Compliance should be a concern for any organizations that deal with the data of their consumers. Unfortunately, it is not always simple for businesses to fulfill the security standards of frameworks such as the PCI Data Security Standard.
The technical and/or commercial restrictions that an organization must contend with are the elements that influence the choices it makes about security and, in some cases, prevent it from putting particular measures into effect.
In the case that an organization is unable to fulfill the criteria for a protective measure, it is required to implement an alternative mechanism that provides a degree of security that is comparable to the standard that was first established.
A compensating control, which is also known as an alternative control, is a system that is implemented to meet the requirements for a security measure that is currently considered too complex or impossible to implement. Compensating controls were included in PCI DSS 1.0 for the payment card industry (PCI) by the PCI Security Standards Council (PCI SSC) in December 2004.
The PCI SSC has since updated the standard regularly. Version 4.0 the most recent one was released in March 2022. The material on compensatory controls saw some little changes between versions 1.0 and 4.0, although overall the rules have not altered all that much.
Compensating controls, as defined by the PCI SSC, provide businesses with an alternative to security standards that are not able to be satisfied "due to legitimate and documented business or technical constraints." Controls for compensating must adequately reduce the risk posed by the initial requirements.
Setting priorities is essential for efficient vulnerability management in any situation, but it's particularly important for OT. The implementation of security updates in complex systems, where periodic maintenance windows and round-the-clock uptime are standard, presents a significant potential cost when patching industrial equipment.
The reality that updates may not always be easily or instantly accessible is another common obstacle to patching in over time. Because these specific vulnerabilities are built into the firmware and/or protocols of the impacted devices.
Compensating controls are useful in situations like these and otherswhen it isn't practical to install updates on time, if at all. Implementing risk-informed rules proactively (and reactively fine-tuning them as necessary) in line with a zero-trust architecture significantly lowers the probability of and lessens the risks associated with the exploitation of various known and undiscovered vulnerabilities in an OT environment. This requires careful monitoring and management of the devices that are located at the endpoints. The goal is to ensure that these devices are secured against known vulnerabilities and kept up to date, while also ensuring that they have just the access that is necessary for them. When it comes to keeping endpoint devices from becoming the weakest link in your security system, this step is very important.
These systems monitor network traffic to identify potentially malicious behaviors or known attack signatures. They are also able to take automatic steps to prevent or control attacks.
The primary objective here is to strengthen the resistance of each system against assaults. To do this, it is important to eliminate software that is not required, disable services that are not being used, and implement stringent access control mechanisms. The goal is to strengthen every single layer of protection that your system has.
By separating the network into separate parts, we are able to protect vital systems from any possible breaches that may occur in places with lower levels of security. Taking this strategy protects critical components of the network and reduces the amount of harm that may be caused by a breach.
When user access privileges are checked and adjusted regularly, as well as when multi-factor authentication is used, the danger of unwanted access is significantly reduced, which brings an increase in security.
Establishing formal processes for assessing, authorizing, and documenting changes to information technologyand operational technology (IT/OT) systems and configurations to avoid illegal modifications and limit the risk of interruptions. Through the process of distributing tasks and privileges across various persons or teams, it is possible to avoid conflicts of interest and lower the likelihood of mistakes or fraud occurring.
Protecting against the loss or theft of data, particularly in situations such as ransomware attacks, may be accomplished by backing up the data consistently and encrypting it. If you want to have a complete security plan, this is a vital component.
Experts advise taking into account the following compensatory controls;
Because of the complexity of these settings, the abundance of proprietary protocols, and the age of the legacy systems, it may be difficult to compile an accurate inventory of OT/ICS. Accurate asset inventories and an understanding of the relationships and dependencies within the environment are made possible by comprehensive insight into the environment.
This makes it possible to implement security measures more thoroughly, particularly for network and internet-facing systems.
The only hardware and software that should be allowed to operate in the environment are those that have been specifically authorized.
In situations when implementing an identical security protocol for both IT and OT networks is impractical, network segmentation might serve as a compensatory measure. Segmentation separates a network into many distinct physical or virtual zones.
Segmented networks may reduce the likelihood that an attack or malware will propagate to other parts of the larger network, confine intrusions, and compartmentalize security events to a single network segment.
Enforcing strong password generation and multi-factor authentication, together with removing default passwords from devices inside the environment, would significantly improve the environment's overall security.
Risk may be significantly reduced by taking an inventory of assets, keeping track of known vulnerabilities, matching vulnerabilities to assets, and regularly monitoring behavior. This is particularly true when an incident response strategy is in place to spot suspicious activity.
Increased monitoring and detection may be a useful compensatory control when preventative interventions are lacking.
It's not simple to implement compensatory controls. Ensuring that the controls are successful in reducing risks to a manageable level takes a lot of work, attention, and money. Organizations often struggle to find appropriate compensating measures that will adequately manage their particular risk profile.
Making sure that these restrictions are correctly implemented and integrated with the current security measures is another problem. This might include spending money and effort revamping systems or processes to incorporate additional controls.
Furthermore, since compensating controls provide several ways to accomplish security goals rather than directly addressing vulnerabilities, it may be difficult to gauge their efficacy. To determine if their compensating controls are operating as intended, companies must set up metrics and monitoring systems.
Since dangers are ever-evolving, maintaining compensatory control efficacy over time is likewise a difficulty. Companies need to keep a close eye on their risk profiles and assess whether their present compensating control scheme is still acceptable or needs to be adjusted.
Sustaining the security and resilience of IT/OT environments requires proper management of compensating controls. The following are some recommended procedures;
- Provide written guidelines and protocols for the selection, application, and administration of compensating controls.
- Clearly state the roles and duties of all staff members managing compensating controls.
- To make sure that compensating controls are appropriately established and functioning, conduct regular audits and evaluations of them.
- To find areas for improvement and manage gaps and vulnerabilities, use both automated tools and human evaluations.
- Encourage cooperation and dialogue between the OT and IT departments to guarantee a comprehensive security strategy.
- Identify shared hazards, exchange threat information, and apply uniform security controls to both IT and OT environments by coordinating your activities.
- Employees managing compensating controls should get thorough training as well as continuing education.
- Inform employees on new developments in technology, cybersecurity best practices, and emerging dangers.
- Adopt a risk-based strategy for compensating control management, allocating resources to address the biggest threats to IT/OT environments.
- Evaluate risks regularly and modify compensatory measures as necessary to handle new threats and weaknesses.
- Reduce human error, increase productivity, and handle compensatory controls more easily by using automation tools and technology.
- Incorporate real-time security event detection and mitigation with automated monitoring, alerting, and response functionalities.
- Keep thorough records of compensating controls, including their objectives, setup parameters, and performance indicators.
- For audit and compliance reasons, keep a record of any updates and modifications made to compensating controls, along with the reasoning behind them.
- Encourage a culture of continuous improvement by periodically evaluating and revising compensating controls in light of audit feedback, lessons learned, and evolving threat scenarios.
- To identify opportunities for improvement and make sure compensatory controls are in line with corporate aims and goals, get input from stakeholders and end users.
Compensating controls help enhance security posture by providing additional layers of defense against cyber threats and vulnerabilities.
Compensating controls are secondary measures used when primary controls are inadequate, whereas primary controls are the main security measures implemented to address specific risks.
Regulatory requirements, organizational risk tolerance, resource constraints, and operational limitations are factors that influence the selection of compensating controls.
Examples include security awareness training programs and incident response and management procedures.
Talking about what are effective compensating controls in IT/OT environments, using compensating controls is an approach that goes beyond just responding to hazards. It's a proactive mindset that enhances conventional patching techniques. These controls provide a flexible approach to OT system security, where patching and compensating measures are applied based on knowledge of the network topology and the roles of individual assets.
This approach focuses on predicting and being ready for dangers rather than merely responding to them when they materialize. By including these controls into your cybersecurity architecture, you can improve resilience, protect vital infrastructure, and maintain operational continuity in the face of constantly changing cyber threats.