Dear Verizon Business: I Have Some Questions About Your PCI-Compliant Cloud…
You’ll forgive my impertinence, but the last time I saw a similar claim of a PCI compliant Cloud offering, it turned out rather anti-climatically for RackSpace/Mosso, so I just want to make sure I understand what is really being said. I may be mixing things up in asking my questions, so hopefully someone can shed some light.
This press release announces that:
“…Verizon’s On-Demand Cloud Computing Solution First to Achieve PCI Compliance” and the company’s cloud computing solution called Computing as a Service (CaaS) which is “…delivered from Verizon cloud centers in the U.S. and Europe, is the first cloud-based solution to successfully complete the Payment Card Industry Data Security Standard (PCI DSS) audit for storing, processing and transmitting credit card information.”
It’s unclear to me (at least) what’s considered in scope and what level/type of PCI certification we’re talking about here since it doesn’t appear that the underlying offering itself is merchant or transactional in nature, but rather Verizon is operating as a service provider that stores, processes, and transmits cardholder data on behalf of another entity.
Here’s what the article says about what Verizon undertook for DSS validation:
To become PCI DSS-validated, Verizon CaaS underwent a comprehensive third-party examination of its policies, procedures and technical systems, as well as an on-site assessment and systemwide vulnerability scan.
I’m interested in the underlying mechanicals of the CaaS offering. Specifically, it would appear that the platform – compute, network, and storage — are virtualized. What is unclear is if the [physical] resources allocated to a customer are dedicated or shared (multi-tenant,) regardless of virtualization.
According to this article in The Register (dated 2009,) the infrastructure is composed like this:
The CaaS offering from Verizon takes x64 server from Hewlett-Packard and slaps VMware’s ESX Server hypervisor and Red Hat Enterprise Linux instances atop it, allowing customers to set up and manage virtualized RHEL partitions and their applications. Based on the customer portal screen shots, the CaaS service also supports Microsoft’s Windows Server 2003 operating system.
Some details emerge from the Verizon website that describes the environment more:
Every virtual farm comes securely bundled with a virtual load balancer, a virtual firewall, and defined network space. Once the farm is designed, built, and named – all in a matter of minutes through the CaaS Customer Management Portal – you can then choose whether you want to manage the servers in-house or have us manage them for you.
If the customer chooses to manage the “servers…in-house (sic)” is the customer’s network, staff and practices now in-scope as part of Verizon’s CaaS validation? Where does the line start/stop?
I’m very interested in the virtual load balancer (Zeus ZXTM perhaps?) and the virtual firewall (vShield? Altor? Reflex? VMsafe-API enabled Virtual Appliance?) What about other controls (preventitive or detective such as IDS, IPS, AV, etc.)
The reason for my interest is how, if these resources are indeed shared, they are partitioned/configured and kept isolated especially in light of the fact that:
Customers have the flexibility to connect to their CaaS environment through our global IP backbone or by leveraging the Verizon Private IP network (our Layer 3 MPLS VPN) for secure communication with mission critical and back office systems.
It’s clear that Verizon has no dominion over what’s contained in the VM’s atop the hypervisor, but what about the network to which these virtualized compute resources are connected?
So for me, all this all comes down to scope. I’m trying to figure out what is actually included in this certification, what components in the stack were audited and how. It’s not clear I’m going to get answers, but I thought I’d ask any way.
Oh, by the way, transparency and auditability would be swell for an environment such as this. How about CloudAudit? We even have a PCI DSS CompliancePack 😉
Question for my QSA peeps: Are service providers required to also adhere to sections like 6.6 (WAF/Binary analysis) of their offerings even if they are not acting as a merchant?
/Hoff
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- PCI DSS Compliance and IT Security: Harmony or Discord? (prweb.com)
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- Revisions to Credit Card Security Standard on the Way (pcworld.com)
- Data Encryption for PCI 101: Introduction (securosis.com)
- Why your QSA should not be your Security Partner (brandenwilliams.com)
- Ask HN: Are you PCI DSS compliant? (pcisecuritystandards.org)
- Can You Have a PCI Compliant Virtualized Web Site? (securecloudreview.com)
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