Yes, Virginia, We Really Do Need A QIR ProgramWritten 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.
After my last column about the PCI Council’s Qualified Integrator and Reseller (QIR) Program, reaction was unusually strong on both sides. And readers did force some questions to be addressed. For openers: Was it really necessary for the PCI Council to launch this program?
Bob Russo, general manager of the Council, said the program was “sorely needed, as evidenced by the number of data breaches” that happened due to implementation errors made by third parties such as system integrators and resellers. Russo pointed out that merchants buy Payment Application Data Security Standard (PA-DSS) validated applications to be secure, but those applications can’t provide the intended security if they are not installed and maintained properly.
Russo’s response reinforces what QSAs (including those who wrote to me, all of whom enthusiastically support the program) see too often: retailers spending good money hoping to get a secure payment application only to find out it has not been installed according to the vendor’s PA-DSS Implementation Guide. QSAs, acquirers and forensic investigators see shortcuts—for example, using the same passwords across multiple installations or leaving debug logs enabled (recording all transaction details)—that supposedly make troubleshooting easier. But these sloppy practices put retailers at risk. Too often, the result—confirmed by published data breach statistics—is that the retailer risks a business-threatening data breach. Anyone wondering why the QIR program needs to exist only has to look at the numbers.
The next question I got from two readers was: Why did the PCI Council act in a vacuum and develop the QIR program on its own? Why didn’t the Council reach out to trade organizations or other groups who have training programs already? Russo’s reply was direct: The Council did work with not one or even two but a range of industry parties to develop the QIR Program. Russo, who appeared surprised at the question, said: “The Council created a task force that included representatives from the card brands, software vendors and acquirers. The task force received a series of briefings from forensic investigators and others on the sources of data breaches. They heard about the risks. Software vendors and their trade group representatives were an integral part of the QIR task force. They provided a lot of valuable feedback.”
So much for the program being developed in a vacuum.
As to why the Council felt it needed to develop its own training and testing program, Russo said: “We want to concentrate on benefitting retailers. More training for integrators and resellers is a good thing, and any program that helps them do a better job installing applications correctly is better for everyone.”
Russo was being a bit more diplomatic about the need for more training than I might have been.