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PCI Self-Assessment Questionnaires Need Some Major Updates

July 21st, 2010

For SAQ B I would like some clarification for the merchants. For example, terminals that “dial out” with an IP line use the Internet. Therefore, in my opinion, they are ineligible for this SAQ (see SAQ C, below). I would like this fact spelled out explicitly in the SAQ instructions, because many small merchants may not understand this distinction.

My other clarification deals with the “terminal data capture” situation where the terminals retain cardholder data after authorization. At a prescribed time, an employee “batches out” the terminal and transmits a file with the day’s (or weekend’s) card transactions to the acquirer for processing. To this QSA, the POS device–and, therefore, the merchant–is storing data electronically. Therefore, merchants with terminal capture would not qualify for a simplified SAQ of any kind under the present guidelines.

We have to understand that the decision on which SAQ a merchant should use is not up to the QSA; the acquirer makes that decision. I had an acquirer overrule me on this exact SAQ B situation–where the POS terminals were storing the card data–and I was fine with that decision.

In my heart of hearts, I agreed with the acquirer because the risk was pretty small. But as a QSA, I need to follow the letter of the PCI law and look out for my client (no matter how much they had trouble understanding it at the time). I think the people who developed SAQ B may well have intended to include terminal capture devices. Either way, a brief clarification on the SAQ instructions to merchants would be welcome.

SAQ C may be most in need of an overhaul. It was designed for merchants that have a payment application connected to the Internet, generally to authorize card transactions. The previous prohibition on storing electronic cardholder data applies to SAQ C merchants, but there is one particularly awkward requirement: “The payment application/Internet device is not connected to any other systems within your environment.”

The reason I call this “not connected to any other system” requirement awkward is that it almost never exists in the real world. Payment applications need to connect to other systems for antivirus and patch updates; they also need to connect to inventory and pricing systems. I can have a merchant segment the payment application behind a firewall, but how many holes does it have to punch in that firewall to allow for the other business services?

My experience is that almost every call center, and a few zillion retailers, thinks it qualifies for SAQ C. In reality, only a very small number do. Reading the instructions carefully, about the only situation where it applies is for those POS terminal merchants with an IP line for authorizations. I think the people who created SAQ C intended more.

The creators of the three simplified SAQs wanted to help merchants become compliant. To a great extent, they succeeded, and for that we should all thank them. The PCI Council and card brand staff who worked on these SAQs did a tremendous amount of work. Before SAQs A, B and C, there was only SAQ D with its 226 questions covering all of the DSS. And not all of these questions were relevant to a large number of merchants. In fact, that original, overwhelming SAQ probably scared some of these same merchants away from PCI compliance.

My hope is that as the PCI Council takes a fresh look and reflects on the merchant feedback, it will consider these ideas as well as the many others I’m sure it has received. It is neither wise nor realistic to go back to the “one SAQ fits all” approach. A few tweaks of SAQs A and B will go a long way; SAQ C is likely to need a more thorough overhaul.

Are you a Participating Organization on the PCI Council? You should be, by the way. And if you are, have you sent any suggestions for improvements on the SAQs? What were they? I’d like to hear your thoughts. Either leave a comment or E-mail me at wconway@403labs.com.


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