Hi, If I were to use separate Windows Server that was PCI-DSS compliant, would I still be compliant if I had a SQL Azure hosting the backend? This is assuming that I'm compliant at the application layer, and that I'm only storing permitted values (like no CVV), etc.
Thanks, Jack
With PCI DSS it is important to remember that it is not just about storing, it's "store, process, or transmit." If any of this happens in or through the cloud then the cloud becomes part of your cardholder data environment, thus in scope for PCI compliance. Since it's a cloud that you don't control, there would be no way to verify compliance.
No verification, no compliance. Sorry.
See http://www.mckeay.net/2009/08/14/cannot-achieve-pci-compliance-with-amazon-ec2s3/. Amazon says you can't achieve PCI-DSS level 1 compliance on their infrastructure. The important lines are -
It is possible for you to build a PCI level 2 compliant app in our AWS cloud using EC2 and S3, but you cannot achieve level 1 compliance. If you have a data breach, you automatically need to become level 1 compliant which requires on-site auditing; that is something we cannot extend to our customers.
I haven't read Azure's documentation, but I am pretty sure they don't allow on-site auditing. Given that, the same conclusions would apply to Microsoft Azure as well.
Not sure of PCI-DSS Compliance status in Azure, but I will note that Azure and EC2S3 are not the same animals. Azure is a completely hosted infrastructure which exposes services and endpoints to offer application writers the ability to sit on a fully managed and monitored (including typical security constructs in place for the on-premise Server product) platform, and extend these services to the resident applications.
Considering the amount of time that Microsoft has spent with the PCI folks (from Vista on), I would be highly surprised if a PCI-DSS compliant application didn't maintain it's level of certification when extended to Windows Azure.
Hope this helps. The purpose wasn't to bash EC2S3, it was more to fill in the blamks on Azure.
Mr. Helper :-)
Microsoft writes in the Azure Faq:
At commercial launch, Windows Azure will not have specific audit or security certifications. You can expect to see us pursue key certifications, such as the ISO27001, in the near future. The Windows Azure Platform and Windows Azure apply the rigorous security practices incorporated in the Security Development Lifecycle (SDL) process. SDL introduces security and privacy early and throughout the development process. The Windows Azure Platform and Windows Azure also benefit from the security capabilities afforded by the Microsoft Global Foundation Services’ (GFS) infrastructure. The GFS assurances are validated by external auditors on a regular basis and include a comprehensive security program that covers the entire delivery stack.
Microsoft makes no claim regarding PCI standards for 3rd party hosting. There are ways to develop cloud based applications to use 3rd party PCI data processers that may keep the cloud application itself out of scope.
http://www.microsoft.com/windowsazure/faq/default.aspx
choose "Licensing and Service Level Agreements" in the drop down then find the last paragraph "What industry audit and security certifications cover the Windows Azure Platform? Specifically, call out position on SAS70, ISO 27001, and PCI?"