We have covered this before, but every now and again I run into a new slant on who bears responsibility for online transaction safety. Bank? Individual? If both, where do the responsibilities begin and end?

Over the last year a few friends, ejected from longtime professions due to the current economic depression, have started online businesses. A couple of these individuals did not even know what HTML was last year – but now they are building web sites, starting blogs and … taking credit cards online. It came as a surprise to several of these folks when their payment processors fined them, or disrupted service entirely because they had failed a remote security audit.

It seems that the web site itself passed its audit with a handful of cautionary notices that the auditor recommended they address. What failed was the management terminal – their home computer, used to dial into the account, had several severe issues. What made my friend aware that there was a problem at all was extra charges on his bill for, in essence, having crappy security. What a novel idea to raise awareness and motivate merchants! I applaud providing the resources to the merchants to help secure their environments. I also worry that this is a method for payment processors to “pass the buck” and lower their own security obligations. That’s probably because I am a cynic by nature, which is why I ended up in security, but that’s a different story.

Not having started a small business that takes credit cards online, I was ignorant of many measures payment processors are taking to raise the bar for security on end-user systems. They are sending out guidance on the basic security measures, conducting assessments, providing results, and suggesting additional security measures. In fact, the list of suggested security improvements that the processor – or processor’s service provider – suggested looks a lot like what is covered in a PCI self assessment questionnaire. Firewall rules, use of admin accounts, egress filtering, and so on. I thought this was pretty cool! But on the other side of the equation, all the credit card billing is happening on the web site, without them ever collecting credit card numbers. Good idea? Overkill?

These precautions are absolutely overwhelming for most people. Especially like one-person shops like my friends operate. They have absolutely no idea what a TCP reset is, or why they failed the test for it. They have never heard of egress filtering. But they are looking into home office security measures just like large retail merchants. Part of me thinks they need to have this basic understanding if they are going to conduct commerce online. Another part of me thinks they are being set up for failure.

I spent about 40 minutes on the phone today, giving one friend some guidance. My first piece of advice was to get a virtual environment set up and make sure he used it for banking and banking only. Then I focused on how to pass the audit. My goal was in this conversation was:

  1. Not overwhelm him with technical jargon and concepts that he simply did not, and would not, understand.
  2. Get him to pass the next audit with minimum effort on his part, and without having to buy any new hardware or software.
  3. Call his ISP, bank, and payment processor and wring out of them any tools and assistance they could provide.
  4. Turn on the basic Windows firewall and basic router security.

Honestly, the second item was the most important. Despite this person being really smart, I did not have any faith that he could set things up correctly – certainly not the first time, and perhaps not ever. So I, like many, just got him to where he could “check the box”. I just advised someone to do the minimum to pass a pseudo-PCI audit. sigh I’ll be performing penance for the rest of the week.