This is the 12th 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 pieces might seem out of context without reading earlier parts):
Let’s determine what documentation should be produced as proof of log review.
First, the common misconception is that having the actual logs provides that. That is not really true: ”having logs” and “having logs reviewed” are completely different and sometime years of maturing the security and compliance program separates one and the other. Please make sure that your team members keep that in mind.
Just as a reminder, we have several major pieces that we need to prove for PCI DSS compliance validation. Here is the master-list of all compliance proof we will assemble. Unlike other sections, here we will cover proof of logging and not just proof of log review since the latter is so dependent on the former:
· Presence and adequacy of logging
· Presence of log review processes and its implementation
· Exception handling process and its implementation.
Now we can organize the proof around those areas and then build processes to collect such proof.
The following items serve as proof of logging:
1. Documented logging policy, covering both logged events and details logged for each event
2. System / application configuration files implementing the above policy
3. Logs produced by the above applications while following the policy.
As stated previously, your QSA is the ultimate judge of what proof of compliance will be adequate for your organization. These tips has been known to be found adequate, but see disclaimers in earlier parts for details.
The following items serve as proof of log review:
1. Documented logging policy, covering log review
2. Documented operational procedures, detailing the exact steps taken to review the logs
3. Records of log review tasks being executed by the appropriate personnel (some log management products create an audit log of reviewed reports and events; such audit trail should cover it – the case of manual review is covered below) – think about this item as “log review log”
4. Also, records of exceptions being investigated (next section) indirectly proves that log review is taken place as well.
The following items serve as proof of log exception process:
1. Documented logging policy, covering exceptions and their handling
2. Documented operational procedures, detailing the exact steps taken to investigate exceptions found during log review (this document)
3. A log of all exceptions investigated with actions taken (“logbook”)
The above evidence should provide ample proof that the organization follows PCI DSS guidance with diligence. Let’s focus on producing this proof – the table has the details.
|PCI Compliance Logging Sub-Domain||Proof of Compliance||How to Obtain Proof?|
|Proof of presence and adequacy of logging||Documented logging policy||Create policy, if not present|
|Proof of presence and adequacy of logging||System / application configuration files||After deployment, preserve the configuration files as a master copy|
|Proof of presence and adequacy of logging||Logs produced by the above applications||Collect sample logs and save as proof of compliance|
|Proof of log review||Documented logging policy||Create policy, if not present|
|Proof of log review||Documented operational procedures||<this document!>|
|Proof of log review||Records of log review tasks being executed||Either use the tool or create a “logbook” (format below)|
|Proof of log review||Records of exceptions being investigated||Create a “logbook” of investigations|
|Proof of exception handling||Documented logging policy||Create policy, if not present|
|Proof of exception handling||Documented operational procedures||<this document!>|
|Proof of exception handling||A log of all exceptions investigated||Create a “logbook” of investigations or “knowledge base”|
The critical item from the above list is “a logbook” that is used to record exception follow-up and investigation, thus creating powerful evidence of compliance with PCI DSS requirements. In a more advanced form, the logbook can even grow into an investigative “knowledge base” that contains all past exception analysis cases.
To be continued.
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