Products

Solutions

Resources

Partners

Community

Blog

About

QA

Ideas Test

New Community Website

Ordinarily, you'd be at the right spot, but we've recently launched a brand new community website... For the community, by the community.

Yay... Take Me to the Community!

Welcome to the DNN Community Forums, your preferred source of online community support for all things related to DNN.
In order to participate you must be a registered DNNizen

HomeHomeOur CommunityOur CommunityGeneral Discuss...General Discuss...PABP-support in DNNPABP-support in DNN
Previous
 
Next
New Post
6/2/2009 10:52 AM
 

At the risk of taking this thread a little bit off topic (forgive me!), here is a link to the congressional testimony I reference above:

http://www.homeland.house.gov/hearings/index.asp?ID=185

Brandon


Brandon Haynes
BrandonHaynes.org
 
New Post
6/2/2009 4:47 PM
 

Brandon, interesting posts, not accurate, but interesting.

We are not "struggling" with anything.

ML is PABP/PA-DSS grandfathered certified.

ML/DNN is not. The DNN platform is not.

To certify our ML/DNN verison, we need participation from DotNetNuke.

Kind of end of issue/discussion, as we've indicated to the DotNetNuke core team for 1.5 years now.

Thanks!

 
New Post
6/2/2009 8:02 PM
 

I suspect that ASPDNSF's equivocation about DotNetNuke PA-DSS is a red herring to distract from its own internal validation; here the VAST majority of compliance issues will relate to its own software, and very little will apply directly to DotNetNuke.

Your suspicions here are unfounded honestly, and statements misleading.  Your tone indicates that AspDotNetStorefront inherently has numerous compliance issues on its own, which is 100% inaccurate.  AspDotNetStorefront ML (on which the ML/DNN platform is largely based) has zero compliance issues as evidenced by our status as a PABP-certified payment application (short history lesson - PABP was replaced by PA-DSS when Visa transferred the project to the PCI security standards council - we are currently grandfathered into PA-DSS due to our certification against PABP v1.4).  We as a company (and I personally as the compliance officer on two certifications now) are fully aware of the requirements to achieve certification, and factually, the majority of compliance issues will actually be found within the DNN framework. 

The DNN framework functionality requires as much scrutiny as the ecommerce components, and perhaps more due to the fact that DNN handles many of the security, logging, error handling, form handling, data access, and administrative functions on the site. The areas where AspDotNetStorefront would be required to make changes corresponds nearly 100% with areas where our application relies on DotNetNuke to perform protected functions.

It is also important to note that PA-DSS compliance is NOT a list of checkboxes and a security scan.  There are a great number of processes and procedures that are required to achieve full compliance, including following a strict SDLC, security breach research and response procedures, code review policies for developers, secure hiring practices, documentation requirements, and other quality system components that must be in place within DNN Corp before there is ANY chance of PA-DSS certification.  This also calls into question any community-developed code that makes its way into the core platform.  It is a complete company-wide commitment to secure application development practices, and requires regular evidence of following those practices to maintain your certification status.  These are all things that AspDotNetStorefront has already undergone, and we are fully and 100% compliant with PA-DSS standards within both the AspDotNetStorefront ML and ML/DNN platforms based on the results of our last external audit as both products follow the same (compliant) SDLC.

The few details about the specific PA-DSS issues with which ASPDNSF is struggling serves to increase this suspicion.

We are aware of MANY of the areas in DotNetNuke that would require changes to meet PABP requirements.  We aren't "struggling" with anything except getting DNN to cooperate.  Without a commitment from the DNN team to address the issues it is a pointless waste of time.  We have asked for that commitment for ~two years now (or somewhere thereabouts) and haven't received it.  For example, doing a quick check of my currently active email folder, I found this, to Joe B, Shaun W, and Nik K. dated February 19th of 2008 (yes, that is over a year ago already).

Subject:     please advise on PABP plans for DotNetNuke + ASPDNSF

[omitted]...cost to do cert is about $X and must be done jointly with DNN due to DNN owning many customer password and security mgmt areas.

That same check revealed that we received zero responses to that inquiry, just as we received zero responses (or at least nothing encouraging) to the half a dozen or more other emails and calls regarding the matter.

If it really wanted to, ASPDNSF could likely avoid DotNetNuke dependencies for PA-DSS-specific tasks.

This is actually 100% accurate.  That specific (PABP Certified) product is already for sale on our website.  It is called AspDotNetStorefront ML.  Buy it, load it within an iFrame in your DNN site, and you are good to go.  One of the biggest draws to the DNN platform however is the single sign-on capability and centralized administration.  Guess what...  both of those are going to fall under PA-DSS jurisdiction and both are handled by the DotNetNuke platform.  If you did away with those, what you basically have is two separate websites.

Indeed, there exist (by my count) only THREE PA-DSS-compliant shopping cart applications on the PCI list (although, granted, such listing is sufficient but not necessary for PA-DSS compliance -- you do not have to be listed to be compliant).

This comment is also a bit misleading without a full explanation of the differences between PCI-DSS compliance and PA-DSS compliance.  Though I won’t go into the intricacies, PCI-DSS compliance is primarily concerned with the implementation of the payment environment.  Yes, this does include using secure applications, but also deals in great detail with things like network security, encryption, labeling, and handling of backup data, access control to servers/data centers, storage of paper records, logging of activities on servers that host payment applications, deployment of anti-virus and IPS/IDS systems, and so on.  These are fully outside of the scope (and control) of the AspDotNetStorefront application (and DotNetNuke for that matter).  In other words, PCI compliance is largely the responsibility of the merchant and hosting provider, not the application developer.

PA-DSS (again, formerly PABP) is primarily concerned with the application itself.  For example, it requires coding practices that securely overwrite sensitive data, logs administrative actions within the software, handles invalid logins properly, handles errors without disclosing sensitive data, properly encrypts sensitive data when appropriate, and provides for overall secure development and release practices (as I mentioned briefly above). 

The number of PA-DSS compliant applications on the PCI-DSS list is completely irrelevant as an indicator of application security.  By nature, any commercial payment application in which the merchant has ANY control over the security environment is not going to be out-of-the-box PCI-DSS compliant because said merchant has requirements as well (for example, following best practices for password security).  Any application that claims otherwise most likely has (or should have) some very fine print attached to that claim.

 
New Post
6/3/2009 11:39 AM
 

I wanted to add-on a bit here that DNN and PA-DSS certification is a bit of a sore spot due to the fact that we have brought this very subject up to the core DNN team many many times in the past.  Our feathers get a bit ruffled when, after pouring significant time and expense into compliance, we are accused of buck-passing, when in fact we have made many efforts to get DNN to undergo certification with us.  If DNN wants to be a viable commercial commerce platform, there is simply no way around it.  Not including development time to fix compliance issues, the audit process itself runs somewhere between $15,000 and $30,000.  With labor factored in, it is going to be $50,000+ (obviously depending on how compliant your application is out of the box, and how many required procedures you already have in place), and re-validation (or at least an attestation of no-change status via the auditor) is required whenever new major versions are released, etc.  We planned on working with DNN through the process and sharing the cost since A) it benefits our application, B) it benefits the DNN platform as a whole, and C) we have been through the process before, putting us in a position to offer insight on overcoming challenges.  That being said, we are not going to absorb the entire cost (on top of the heavily front-loaded R&D costs associated with the ML/DNN platform) to allow Catalook to advertise themselves as PA-DSS compliant next month at our expense.

At this point the question regarding DNN and PA-DSS does tend to invoke a canned response, as we have been answering the same question for two years, so I guess I can understand why Mr. Haynes' suspicions were aroused.  I'm glad it was brought up however, because it was and is a serious consideration for us, and the community as a whole now knows exactly what our stance is on certification.  If Joe or Shaun (or one of the new C-levels) wants to give me a ring and discuss undergoing PA-DSS compliance, I'd be happy to take their call.

I'd also like to add (albeit as a loosely-related side note) that the rampant over-usage of similar acronyms by the PCI SSC (Payment Card Industry Security Standards Council) and overlapping scopes of the PA-DSS (Payment Application Data Security Standard) and PCI-DSS (Payment Card Industry Data Security Standard) don't tend to make anything overly clear to the casual observer, thus leading to a lot of misinformation and confusion regarding compliance requirements and statuses.  Adding to the confusion are applications and services advertising themselves as "PCI Compliant", giving the false impression that all you have to do is install their application or sign up for their service and you are instantly compliant.  For instance, RackSpace Mosso has a PCI Compliance Guide posted prominently on their home page.  When you read it, the guide simply tells you to use "boomerang" gateway (where the customer is taken completely off of your website to the payment gateway's site to process payment).  By doing so, you aren't really achieving PCI compliance, but simply circumventing it due to the fact that you are not performing any actions that would require certification  In effect, it really should be called a PCI Avoidance Guide.  Until the PCI SSC themselves make an effort to filter some mud from the waters, this particular problem will only get worse.

 

 
New Post
6/4/2009 11:15 AM
 

Well, it seems that I have stepped into a hornet's nest here rich with past political discord, to which I can neither speak to nor offer any remedy.  You know that you've struck a nerve when someone pastes something in Times New Roman without typing directly within the editor.

My use of the word "struggling" here has been interpreted overly broadly (and, indeed if I had been aware of the history here I would have been more politic).  My intent was not to imply that ADNSF ML had trouble with PABP validation (with which it obviously complies), but rather that it has not been able to pull off a DNN-ADNSF PA-DSS version (which it clearly has not).  Since some effort appears to have been put into this area, I think that "struggling" (engaging in an activity with laborious effort) is a reasonable characterization, if not a bit imprudent.  This is perhaps supported by the lengthy response in which Mr. Van Kuren has described his experience in working with the corporation, apparently to naught.

While DotNetNuke has out-of-the-box *-DSS compliance issues, it remains my strong supposition that -- through configuration and utilization of existing, forward-compatible extension points -- there are few major issues that prevent its ultimate ability to reach compliance.  For example, logging is trivially remediated via custom provider.  Authentication, profiling, and membership may be brought into compliance via a stronger subsystem (such as the UpmMembershipProvider).  Data access maybe similarly secured via decoration of the existing provider (or even better by the full partition of PA-DSS-applicable data from its CMS-related counterpart).  Because of the project's MIT license, analysis of upgrades may be certified by any outside party to ensure continued compliance.

The fact that these issues are largely circumventable does not speak to the economic viability thereof, to which I briefly speak in my original post.  But the fact that no business model might exist that makes compliance-by-customization possible (a dubitable assertion) does not thereby imply that DotNetNuke is not, prima facie, PA-DSS certifiable without corporate assistance.  I can sympathize with your business arguments, but those are of an economic and not technical nature.

So, I am most interested in learning about what specific, unavoidable technical issues -- not able to be remediated through existing extension points -- that have been experienced which preclude PA-DSS compliance on the DotNetNuke platform.  There may very well be many -- but we are presently without sufficient detail to reach this conclusion.  At the risk of being repetitive, cost-sharing or communication-related issues are obviously apropos, but are nonetheless not technical issues.

Any argument that I have somehow otherwise misled is highly spurious, as I'm sure that any objective reader has already concluded.

Brandon


Brandon Haynes
BrandonHaynes.org
 
Previous
 
Next
HomeHomeOur CommunityOur CommunityGeneral Discuss...General Discuss...PABP-support in DNNPABP-support in DNN


These Forums are dedicated to discussion of DNN Platform and Evoq Solutions.

For the benefit of the community and to protect the integrity of the ecosystem, please observe the following posting guidelines:

  1. No Advertising. This includes promotion of commercial and non-commercial products or services which are not directly related to DNN.
  2. No vendor trolling / poaching. If someone posts about a vendor issue, allow the vendor or other customers to respond. Any post that looks like trolling / poaching will be removed.
  3. Discussion or promotion of DNN Platform product releases under a different brand name are strictly prohibited.
  4. No Flaming or Trolling.
  5. No Profanity, Racism, or Prejudice.
  6. Site Moderators have the final word on approving / removing a thread or post or comment.
  7. English language posting only, please.
What is Liquid Content?
Find Out
What is Liquid Content?
Find Out
What is Liquid Content?
Find Out