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The Missing Piece In PCI: System Resellers
Good software vendors and their resellers/integrators take their responsibilities seriously, and they do their work well. But retailers need to do their part, too. For a start, get a copy of the IG from your reseller (or the software vendor), and then read it. If the IG is well prepared, any retailer should understand the instructions and see the risks of noncompliance. Work with your reseller/integrator, and have them demonstrate to you how they accomplish each step of the implementation.
If the individual installer is not familiar with the IG or its requirements, you, the retailer, could be at risk. Contact someone in authority at the reseller/integrator and demand a competent installer. Clients of mine have had bad experiences. There is no excuse for any retailer to have such an experience, and good resellers/integrators will remedy the situation immediately.
Are resellers/integrators themselves subject to PCI DSS compliance? From one perspective, they might be, because although they do not store, process or transmit cardholder data, by their actions they certainly can impact the security of each transaction. For example, if the payment application uses wireless (a common situation), the reseller/integrator must follow both PA-DSS 6.1—requiring changing the default password—and PCI DSS 2.1.—requiring a firewall. Another example is that no cardholder data should be stored on any Internet-accessible system (PA-DSS 9.1). In both cases, the reseller/integrator clearly can affect the security of the card data and may be considered a PCI service provider.
The difficulty is that most resellers/integrators do not consider themselves to be service providers. Retailers will not find too many of them on the Visa and MasterCard lists of PCI-compliant Level 1 service providers.
What this means is that it all comes back to the retailer. Retailers have to continue to take direct responsibility that their resellers and integrators accomplish their work in a PCI-compliant fashion. There is no way around it if the retailer is going to host a payment application.
What do you think? What is your experience with resellers and integrators? What has been their reaction when you asked if they were PCI compliant? I’d like to hear your thoughts. Either leave a comment or E-mail me at wconway@403labs.com.
-Marc
March 2nd, 2012 at 1:37 pm
As a follow-up to the column, I learned that Visa has a Best Practices document for resellers and integrators on their website. Retailers (and anyone) can go here and take a look at what Visa is telling resellers and integrators to do when they work on a merchant site: http://usa.visa.com/merchants/risk_management/cisp_alerts.html.
It looks like a very good list, and thanks to the SFBT reader who brought this to my attention. Merchants can use the best practices, too, to make sure they get all they are paying for.