“Careless” Systems Integrators Now Directly Under PCI DSSWritten by Walter Conway
A 403 Labs QSA, PCI Columnist Walt Conway has worked in payments and technology for more than 30 years, 10 of them with Visa.
Mistakes made by careless or incompetent payment application installers or system integrators have led to far too many data breaches over the years. In each case, even though the reseller or integrator made the mistake, the merchant bore the ultimate responsibility.
Unfortunately, system resellers and integrators formerly fell in a governance gap in PCI, and their actions were outside the PCI Council’s jurisdiction. I say “were,” because that situation is about to change, and merchants are the ones who will benefit the most. Beginning later this year, system resellers and integrators will be held to training and testing standards as high as merchants and service providers. The winners will be merchants, for sure, but those competent system resellers and integrators will also find their high standards rewarded.
The PCI Council is in the process of rolling out a new program to train and approve (certify?) software resellers and system integrators. The Council will list on its Web site those organizations and individual employees who pass the training and meet its standards. The Qualified Integrator and Reseller (QIR) program is designed to improve merchant security, reduce risk and achieve PCI compliance. This program may prove to be one of the most significant developments since the introduction of the Payment Application Data Security Standard (PA-DSS).
As with any program, the burden ultimately rests with merchants to make this work. Merchants, as I have pointed out many times, can outsource the installation and maintenance of their payment applications, but they cannot outsource their responsibility. That fact has not changed: If your system is breached and you lose cardholder data, it is the merchant’s breach regardless of who installed the system. What is changing, however, is that the QIR program will give merchants the information and resources they have needed to have confidence their payment application is securely installed and maintained.
The QIR program will be particularly great news for small and midsize merchants, franchisors and their franchisees. It also will be welcome news for the many software resellers and system integrators who perform quality work for their customers and take security seriously. Although most resellers and integrators are competent, the reality is that some are not. And when a system is installed improperly or insecurely, the merchant pays the price.
The PCI Council is talking about the QIR program in “open mic” sessions for Participating Organizations. It also recently shared program details at a briefing for QSAs. Based on that QSA briefing, here is how we can expect program to work.
The Council will issue a QIR Program Guide by mid-year. This guide will spell out the implementation lifecycle and detail responsibilities for both the merchant and the reseller/integrator. QIR companies will be required to have an internal quality assurance (QA) program that double-checks the work of each individual installer.
After the implementation, the QIR will provide to the merchant a written report documenting that the software was installed securely and according to the software vendor’s PA-DSS Implementation Guide. Merchants will retain that report to show their QSA and/or processor and as evidence of the payment application’s proper implementation.
Approving QIR companies alone would be a positive step, but the PCI Council went further. Each individual employee who installs payment applications needs to be trained and tested to be included in the program. Merchants will be able to check that the particular individual who shows up to implement their payment software, configure their firewall, and configure encryption and key settings knows what he or she is doing. Merchants also will understand their responsibilities for maintaining the application and supporting the implementation.