This is page 2 of:

PCI 2.0 Or 1.2—The Choice Is Yours, For Now

November 4th, 2010

The good part is you will be able to find (and remove?) cardholder data that can lurk in expected and unexpected places. The bad part is finding it all is likely to take some effort.

How do you find all the cardholder data? You can start with the places you know about now, including the back-office departments that do accounting, chargeback processing and dispute resolution.

The situation the revised guidance is designed to address, though, is not all the “usual suspects.” It’s the unknown unknowns; that is, the places where cardholder data may have leaked—intentionally or not.

Things get complicated when a processor uses insecure means to return transaction data to the merchant. Merchants report that in some cases their processors use E-mail or FTP to transmit cardholder data to them. In addition to bringing any number of the retailer’s systems into PCI scope, the operational result is a range of databases, flat files, servers, flash drives, laptops, spreadsheets and myriad other places that are used to “store, process or transmit” cardholder data. Confirming your PCI scope, therefore, is likely to take some effort under Version 2.0.

For example, how is an IT executive to know how many files were created or whether all have been securely identified and purged? Furthermore, how is your QSA to confirm that?

The guidance says: “The entity retains documentation that shows how PCI DSS scope was confirmed and the results, for assessor review and/or for reference during the next annual PCI SCC scope confirmation activity.” Unfortunately, there is no example of what the PCI Council means by “documentation.” Lacking something concrete, it will be hard for a QSA to meet this requirement.

During training, QSAs are instructed that it is their responsibility to determine the scope of the assessment. Currently, we rely on cardholder dataflow diagrams, network diagrams and interviews to make this determination. We often use sensitive number finders and other automated data discovery tools partly to confirm the scope but also to reduce the risk of a data compromise.

Under Version 2.0 these automated tools seem, at least to me, to be all but required. Without one of these tools, it is difficult to see how a merchant or processor can either be sure all their cardholder data has been found or document their findings.

The upside is that it won’t necessarily cost merchants any money for a good tool. A number of decent open-source tools are available. The investment will be in tuning the tool, applying it thoughtfully and carefully, and documenting the findings for the assessment.

For 2011, all merchants and processors have the option of using either PCI Version 1.2 or PCI Version 2.0. Given the quirks of the calendar, that means those who validate in the fourth quarter of this year can continue to use 1.2 again next year. In other words, they won’t have to validate compliance with PCI 2.0 until the end of 2012. I recommend that you decide carefully and with some deliberation.

Which version will you choose? I’d like to hear your thoughts. Either leave a comment or E-mail me at


Comments are closed.


StorefrontBacktalk delivers the latest retail technology news & analysis. Join more than 60,000 retail IT leaders who subscribe to our free weekly email. Sign up today!

Most Recent Comments

Why Did Gonzales Hackers Like European Cards So Much Better?

I am still unclear about the core point here-- why higher value of European cards. Supply and demand, yes, makes sense. But the fact that the cards were chip and pin (EMV) should make them less valuable because that demonstrably reduces the ability to use them fraudulently. Did the author mean that the chip and pin cards could be used in a country where EMV is not implemented--the US--and this mis-match make it easier to us them since the issuing banks may not have as robust anti-fraud controls as non-EMV banks because they assumed EMV would do the fraud prevention for them Read more...
Two possible reasons that I can think of and have seen in the past - 1) Cards issued by European banks when used online cross border don't usually support AVS checks. So, when a European card is used with a billing address that's in the US, an ecom merchant wouldn't necessarily know that the shipping zip code doesn't match the billing code. 2) Also, in offline chip countries the card determines whether or not a transaction is approved, not the issuer. In my experience, European issuers haven't developed the same checks on authorization requests as US issuers. So, these cards might be more valuable because they are more likely to get approved. Read more...
A smart card slot in terminals doesn't mean there is a reader or that the reader is activated. Then, activated reader or not, the U.S. processors don't have apps certified or ready to load into those terminals to accept and process smart card transactions just yet. Don't get your card(t) before the terminal (horse). Read more...
The marketplace does speak. More fraud capacity translates to higher value for the stolen data. Because nearly 100% of all US transactions are authorized online in real time, we have less fraud regardless of whether the card is Magstripe only or chip and PIn. Hence, $10 prices for US cards vs $25 for the European counterparts. Read more...
@David True. The European cards have both an EMV chip AND a mag stripe. Europeans may generally use the chip for their transactions, but the insecure stripe remains vulnerable to skimming, whether it be from a false front on an ATM or a dishonest waiter with a handheld skimmer. If their stripe is skimmed, the track data can still be cloned and used fraudulently in the United States. If European banks only detect fraud from 9-5 GMT, that might explain why American criminals prefer them over American bank issued cards, who have fraud detection in place 24x7. Read more...

Our apologies. Due to legal and security copyright issues, we can't facilitate the printing of Premium Content. If you absolutely need a hard copy, please contact customer service.