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PCI’s Not-So-Open Global Forum

July 22nd, 2013

Really? Are we going to have this argument again, PCI Council? I thought we resolved this back in Orlando in 2010 when I took the open mic on the subject at the PCI Community Meeting. At that time it was about “additional DSS reporting requirements” that I knew nothing about until my QSA was on site explaining to me why he was asking for a lot more detail for his executive summary and checkboxes. At that meeting, the Council admitted they needed to do a better job of keeping the entire community informed of important changes to the Data Security Standards and avoid suppressing important updates from participating organizations. In fact, the very next day, the additional reporting requirements were posted in the Documents Library. But it now appears the PCI SSC has fallen back into its old ways of keeping participating organizations in the dark.

I just can’t figure out why I have to learn about security standards changes or so-called “new guidance” from my QSA or PA-QSA and not via official correspondence from the PCI SSC to all participating organizations. It makes no sense to tell only the assessor community. Why is there a secret society within a self-proclaimed, open global forum?

I reviewed the lifecycle policy for PCI DSS and PA-DSS, and there is a provision for “minor changes or errata” the Council may publish at any time. Unfortunately, the Council publishes these changes in a newsletter that goes out only to the assessor community. Is this where new standards, revisions, and errata – that apply globally – should be published? I think not.

In its own words, the PCI SSC defines itself as “an open global forum.” Open global forum? What part of this practice is open or global? What the Council needs is a global newsletter that goes out to the entire PCI community so that we can all be on the same page.

Now it’s been a few years since I last took a political science course and studied the Rule of Law, but I do recall a specific requirement that all laws be publicized before they are enforced. And that publication of the law has to be broad enough so that any interested party can find it. Well, here I am. I am an interested party, and I want to know more about this change to Requirement 4.2.7, but I can’t find any written information. Until I do see officially published documentation, I will consider the PCI Council’s guidance to the assessor community regarding PA-DSS Requirement 4.2.7 to be an illegal change to an existing, in-force security requirement.

You need to fix this, PCI SSC. So please come down from your ivory tower and follow your own written policies. I’m tired of the PCI SSC using the QSAs to bully participating organizations. From personal experience, I know that many QSAs and PA-QSAs are frustrated that they constantly have to explain the Council’s position in the absence of any concrete, black-and-white security standard. That is just wrong.

I look forward to PCI’s response to and remedy of this situation. I welcome comments, questions, and commiseration. And to those assessors drinking the PCI Kool-Aid, please don’t clutter the Internet with rebuttals or holier-than-thou rhetoric. There is no PCI DSS 11.5 alignment within the PCI Payment Application Data Security Standard, and until there is, you have no leg to stand on. Period.


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2 Comments | Read PCI’s Not-So-Open Global Forum

  1. Marc Says:

    I agree with your premise that the PCI SSC needs to do a better job of communicating with POs.
    I don’t agree with your QSAs interpretation of PA-DSS requirements. 4.2.7 is not specific to user accounts with user databases. “4.2 Payment application must provide an audit trail to reconstruct the following events: 4.2.7 Creation and deletion of system-level objects within or by the application.”
    The standard interpretation, in my experience, is that the application must provide an audit trail for system events.
    Here are the details on what is supposed to be reported in the ROV:
    Describe how the payment application was tested to confirm the following is logged:
    i. Creation of system level objects within or by the application
    ii. Deletion of system level objects within or by the application

    Describe the audit log settings observed to log:
    i. Creation of system level objects within or by the application
    ii. Deletion of system level objects within or by the application

    Describe how the observed audit logs include:
    i. Creation of system level objects within or by the application
    ii. Deletion of system level objects within or by the application

    I think that your QSA might not have been doing what he/she should have been doing as part of validation and is now back-tracking. Now maybe this doesn’t apply to your application simply because system events or objects (like error messages or directory containers) don’t exist, but that’s different than N/A because there’s no user database.

  2. Stephen Ames, CISA, CISSP Says:

    I received confirmation from the PCI Council’s director of data security standards that my PA-QSA was not exacly spot on with his guidance. Without getting into too much detail, my application in question is compliant with PA-DSS 4.2 out-of-the-box. I’ll be having a conversation with my PA-QSA about this.

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