Late last year, the chain decided to move its data center from an in-house facility to a purpose-built data center campus in another part of the United States. The goal was to gain additional raised floor space, energy efficiency and to avoid significant natural disaster risks with the location of the existing data center. In the QSA's review of the new data center, it was seen as a model of energy efficiency and modern design of data centers. So far, so good. But when the QSA returned for the annual PCI assessment, a review of the core switch and the layer 3 ACLs (Access Control Lists) revealed that all of the switch’s ACLs have been disabled—commented out—for both data centers. The formerly segmented network was totally flat with no segmentation.
One of the nation's 15 largest retail chains had done a tremendous job segmenting its network to reduce the scope of its PCI assessment. All of that was thrown away, though, during a simple data center transition, when Networking made a security change but no one ever bothered to tell senior IT management.