Friday, January 5, 2018
"Encryption only protects data when it's implemented correctly," stated Marc Punzirudu, Director of Security Consulting Services at ControlScan Inc., a managed security and compliance solutions company. "While we don't know what caused the breach at this stage, Forever 21's public statement indicates that encryption was in place but not functioning in all cases, which tells me it wasn't properly and consistently implemented across the organization's chain of stores."
Invoking the security industry's mantra, "trust but verify," Punzirudu said testing is the best way to evaluate a security solution's effectiveness. "There are many products and methods used to protect cardholder data, and it is important that businesses are not lulled into a false sense of security when using any one of them," he said. "You will never know for sure until you test it in an operational setting."
On Jan. 2, 2018, the company shared highlights from the requisite investigation into the intrusion and confirmed encryption technology had not always been active in all devices. Investigators found signs of unauthorized network access and malware designed to search for payment card data on infected devices.
"The malware searched only for track data read from a payment card as it was being routed through the POS device," the company stated. "In most instances, the malware only found track data that did not have cardholder name – only card number, expiration date, and internal verification code – but occasionally the cardholder name was found."
Investigators traced malicious activities, of varying durations, that occurred between April 3, 2017 and Nov. 18, 2017. Criminals had mined data from infected devices for days, weeks and months, according to the statement. They may have also found payment card data stored in the clear on store logs, "so if encryption was off on a POS device prior to April 3, 2017, and that data was still present in the log file at one of these stores, the malware could have found that data," company representatives stated.
Forever 21 stated it is working with its payment processors, device manufacturers and third-party experts to ensure that encryption is fully implemented across the enterprise. "Forever 21 stores outside of the U.S. have different payment processing systems, and our investigation is ongoing to determine if any of these stores are involved," company representatives added.
Protecting cardholder data and protecting your business are two very different things, although they often overlap," Punzirudu noted. "Regardless, both are ongoing processes that involve non-stop diligence," he added. "Businesses must take security seriously all the time, because cybercriminals are operating 24/7/365."
It is critical to remain diligent in implementing security controls and to not be distracted by buzzwords such as "PCI DSS scope reduction," Punzirudu said. "Businesses must have a plan in place to internally audit controls that are used to protect cardholder data, as well as a method for regularly analyzing access to environments which may contain cardholder data."
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