This is page 2 of:

PCI Scoping Toolkit: Where QSAs Fear To Tread?

September 4th, 2012

This conclusion holds even if the systems in question are segmented by an effective firewall that restricts their ability to interact with systems in the CDE—keep in mind that the PCI DSS Requirements and Security Assessment Procedures define “segmentation” to mean “isolation.” Naturally, the firewall itself is in scope because it connects directly to the CDE and provides critical security services.

So far, so good. The Toolkit supports the PCI Council’s guidance on scoping while adding some additional detail and color. However, the Toolkit begins to break new ground on the second question: Where does scope end?

The Scoping Toolkit makes a critical distinction between the CDE, which is infectious (as noted above), and those systems that can connect to or receive a connection from the CDE. The Toolkit treats these connected systems differently. They are in scope, but according to the Toolkit, the PCI scope ends there. These connected systems are not infectious. For example, based on the Toolkit, an enterprise’s antivirus update server is in scope if it can initiate a connection (through a firewall, remember) to a device in the CDE. But the rest of the enterprise’s systems that connect to that server are not drawn into scope. The merchant’s or service provider’s scope (i.e., “infection”) ends at that first “connected to” device so long as it does not store, process or transmit cardholder data and is isolated from the CDE. PCI scope does not continue to grow, thereby avoiding the formation of a daisy chain that encompasses almost every device in the enterprise.

The Toolkit again diverges from the PCI DSS Requirements and Security Assessment Procedures when it addresses the third question: What does it mean to be in PCI scope? Based on the Council document, if a process, device or system is in scope, then all 280+ requirements and sub-requirements of PCI DSS apply. This position has the appeal of straightforwardness. But the Scoping Toolkit challenges that.

The Toolkit takes a more nuanced approach, one that reflects the hands-on real-world experience of the people who created it. It describes how only a subset of PCI DSS requirements might apply to particular devices. The example given is for a workstation that, say, can pass through a firewall to administer a device in the CDE. That workstation does not store, process or transmit cardholder data. Although noting that each situation may be different, the Toolkit suggests that only PCI Requirements 1.4, 2, 5 and 6.1 might apply.

By identifying specific PCI requirements that apply in a given situation where scope is limited and by recognizing that each situation is different, the Scoping Toolkit adopts an approach similar to that underlying the shortened Self-Assessment Questionnaires (SAQs). That is, if a merchant’s card processing environment meets certain conditions, then it may validate its compliance against a subset of PCI requirements. The Scoping Toolkit extends this approach and applies it to the “connected to” devices and systems.

As I read the Scoping Toolkit, I find myself asking what will be its ultimate impact? As a QSA, I follow what the PCI Council provides in terms of definitions and guidance. Nevertheless, I respect the effort, thinking and expertise that went into both the Scoping SIG and the Scoping Toolkit. Maybe the Toolkit will generate some buzz at the upcoming PCI Community Meeting. I have to believe the timing of its release, just before that meeting, is not an accident.

Meanwhile, I would like to hear what you think. What is your reaction to the Toolkit? Is it a useful contribution? Do merchants and service providers need additional guidance on what systems are in their PCI scope? How will your organization use (or not use) the Scoping Toolkit? Either leave a comment or E-mail me.


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.