Once upon a time, I was retained to create a comprehensive PCI DSS-focused log review policies, procedures and practices for a large company. They are focused on PCI DSS compliance, but based on generally useful log review practices that can be utilized by everybody and with any regulation or without any compliance flavor at all. The practices can be implemented with commercial log management or SIEM tools, open source log analysis tools or manually. As you undoubtfully know, tools alone don’t make anybody compliant!
This is the 15th post in the long, long series (part 1, part 2, part 3 – all parts). A few tips on how you can use it in your organization can be found in Part 1. You can also retain me to customize or adapt it to your needs.
And so we continue with our Complete PCI DSS Log Review Procedures (please consider reading from Part 1 – at this stage we are deep in the details and these sections might seem out of context without reading earlier parts):
Finally, it is useful to create a “PCI Compliance Evidence Package” based on the established and implemented procedures to show it to the QSA. It will help establish your compliance with three key of PCI DSS logging requirements:
· Presence and adequacy of logging
· Log review
· Exception handling
While it is possible to prepare the evidence package before the assessment, it is much easier to maintain it on the ongoing basis. For example, keep printed or electronic copies of the following:
1. Logging policy that covers all of the PCI DSS in-scope systems
2. Logging and log review procedures (this document)
3. List of log sources – all systems and their components (applications) from the in-scope environment
4. Sampling of configuration files that indicate that logging is configured according to the policy (e.g. /etc/syslog.conf for Unix, screenshots of audit policy for Windows, etc)
5. Sampling of logs from in-scope systems that indicate that logs are being generated according to the policy and satisfy PCI DSS logging requirements
6. Exported or printed report from a log management tools that shows that log reviews are taking place
7. Up-to-date logbook defined above
This will allow always establishing compliant status and proving ongoing compliance.
To be continued.
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