In a recent post on his blog, Denver Prophit made some insinuations that I felt needed addressed. As many of those who are, or have been associated with CRE Loaded, Denver feels the lack of truth is the best way to profit off those who are Internet Illiterate.
Denver Prophit said; “If you request identity information such as billing address, name and telephone number, you need a secure encrypted channel to send it. You also need good P3P in place.”
Fact is, CRE Loaded, osCommerce and 99% of all open source eCommerce applications never considered SSL important, that is until a couple years ago. Furthermore, an article on the InformationWeek website, ["Black Hat: Security Pro Shows How To Bypass SSL,"] suggests that MITM attacks are not impossible:
“…Marlinspike explained that he obtained such data by placing proxy software he’d written, called ‘sslstrip,’ on a node of a Tor network, to conduct what’s known as a man-in-the-middle attack. The proxy software intercepts HTTPS traffic, generates and signs security certificates, and mediates data passing between the client and server, capturing everything in the process.”
Martinspike captured 16 credit card numbers, seven PayPal logins, and 300 other miscellaneous secure login sessions in only 24 hours.
Marlinspike went on to say that:
“Lots of times the security of HTTPS comes down to the security of HTTP, and HTTP is not secure…”
Denver Prophit said; “The PCI standard requires Internet retailers to complete a 12-step security audit that must be certified annually and checked every three months.”
That may be true IF you accept credit cards on your website. However, if you use a payment processor, such as Authorize.net, Google Checkout or PayPal for example, PCI compliance is not your responsibility.
I emailed PCI Security Standards and received this reply:
“As described in PCI Data Security Standard Requirements and Security Assessment Procedures (available at https://www.pcisecuritystandards.org) the PCI Data Security Standard is intended to protect cardholder data and sensitive authentication data. As described on page 4 of that document cardholder data includes the primary account number, cardholder name, service code and expiration date, while sensitive authentication data includes full magnetic stripe data, CAV2/CVC2/CVV2/CID, and the PIN/PIN Block.”
You’ll notice that although cardholder name is mentioned, billing address and telephone number are not mentioned. Why? That is Not the information they [the card issuer] wants to protect. So, why would a small business owner need a “secure encrypted channel” if they are not accepting credit cards on their website?
Denver Prophit mentioned RSA in his post; “The point I stress, here, is * Encrypting transmission of cardholder data and sensitive information across public networks. your admin pages HAVE to be encrypted because it stores sensitive information and is required by federal law. See RSA.com 2005 A Corporate Minefield: FTC Demands “Reasonable & Appropriate” Measures to Protect Digital Assets (August 04) http://www.rsa.com/press_release.aspx?id=5991 (accessed January 14, 2009)”
I am glad you mentioned RSA. Taking the time to read that press release, one would find that Art Coviello, president and CEO at RSA Security Inc. stated; “The question that many organizations are now asking is ‘what constitutes reasonable and appropriate action?’ In an increasingly complex regulatory environment, finding a comprehensive answer to that question can be a laborious task.”
Who deceides what is “reasonable & appropriate?” One definition of reasonable is “Not excessive or extreme; fair.” The legal definition of reasonable is “Suitable; just; proper; ordinary; fair; usual. The term reasonable is a generic and relative one and applies to that which is appropriate for a particular situation.” (West’s Encyclopedia of American Law, edition 2. Copyright 2008 The Gale Group, Inc. All rights reserved.)
Based on Denver’s analysis, a small business owner, which would account for 90% of EOS Online Merchant’s user base, would be unable to do business on the Internet, if all that Denver claims is absolute. And, its is not.