Compliance is necessary, but not always sufficient to prevent security breaches

Over the past five days we’ve seen news of a major breach at U.S.-based credit card processor Global Payments. While details are still emerging, reportedly up to 1.5 million cards may have been compromised. This story not only highlights the difference between security and compliance, but also reminds us of the fundamentals of dealing with administrative accounts.


VISA reportedly removed Global Payments from its list of approved third parties that process transactions between stores and banks. This implies that Global Payments was considered “PCI compliant” at the time of the breach. This demonstrates the difference between compliance and security. While complying with various requirements and regulations is necessary, it is not always sufficient. Security risks must be understood and addressed separately from compliance programs, as the consequences can be very real – a lesson Global Payments likely learned quickly as its stock dropped 9% before trading on its stock was halted, according to a Wall Street Journal article from March 30.


Gartner Analyst Avivah Litan reported that the hackers may have taken over an administrator account that was accessed by guessing the answers to the “knowledge-based authentication” questions. What stands out here is Global Payments’ apparent lack of understanding of basic Privileged Identity Management principles. Not only should administrative accounts be secured to a higher standard than normal user accounts, but they should be treated fundamentally differently than standard user accounts:



  • To ensure proper tracking, control and accountability, users should not be able to access these accounts directly, but only once authenticated and logged in to a “personal” identity.

  • Because privileged accounts are nearly always shared, having “knowledge-based questions” that enable access is a profoundly flawed practice.

In addition, even privileged accounts should follow the principle of “least privilege.” While Global Payments may never reveal this amount of detail, I wonder if the compromised accounts truly required the privileges to both access unencrypted credit card data and to export that data from the systems.


That Global Payments was found to be in compliance with PCI requirements by a certified assessor will hopefully spark discussions on whether PCI requirements require sufficient protections for privileged accounts. In addition, organizations should determine their security needs according to their tolerance for risk, rather than relying on requirements or standards to tell them what is necessary to protect their business.

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Russell Miller

Russell Miller has spent over five years in network security in various roles from ethical hacking to solutions marketing. He currently manages marketing activities for the CA ControlMinder products. Russell has a B.A. in Computer Science from Middlebury College and an M.B.A. from the MIT Sloan School of Management.

This article has 1 comment

  1. In the wake of Global Payments’ data breach, there has been a lot of advice on what people should do to protect themselves, but way too often we are asked to do more than what’s needed and that can needlessly lead to different issues. However, while the damage done by the hackers is real, they cannot harm us without first tricking us into revealing the information they don’t yet have (name, address, SSN). So as long as we are cautious and don’t give our personal information to strangers, we will do just fine.

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