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PCI DSS: The Next Generation
Another, more subtle point made by the PCI Scoping presenters was that just because a system is in the merchant’s PCI scope, does not mean that every single PCI DSS control necessarily apples. There are roughly 280 controls in PCI DSS. A patching server, for example, will not store, process or transmit cardholder data, so many of the requirements (e.g., Requirement 3, Protect Stored Cardholder Data, among others) will not apply. Next-generation PCI team members need to know they have the leeway to consider carefully each requirement and to determine whether or not it is applicable to their unique situation.
This is not to say merchants may take a risk-based approach to PCI. The difference may seem subtle, but merchants do not get to pick and choose between which PCI requirements they will apply and which they will skip. That approach has long been declared taboo, and the next-generation PCI team needs to understand that and move on.
One issue a U.S.-based next-generation PCI team will face very soon is the impact of the migration to EMV chip cards. I was recently asked whether the introduction of EMV chip cards in the U.S. market would not be the silver bullet that eliminates the need for PCI compliance. Unfortunately, I had to disabuse the questioner of that notion immediately. The answer is that EMV is about authentication, not confidentiality, and that PCI will not go away. Those of us who have been in the industry for a while know we resolved this question a long time ago. The next-generation PCI team was not around to hear the answer, however.
I hope the next-generation PCI phenomenon will produce one very particular, positive result: a fresh look at the organization’s PCI governance structure. Fresh people and fresh ideas present opportunities to improve how merchants and service providers manage their PCI compliance for the 364 days between yearly compliance validations.
For example, does your next-generation PCI team represent both the IT and the business side of the organization? Do the marketing and new product areas get their mobile commerce questions answered? Does the next-generation PCI team understand the impact of the new Wi-Fi system that the warehouse or fulfillment department is about to install? Are the EMV lessons from the organization’s European or Canadian operations—and the PCI compliance lessons from the U.S. operations—shared with the next-generation PCI team?
The emergence of the next PCI generation presents many more opportunities than challenges. Yes, it makes some people (like me) feel old or possibly frustrated at answering the same questions we heard five years ago. The upside, however, is the opportunity to take a fresh look at the organization’s PCI scope and PCI governance. These benefits will far outweigh any costs.
What do you think? I’d like to hear your thoughts. Either leave a comment or E-mail me.