The PCI DSS Wireless Guidance document is filling out a very important need. As I said in Part I, Part II, and Part III. Today I will continue analyzing this Wireless Guidance document. I will number them and ask that you refer to that number in your comments on my suggestions. Remember – the goal is to help improve the document.
How to Improve on the PCI DSS Wireless Guidelines Document – Part IV
Continuing in the review of the "Complying with PCI DSS" flow chart, I found some other areas I would change.
(14) I remove the arrow form "Change defaults" and draw one instead from "Generate audit report" – to "Enable 802.11i". This may seem as a small fix, but in fact it means "Enable 802.11i AFTER you generate an audit report". I also (15) would consider changing the verbiage of "Generate audit report"…. How can you generate an audit report to prove that the defaults have been changed? Do you simply compare it to an earlier report that said that those were the vulnerabilities? Do you just submit it as "this weakness not found" type report? Either way, lets change the way it is phrased.
Similarly to (14) above, I would recommend item (16) to route the arrow from "Enable 802.11" to "Physically Secure" to originate at "Generate a wireless audit". The difference being that taking the steps of "A centralized management system" and "Generate a wireless Audit report that proves…" are very important to enablement of Audit. The way the chart is drawn now, these can be seen as optional processes, and should not.
Finally here (17) I would like to note that in some situations it is not feasible, while certainly being desirable, to physically secure wireless devices. They can be our of reach (as in on a very high ceiling) or maintained by a third-party organization. I would suggest that the term be defined so an organization would not fail on their audit just for that reason alone.
More to come next Monday…
Tomorrow we will have Chris’ final article in the "How to talk to Senior Management about Security". On Friday, as I promised, a discussion of Confidentiality, Integrity and Availability, and the next article in the PCI DSS Wireless series will be Monday.