As a major part of becoming and maintaining PCI compliance, organizations are tasked with performing routine/periodic tasks over the course of a year.  And during their annual PCI re-validation, the organization is required to provide evidence that these routine tasks have been performed. But what happens when the QSA determines that the organization did not keep up with their homework? How does it affect their PCI compliance?

Short answer….it doesn’t.

Merchants and service providers (SP) are required to perform the following routine tasks which a QSA then needs to validate as having been completed:

  • Daily review of audit logs
  • Quarterly internal vulnerability scans
  • Quarterly external vulnerability scans
  • Quarterly scans w/wireless analyzer
  • 6 month review of firewall/router rule sets
  • Annual risk assessment
  • Annual review/update of infosec policies
  • Annual internal penetration test
  • Annual external penetration test
  • Annual security awareness
  • Annual incident response test

Of course if this is an organization’s first attempt at compliance, they will be unable to provide a “year’s” worth of evidence that the above has been completed.  But, if this is not their first time around the PCI block, then the organization should be able to provide a year’s worth of evidence.  However, what happens when a merchant or SP missed a quarterly scan or it’s been over a year and they have yet to conduct IR testing?  One might think that they’ve missed their mark to be compliant for that year, and another year needs to go by.  But that is not the case. If an organization failed to meet a task, they are simply asked to promise (and mean it this time) in a strongly worded policy/procedure to have it done in the required timeframe next year.  As for the current assessment, the organization just needs to get it done and submitted to the QSA for review, even though it is outside of the task window. As long as it’s done sufficiently, the QSA has no choice but to mark it “In Place.”

What’s the point? I’d like to see a QSA that actually tells the organization, “Nope, you missed the annual window. You’ll have another chance to be PCI compliant next year.”  I know I am being harsh but where are the consequences for not taking these tasks seriously knowing they can just get it done after the fact?  Does a breach have to occur in which the card brands, jumping up and down, pointing their finger proclaiming that “at the time of the breach, the organization was not PCI compliant.”  By then it would be too late.  I think most of us can agree that the tasks identified are part of a comprehensive infosec security plan; however, I consider this is just another example as to why the PCI standard itself needs to be re-evaluated on how it is being applied.

Letter to the client

July 7, 2010

Dear Client,

I know you have reservations about going through an assessment so I propose a mutual commitment of things we can both do to make this process as  painless as possible:

You agree to do the following:

  1. Gather as many of the policies, procedures, and supporting documentation available before I arrive.  In other words, if you say you do something, be able to provide some sort of evidence that it is being done.
  2. Schedule  interviews with the people who “do” the actual work, not the managers that think they know what’s happening down in the trenches.  I’m sure you think you know what is supposed to occur, but in the interest of not wasting our time, I’d prefer to speak with those that actually do the work.
  3. Identify your environment.  Make sure there is an updated network diagram and a matrix detailing all of the systems that deal with sensitive information.  For example, during the assessment is not the time to discover the backup of the production database under the receptionist’s desk, which was replicated “just in case.”

I agree to do the following:

  1. I will not be your enemy.  My goal is not to publicly humiliate you or your staff.  The goal is to work together to identify any gaps in your infosec program in order to make it better.
  2. I will not know everything there is to know. I encourage you to “push back” if you do not agree with anything I say or find.  I welcome conversation as it better helps me understand your environment.
  3. I will not ask “trick questions.” If you want to mislead me, then that is on you.  I am going to ask you what I need and want to know.

An assessment can be a learning experience and by agreeing to the terms listed above you can expect the same courtesy in return.  As this can help in easing the pain that is….A security assessment.

Disclaimer: I do not speak for all infosec assessors, neither good nor bad.  These are my own thoughts based on my own experiences.