Many Retailers Taking Big Chances with Test Data

02/10/2007 by gerry.

Some retailers have tried to mitigate the damage by using older customer data, on the belief that such data would have outdated information that might be less valuable if intercepted. But Mark Rasch, the former head of the U.S. Justice Department’s high-tech crimes unit and currently a security consultant in Washington, questions that premise.
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“The fallacy is that there is something called ‘old data,’” Rasch said, adding that most credit card information—including name, address and often the credit card number itself—does not change with any frequency. “What’s personal about me tends to remain personal even with the passage of time,” he said.

The credit card’s expiration date will periodically change, but Rasch said there’s such a small number of possible month/year combinations in the typical 2-year period that a thief could simply try them all until the right combination was discovered.

Rasch also has concerns about whether the use of such information for network testing violated “the implicit agreement between the merchant and the customer” that “you get my data for certain purposes, primarily to sell me the product and to validate payment.”

As for why test data hasn’t been created to safely test systems, Rasch said it’s a matter of money. To make it work, the test data would have to have a lot of numbers, with segments created to replicate various banks and other processors. It would do a retailer little good, for example, to test a Visa connection using a MasterCard number or even a card number from one major bank when testing a different bank’s card. “The question really is, ‘Who’s going to pay for it?’,” Rasch said.

Money is also behind the lack of security on the networks transmitting the test data, said the PCI Security Vendor Alliance’s Taylor. “These people are operating on a limited budget. What you secure first is the production environment and anything that is outwardly facing,” he said.

As for protecting the data itself, that’s a combination of laziness coupled with cheapness, Taylor said. There is a way to properly sanitize test data, he said, but it’s a lot of work.

He cited one insurance company that was testing with non-sanitized test data. “They didn’t have any way of generating test data on an enterprise basis. No tools, no procedures, not even a policy. They had no system-level prevention at all,” Taylor said. “They were using production data without masking, without encryption, without scrambling.”

Why? “Hey, it’s hard. Unless someone makes them do it, they’re not going to do it,” Taylor said. “You need policies. It’s so much easier to just copy production records.”

Is there a way out? Taylor said such numbers could be created by a group of card issuers coordinated by some overarching entity, such as Visa or some other industry group. Why has it not yet happened? Said Taylor: “I just assume it’s not their priority.”

Gerry adds: This is a great reason to have a look at tools like Data Masker. Making the process easy and repeatable as data is refreshed is what it’s all about!

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