I don’t really understand this. Look at my desk, you can see what I am reading – although you won’t find that I have a small place in my heart for teenage sci-fi fantasy novels – I didn’t get enough as a teen so I still read them now.

5. You've no idea if the Kindle 'phones home' via EVDO if you're reading with the EVDO enabled, or stores up behavioral information and then sends it home when you turn on EVDO or enter an EVDO service area. It's hard to investigate this without specialized equipment or investing the time to root the Kindle, since it uses EVDO exclusively, no WiFi capability.

Of course it phones home – Amazon wants your marketing information just like everybody else. I actually don’t know this to be fact. I would worry more about the fact that the Kindle has GPS (not really but sorta GPS) where oh where has my poor cheating SO gone with her Kindle so I can come and keel her secret lover….
As noted by Amazon:
“The Device Software will provide Amazon with data about your Device and its interaction with the Service (such as available memory, up-time, log files and signal strength) and information related to the content on your Device and your use of it (such as automatic bookmarking of the last page read and content deletions from the Device). Annotations, bookmarks, notes, highlights, or similar markings you make in your Device are backed up through the Service. Information we receive is subject to the Privacy Notice.”

6. The Kindle obvious has the ability to store and trasmit such behavioral information, given that now multiple Kindles on the same account can keep in sync with one another in terms of content on your Kindle, your current location inside a given book, etc. Amazon plan to extend this capability, along with the base ereader functionality, to other types of devices, over time.

Is this information encrypted in any way? If so, is it real encryption, or is it ROT13? Is it encypted only in flight, but at rest, as well?
See my answer to question 5. The real value here is what are your preferences so that they can sell more stuff to you. Why should it be encrypted – it’s a series of numbers identifying your kindle & your accounts token – nothing of value here – well other than the fact that I just ordered a subscription to the Atlantic and the New York Times and I need my Kindle updated.

7. If the Kindle is phoning home, are Amazon selling your behavioral data to advertisers? Even if they're not, are they mining it (in addition to the data you already consciously and voluntarily give them), and is it stored securely (for some value of 'secure')?

I am going to defer to Amazon on this one:
“Information about our customers is an important part of our business, and we are not in the business of selling it to others….Protection of and Others: We release account and other personal information when we believe release is appropriate to comply with the law; enforce or apply our Conditions of Use and other agreements; or protect the rights, property, or safety of, our users, or others….With Your Consent: Other than as set out above, you will receive notice when information about you might go to third parties, and you will have an opportunity to choose not to share the information.”

And finally
“How Secure Is Information About Me?
We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input.
We reveal only the last five digits of your credit card numbers when confirming an order. Of course, we transmit the entire credit card number to the appropriate credit card company during order processing.”

8. The Kindle allows you to highlight chunks of books/documents, annotate them with notes, and store them on the device. Are they DRMmed to your particular device, or are they just unencrypted text files, which can be accessed and downloaded via the USB mounting facility (I know which way I'd bet, heh).

Your clippings are .txt files that you can pull right off the Kindle when in USB mode. Why would you DRM to a particular Kindle?

9. I've never used the Kindle Web browser; does it let you store usernames/passwords/cookies for Web sites you access? If so, then they're sitting there on the flash, waiting to be downloaded via USB by anyone who can get hold of the device

The Kindle browser blows. There is no way to say anything good about it. The little configuration it does allow is choosing basic versus advanced mode.
• Set Default View Mode - lets you choose between Advanced and Basic View Modes.
• Clear Cache: Delete temporary Internet files from Kindle browser's cache.
• Clear History: Delete Internet address entries from Kindle browser.
• Clear Cookies: Delete cookies from the Kindle's browser.
• Enable Javascript: In Advanced Mode you can enable execution of Javascript on the pages you visit. Choosing to enable Javascript will probably slow down your browsing speed.
• Show Images: Lets images on pages appear - again, slows down browsing.
In all fairness to Amazon – to get to the browser you have to choose Experimental. I am not sure how security works for everyone but common sense 2.0 tells me that when I find stuff under experimental I shouldn’t trust it with my super secret stuff.
As a side I can’t find password on mine – maybe I will do a deeper dive with some other tools.