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“Careless” Systems Integrators Now Directly Under PCI DSS
The QIR program will be modeled closely on the current QSA program. That is, there will be QIR companies and individual QIRs, who will be the people installing the application. QIR employees will go through PCI Council training (which is under development) and take a written exam. Approved QIR companies, together with individual qualified installers, will be listed on the PCI Council’s Web site.
The message for merchants is clear: If you use a software reseller or system integrator, make sure the company and the person who shows up on your doorstep to install the application are both on the QIR list. If they are not, you cannot be certain that your PA-DSS validated payment application is properly implemented.
Merchants will determine whether the whole QIR program will succeed or fail. There will be no PCI Council or card-brand mandate (more on this later). Merchants will be encouraged to use QIRs listed on the Council’s Web site, to follow the program guide and, importantly, to read the program guide and maybe look over the shoulder of their implementer.
It will be interesting to observe how this program unfolds and how the market reacts. One wild card is price: Will it cost more to have a QIR implement a payment application? QIRs will have some added costs—I’m sure the PCI Council will charge for QIR training and listing. Will QIRs absorb these costs, or will they pass them along in the form of higher prices?
Could we see a two-tiered market where merchants can have a QIR install their application for one price or have a less qualified, less experienced, less professional person do it for a lower price? If we have a two-tiered market, how will merchants react, particularly small merchants, who may be more price sensitive and less security aware.
Another wild card will be how the software application developers themselves react. Will they insist that their resellers be QIRs? It makes sense that software vendors would take this step to ensure the quality of their product and brand in the marketplace. It also costs the software vendor nothing, because the reseller or integrator will pay the training and listing fees.
Will QSAs and processors accept the QIR’s report of a secure implementation at face value? If a report is challenged, I have to believe the QSA’s opinion would still carry the day. But it certainly would lead to some touchy discussions between the QSA and his or her merchant.
Lastly, although neither the Council nor the card brands will mandate using QIRs (as noted above), will processors insist that merchants prove they used a QIR? Or will the QIR report be required as part of each merchant’s Self-Assessment Questionnaire (SAQ)? The PCI Council is in its feedback period, and I get the impression that the SAQs, too, are fair game for revision and updating to reflect both new programs and current attack vectors. Visa and MasterCard have already mandated PA-DSS-validated applications for those merchants who use packaged payment applications. Will the PCI Council and the card brands similarly mandate QIR implementation where resellers or system integrators are used?
Clearly, there are lots of questions, as is expected with any new program. Nevertheless, none of these questions detracts from the fact that the QIR program is a very positive development for merchants. I understand that the PCI Council consulted with leading software vendors, system resellers and system integrators as it developed the QIR program and guidelines. Hopefully, when the program is implemented it will reflect best practices and reduce data compromises at merchants, franchises and franchisors.
What do you think? Do you use a system reseller or integrator? Would you pay a little more to have a QIR do your installation and provide you with documentation? I’d like to hear your thoughts. Either leave a comment or E-mail me.