Writeups and actions like this from cloudflare are exactly why I trust them with my data and my business. Yes, they aren’t perfect. They do some things that I disagree with. But overall they prove themselves worthy of my trust, specifically because of the engineering mindset that the company shares, and how serious they take things like this. Thank you for the blog post!
Then, the advertisement worked. - Insist that you have better integrity than your competitors - share a few operational investigations after your latest security event what cloudflare doesnt do is provide their SOC risk analysis as a PCI/DSS payment card processor. Cloudflare doesnt explain why they ignored/failed to identify the elevated accounts or how those accounts became compromised to begin with. They just expl…
They clearly defined the scope of impact, and demonstrated that none of this impacts systems in scope for PCI. There was no breach to change management inside of BitBucket, and none of the edge servers processing cardholder data were impacted. They will have plenty of artifacts to demonstrate that by bringing in an external firm. So I am really not clear why you're bringing up PCI at all here. They made it clear no cardholder data was impacted so your perspective on the required "on-site" audits is moot.
Cloudflare operates two entirely different scopes for PCI; The first being as a Merchant where you the customer pays for the services. This is a very small scope of systems. The second is as a Service Provider that processes cards over the network. The network works such that it is not feasible to exfiltrate card data from the network. There are many reasons as to why this is, but they demonstrate year over year that this is not something that is reasonably possible. You can review their PCI AoC and get the details (albeit limited) to understand this better. Or you could get their SOC 2 Type 2 Report which will cover many aspects of the edge networks control environment with much better testing details. After reading that you can then come back to the blog and see that clearly no PCI scoped systems were impacted in a way that would require any on-prem audit to occur.
And they are not a card network. They are a PCI Service Provider because cards transit over their network. They are not at risk of being unable to process payments or transactions for their Merchant scope even if there are issues with their Service Provider scope. Because, again, these are two separate PCI audits that are done, testing two different sets of systems and controls.
And, as an aside, Cloudflare effectively always has on-prem PCI audits occur. Because the PCI QSA's need to physically visit Cloudflare datacenters to demonstrate not only the software side of compliance, but the datacenters deployed globally.