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GuestView Columnist Joel Weise–the chief technologist for Sun Microsystems GSS Security Program Office–argues that although there are many qualified security assessors (QSAs), “a few who simply do not have the background and expertise in systems security manage to distort the original intent of PCI.” “A good QSA would ask not only if an antivirus package existed or if a firewall appliance was installed or if a unique user ID policy was followed, but also how these were designed, architected, implemented, configured and monitored,” Weise wrote. “A good QSA would ask to what security policy must applicable operational procedures adhere and whether anyone looks at the alerts and logs generated by the antivirus or firewall products.” Read more. |
April 16th, 2008 at 11:01 am
This excellent post should be required reading for every QSA in training and more importantly, every person responsible for their company’s PCI compliance.
PCI is not a checklist; it is a data protection standard. It is evolving as we speak, and we can expect some changes (big or small, no one yet knows) in the fall. A checklist mentality will blind you to the bigger picture.
Joel is also right in pointing out that security is an art. QSAs are people, so some will be better at their “art” than others. You can interview the QSA organization all you want, but the key is to meet and be comfortable with the individuals who will be working on your compliance project. Some questions you might ask are:
– Tell me what you know about my industry and how my customers pay;
– Can you help me move a lot of my systems out of scope (…my personal favorite question)?
– How will we resolve our differences? or
– What other (remediation) products and services are you selling?
The PCI Council is releasing a quality assurance program for QSAs and ASVs, but it needs merchant participation to be successful. Did you complete a QSA satisfaction survey form after your last audit? (BTW, they are required to give this survey to you; if they forgot, it is on the Council’s website.)
As Joel said, there are a lot of great, experienced, informed, and helpful QSAs out there. The idea is to make sure you get one of those.
April 16th, 2008 at 6:27 pm
Excellent piece Joel! You and I have had this very conversation many times, and we see it in the field ALL the time.
April 17th, 2008 at 10:29 pm
I agree with the premise and would hasten to add that there are many examples of assessment process issues in the PCI Knowledge Base.
Another issue that plays a major role in the QSA process is that assessors rely heavily on the vendors and products that they “know” or have experience with on other assessments. Some assessors go so far as to resell products, but most do not.
A result is that if an assessor is not familiar with a particular security product, the merchant (and sometimes the vendor) is placed on the defensive and must go to greater lengths to “prove” that specific functionality matches specific PCI DSS requirements.
This scenario tends to favor market leading security vendors and those vendors who have established “relationships” (formal or informal) with particular assessors. In some cases, assessors also sell their own security products, suggesting to merchants that there is a “Chinese Wall” that separates the different parts of the company.
My personal suspicion is that a notable breach, or merchant outcry, or government intervention will, at some point, serve as a “friendly reminder” that there is a lesson from the Enron case that some companies still need to learn. IMHO.