Government & Public Sector

What Everyone Should Take Away from the Recent Retail Breaches

By: Gene Geiger, Partner of A-LIGN Recent Retail Breaches – What Should You Do When news of the Target breach was announced, in the middle of the holiday shopping season, it made headlines and re-kindled the debate on payment card data security and more specifically, the effectiveness of the PCI Data Security Standard (“PCI DSS”), which was established to protect payment card data. This debate has only intensified as news of breaches at other major retailers has surfaced. So what went wrong? How were millions of records exposed? You don’t have to go very far to find the finger pointing and criticism of everyone involved, including Target, the PCI Security Standards Council (“PCI SSC”) and the core infrastructure used in the payment card industry. These discussions will continue and additional guidance may be produced, but at the end of the day, the clients I speak with want to know one thing “What should we do?” Outlined below are some thoughts I would like to share on how to increase the security in your environment.

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Understanding FedRAMP: Cloud Service Provider’s Top 4 Questions Answered

By: Gene Geiger, Partner of A-LIGN Security and Compliance Services As an information security and audit firm focused on the compliance needs of service providers, A-LIGN’s accreditation as a FedRAMP third party assessment organization (“3PAO”) is a natural fit with our existing service offerings. Since becoming a FedRAMP 3PAO, we have noticed a trend in client calls stating their customers are inquiring about FedRAMP or that FedRAMP is being discussed during the sales cycle with prospective customers. With that being said, I thought it would be beneficial to outline the most common FedRAMP questions we have received with detailed responses.

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How Subservice Organizations Impact SSAE 16 Reports

By: Scott Price, Managing Partner of A-LIGN Determine whether your SSAE 16 Report is saving your client money or costing them! With year-end financial audits fast approaching, your clients will soon be requesting your SSAE 16 report. Why? This is because your SSAE 16 reports will allow your client’s financial auditors to determine if they need to perform additional testing or if they can utilize the report for their year-end financial audit. If the latter option happens to be this case, your SSAE 16 report will save your clients both time and money. Now, aren’t you efficient?

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PCI Data Security Standard Version 3.0 – Breakdown of Changes to Anticipate

By: Gene Geiger, Partner of A-LIGN Following the 36 month lifecycle the PCI Security Standards Council (“Council”) has established for the published standards, Version 3.0 of the PCI Data Security Standard is in the final stages before it will be released on November 7, 2013. Through several webinars and documents provided to stakeholders, the Council has provided information on the final draft in order to receive feedback at the 2013 Community that will be held in Las Vegas September 24 – 26. The core twelve requirements remain the same, but after a review of the changes and guidance provided by the Council, the change to Version 3.0 is more comprehensive than we experienced with previous version changes. However, due to the impact of these changes and the time it may take to fully comply with the requirements of Version 3.0, Version 2.0 may be used for assessment until December 31, 2014. Nonetheless, the Council encourages adoption of Version 3.0 as soon as practical.

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Ask A-LIGN: When receiving our first SSAE 16 audit, if the auditors find minor mistakes, will we have the opportunity to correct them?

By: Scott Price, Managing Partner of A-LIGN Answer: I hear this question often and, my answer is, “it depends.” I realize this is not the response most of you were hoping for, but I will elaborate. If your audit is a Type 1 SSAE 16, you can elect to have the review date of the report dated for when the service organization has remediated all deficiencies found in the controls. This is one of the main reasons why service organizations like to start with a Type 1 audit. However, in the same breath, the user community sees the limitations of a Type 1 since it only gives assurance at a specific point in time. It is a snapshot.

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New HIPAA Rules: Impact on Business Associates

As I read the “Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules under the Health Information Technology for Economic and Clinical Health Act and the Genetic Information Nondiscrimination Act; Other Modifications to the HIPAA Rules” recently released by the Department of Health and Human Services, I struggled to think how to summarize the 563 page PDF document into a meaningful summary for A-LIGN’s clients.  The title alone is a paragraph long.  A large part of the document is minutia that is not relevant for the everyday conversation on how to protect electronic protected health information (“ePHI”) but there are some key points and clarifications that are made which I believe should be understood by our clients.  As a provider of audit, compliance and security services primarily to companies defined as service organizations or service providers, I will focus on two key points that impact service organizations that handle ePHI, applicability and liability.

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PCI Security Standards Council Releases New Information Supplement on Cloud Computing

In February the PCI Security Standards Council (the “Council”) released a new information supplement related to the application of the Payment Card Industry Data Security Standards (“PCI DSS”) requirements in the Cloud. The goal of the information supplement is to assist Merchants and Cloud Service Providers (“CSP”) maintain PCI DSS compliant environments and also to guide the Qualified Security Assessors (“QSA”) that are tasked with performing the validation assessments.

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PCI Security Standards Council Releases New Information Supplement on Cloud Computing

  By: Gene Geiger, Partner of A-lign Security and Compliance Services In February the PCI Security Standards Council (the “Council”) released a new information supplement related to the application of the Payment Card Industry Data Security Standards (“PCI DSS”) requirements in the Cloud. The goal of the information supplement is to assist Merchants and Cloud Service Providers (“CSP”) maintain PCI DSS compliant environments and also to guide the Qualified Security Assessors (“QSA”) that are tasked with performing the validation assessments.

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Ask A-LIGN: What is the difference between a SOC logo and a SOC seal?

By: Scott Price, Managing Partner of A-LIGN  Answer: Misuse of Service Organization Control (SOC) terminology is a common mishap in the marketplace. When it comes to the use of the SOC logo or seal, many tend to assume the terms mean the same thing (six of one, half a dozen of the other), but in reality they are classified as entirely different entities. Let me explain…

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Ask A-LIGN: What is the difference between a Penetration Test and a Vulnerability Assessment?

A square is a rectangle but a rectangle is not a square. That saying always confused me in school and reminds me of the confusion in the market place between vulnerability assessments and penetration tests. A penetration test is a vulnerability assessment but a vulnerability assessment is not a penetration test. As I speak to organizations that want to test the security of their technology infrastructure I ask “Do you want a vulnerability assessment or a penetration test?” I receive responses ranging from “aren’t they the same” to “I don’t know you tell me”. There are key differences between the two depending upon the purpose of the project.  I would like to outline the purpose of the two projects and when you would select each.

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