Change management is the process of controlling the lifecycle of all changes to minimize disruption to IT services. It includes formally documenting all proposed changes, assessing their impact, obtaining approvals, testing changes, and back-out procedures. The Change Advisory Board evaluates proposed changes and assists the Change Manager in prioritizing and scheduling changes. Challenges include ensuring complete documentation, testing, and sign-offs for all changes as required by PCI compliance. Effective change management processes take time to implement fully and require adherence from all IT staff and developers.
2. PCI Requirement on
Change Management
1.1.1 A formal process for approving and testing all
network connections and changes to the firewall and
router configurations
6.4.5 - Change control procedures for the
implementation of security patches and software
modifications. Procedures must include the following:
Documentation of impact
Documented change approval by authorized parties
Functionality testing to verify that the change does not adversely
impact the security of the system
Back-out procedures
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3. What is Change Management?
ITIL Definitions:
Change Management C
The process responsible for controlling the lifecycle of all
changes. The primary objective of Change Management
is to enable beneficial changes to be made, with
minimum disruption to IT services, security standards
and updating the existing ones
Request For Change (RFC) C
A formal proposal for a change to be made. An RFC includes
details of the proposed change, and may be recorded on paper
or electronically. The term RFC is often misused to mean a
change record or the change itself
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4. What is Change Management?
ITIL Definitions:
A Change C
The addition, modification or removal of anything that could
have an effect on IT services. The scope should include all IT
services, configuration items, processes, documentation, etc.
Change Advisory Board (CAB) C
A group of people that advises the Change Manager in
the assessment, prioritization and scheduling of
changes. This board is usually made up of
representatives from all areas within the IT service
provider, representatives from the business and third
parties such as suppliers
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5. What is included/ in scope?
Anything that is considered to be part of the production
environment and within PCI scope
Changes to the IT infrastructure (HW) or operating
system (patches)
Any software changes, be it application (bespoke/
standard) or database, new installations or upgrades
Changes to LAN and WAN, data lines, configuration
changes, firmware upgrades, etc.
External systems such as mail servers, PBX for call
centre, voice recording systems etc.
Data center supporting equipment like UPS, generators,
cooling units, fire suppression, etc.
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6. Change Advisory Board (CAB)
The Change Advisory Board (CAB) is a body that exists
to support the authorization of changes and to assist
Change Management (assessment and prioritization)
with changes to LAN and WAN, data lines, configuration
changes, firmware upgrades, etc.
The Change Manager normally chairs the CAB, and
potential member include
Customer(s)
Facilities/office services staff
Services and operations staff
User manager(s), user group representative(s)
Contractors or third parties representativesOther parties
Applications developers/maintainers, specialists/technical consultants
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7. CAB Agenda
The Change Management process, including any amendments made to it
during the period under discussion, as well as proposed changes
RFCs that have already been assessed by CAB members and were put on
hold, pending additional information or testing
Failed changes, unauthorized, backed-out changes, or changes applied
without reference to the CAB by incident management, problem
management or Change Management
Outstanding changes and changes in progress
RFCs to be assessed by CAB members C in structured and priority order
Advance notice of RFCs expected for review at next CAB
Review of unauthorized changes detected through Configuration
Management
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8. Emergency Change
In an emergency situation it may not be possible to convene a
full CAB meeting. Where CAB approval is required, this will be
provided by the Emergency CAB (ECAB)
Not all emergency changes will require the ECAB involvement
An emergency change procedure will follow the normal change
procedure except that approval will be given by the ECAB
rather than waiting for the full CAB meeting
The CAB should be informed of any emergency changes and/
or changes that have been implemented as a workaround
All emergency changes are documented and signed off by
three CAB members
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9. Initiate
Change Detailed Change Process Change Builder
Change, Rollback,
Change Mgr. Testing, Implem.
reviews RFC
Yes
No Close Urgent?
Accept? Change
No
Yes
Change Mgr. Independent
Prioritizes Testing
Yes ECAB Evaluation & Yes No
Urgent? Meeting Review Urgent? Positive?
No Yes
No
Change Mgr. Change Manager
Categorizes Release Change
& Implement
Minor Significant Major Standard
Change Mgr. CAB CAB/ Mgmt. Change Mgr.
Authorizes & Authorizes & Authorizes & Monitors No
Monitors Monitors Monitors Process Positive? Implement
Rollback
Implement
Yes per process Yes
Authorized? Change Mgr.
No Review
Submit more Yes No Close
Information Need Info? Change
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10. PCI Compliance Challenges
Verify that the correct access rights have been given to
the various roles
Ensure that every week has two records of the change
log C before and after the CAB
Consistency of the data in the log e.g. approval date
cannot be after the installation date, a status cannot be
skipped
All CAB members need to sign off on the change log as
a collective endorsement of everything agreed upon
during the meeting
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11. Implementation Challenges
Everything takes longer, especially in the beginning
No more shortcuts by sales and management
It takes time for IT staff and developers to understand
what complete information on a change request means
Starting with more than less, is the way to go. When
people make assumptions, they are generally wrong
Testing of the change AND the roll back scenario is not
only required, but must be documented
HR policies need to be upgraded to allow consequences
when the process is not adhered to
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12. Change Categorization
Minor impact and few resources needed
Change Manager evaluates and can approve autonomously
Significant impact and significant resources needed
CAB meeting to evaluate and approve or reject
Major impact and a high level of resources needed
After CAB approval, may additionally seek management approval
Standard C pre-approved changes
Change manager checks that the correct procedures are followed
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