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PCI 2.0 Changes: The Good, The Bad And The Hashing

October 28th, 2010

The clarification to Requirement 11.1 is a sensible one that may make compliance easier for retailers with a large number of locations. That requirement also dealt with wireless security and formerly instructed retailers to “test for the presence of unauthorized wireless access points by using a wireless analyzer at least quarterly or deploying a wireless IDS/IPS.” The requirement now states, “methods that may be used in the process include, but are not limited to, wireless network scans, physical site inspections, network access control (NAC) or wireless IDS/IPS.” That means you don’t necessarily have to carry a wireless analyzer. A little physical observation and war-walking might do the trick. Don’t let this be a throwaway; rogue wireless devices are a very real threat, and you should take these (at least) quarterly inspections very seriously.

Going beyond the changes to the actual PCI DSS, the Council announced a number of initiatives to improve communication with merchants and processors. These initiatives include a new Web site (with special sections for small merchants), a new “Navigating the PCI DSS Document” and revised Self-Assessment Questionnaires (SAQs). There may even be a new SAQ or two, if I understood some of the hints at the Community Meeting.

At the risk of being picky, there is one area that I wish had been addressed and one statement in the PCI DSS that I believe is incorrect and needs to be changed.

The area that didn’t get addressed is Requirement 12.8. It seems uniquely unfair that retailers need to get their service providers to acknowledge in writing their responsibility for the security of the retailers’ data in their control, but there is no corresponding requirement for the service providers to actually give that acknowledgement. I pointed this out during one of the sessions with the PCI Council and the group noted it thoughtfully, so maybe we will see this reflected in an updated version.

The change that didn’t get made is the definition of the scope of external vulnerability scans. Both the previous and new documents state that “Scan[s] must cover all externally accessible (Internet-facing) IP addresses in existence at the entity.” I had hoped the PCI Council might update it to specify only IP addresses in the cardholder data environment. This specific issue was raised at last year’s Community Meeting, and the response was that scanning only applied to the cardholder data environment. Given that a lot of retailers and processors can have thousands of IP addresses, I would have thought this definition might be corrected. At least, I hope it’s a correction!

There are many other clarifications, some small and some large. Which items caught your attention? What changes did you want to see? I’d like to hear your thoughts. Either leave a comment or E-mail me at wconway@403labs.com.


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