Hi Danux,
IMHO, although the Log management server, does not store, process or
transmit credit card date, it is the system that monitors systems
carrying cardholder data. Therefore, not all but a few PCI
requirements would be applicable related to audit trails (req 10),
authentication (req 8), password storage (req 8), hardening (req 2)
and scanning (this is controversial).
However, using this system to put all other systems in the network in
scope would not be right (if I understand what you said correctly).

Hope this helps,
Rajat.

On Thu, Nov 12, 2009 at 5:18 PM, Danux <danuxx (at) gmail (dot) com [email concealed]> wrote:
> Thanks all for your feedback,
>
> I will clarify the most common questions you asked:
>
> a) The Log Management server is a receiver so it is not able to reach
> PCI Assets.
> b) The Log Management server does not store PII/CC data.
>
> It seems like 80% of the audience thinks that if I am not storing
> PII/CC data in the Log Server and not direct access (push) to PCI
> assets then it should be out of scope.
>
> I asked the PCI Auditor that in my  opinion the PCI goal was to
> protect CC data and since my Log Server is not able to reach PCI
> assets then it was out of scope.
> The PCI Auditor said exactly what David Glosser mentioned above, The
> goal in this point is to protect the Log Server from tampering.
>
> I totally disagree with that because I think PCI goal is to protect CC
> data and if no PII/CC is store in log server then it does not matter
> if someone is tampering it.
> Someone can tell me whether by getting usernames from log files you
> are gonna be able to bypass firewall to connect to PCI assets and or
> get passwords automatically and or steal/decrypt CC data? All this
> requires extra effort, usernames are not even considered PII since is
> something PUBLIC.
>
> Now, if the goal is to protect Log files then as i mentioned at the
> beginning of this conversation, all assets pushing info to Log server
> are in scope too!! because each one can reach it and therefore try to
> compromise it.
>
> CONCLUSION:
>
> Lets think as Auditors, if I want to convince PCI Auditor about
> putting my Log Server out of scope, I need trust resources. Do you
> have any documentation from trusted sources like NIST, Garner, so on
> where explains how to deal with this Scenario?
>
> Thanks all once again.
>
> I promise to let you all know the result of this point to know the
> real way in a PCI perspective to deal with.
>
> On Thu, Nov 12, 2009 at 3:34 PM, Eric Milam <emilam (at) coretechsg (dot) com [email concealed]> wrote:
>> Its not my decision, last I checked I don't think the PCI Council allowed it
>> as the only form of separation.
>>
>>
>>
>>
>> Tracy Reed wrote:
>>>
>>> On Thu, Nov 12, 2009 at 12:42:35PM -0800, Eric Milam spake thusly:
>>>
>>>>
>>>> Basically the fear are base camps from which to launch an attack.
>>>> As Erin stated below, if there are measures in place (not just
>>>> vlans) to prevent access from the log machine to the Card Holder
>>>> data environment then it may be that the device will be out of
>>>> scope.
>>>>
>>>
>>> Why not just VLANs? Do we not trust VLANs or are we worried about VLAN
>>> misconfiguration? Or switch compromise? Cisco commissioned a study by
>>> @Stake (IIRC) which made a pretty good case for VLAN security. Of
>>> course, that may just be Cisco getting the results it paid for. But it
>>> seemed reasonable to me.
>>>
>>>
>>
>>
>
>
>
> --
> Daniel Regalado aka Danux
> Hacker Wanna Be from Nezahualcoyotl
>
> www.macula-group.com
>
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--
Rajat Swarup

http://rajatswarup.blogspot.com/

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