A Look at PCI in 2010

Written by Walter Conway
January 6th, 2010

A 403 Labs QSA, PCI Columnist Walt Conway has worked in payments and technology for more than 30 years, 10 of them with Visa.

What are the PCI stories we are likely to see in the coming year? We know there is a new/revised version of PCI due to become effective in October, but what are the likely changes?

And let’s not forget the card brands themselves or the technology vendors who constantly promise to make merchants’ lives easier (if maybe a little more expensive). With a new year in front of us (and caution behind), here are some forecasts and speculation for the coming year in PCI.

May 1st will see the updated release of PCI labeled “version 2.0.” My reading of the tealeaves is that the Council will take the opportunity to declare the revised standard a whole new version rather than simply an upgrade from the current version 1.2. It may all be appearances, but calling it a new version communicates the evolution of the standard.

Some will criticize the move contending PCI is a shifting, unstable standard, but I don’t think too many people buy that argument. PCI needs to evolve to reflect the latest attack vectors and technology, and tagging the latest release as a new version communicates that dynamism. And yes, it’s good PR for the Council, too.

Version 2.0 could mandate automated cardholder data discovery. One change I anticipate is mandating the use of automated cardholder data discovery tools. I say that for a couple of reasons. First, the Council has been encouraging QSAs to use data discovery tools in our assessments. They even provide a list of both open source and commercial products at QSA training sessions complete with examples of how to configure them.

Then at September’s PCI Community Meeting the Council gave Verizon a prime slot to pitch their data breach investigations report. That report highlighted that in 38 percent of breaches—representing fully 67 percent of compromised records–the breached entity had no idea it was storing the cardholder data. You can’t protect what you don’t know you have, and the only way to be sure you know where all your data are is to conduct an automated search.Therefore, I am looking for the Council to require automated data discovery starting in October.

Why is this important for merchants? If you have a lot of locations, you have work to do setting up and scanning all those databases, workstations and servers. Especially watch to see if the Council decides to implement data discovery like it did wireless scanning (Requirement 11.1).

If this happens, merchants will not be able to sample locations and will have to search each one. The good news is that you can conduct these searches internally and there are good open source products available. Your QSA likely would only need to verify the results of your automated discovery and to review the scope of your search.

Council PCI training will be oversubscribed. Both Level 1and Level 2 (thank you, MasterCard) merchants have an incentive to send staff to the Council’s PCI training. The training runs about $1,000 per person for the two-and-a-half day session, but it can be a bargain if you can leverage it to reduce the effort in your annual assessment.

As a QSA, I love it when my client knows a lot about PCI since it makes the assessment go much smoother. Another advantage for merchants is that you are less likely to fall afoul of knuckleheaded mistakes like missing a quarterly scan when you have somebody on staff who knows and understands the requirements.

I have two words of advice to those who take the training: pay attention. The training is good if a bit tedious at times, but there is a test at the end to get the credential (details are still being decided). You won’t want to explain to your boss how you blew the test (and the budget). The training will continue to be across regions, so check the Council’s website for the dates and locations. Sign up early, as space will be limited.


5 Comments | Read A Look at PCI in 2010

  1. Dave CISA/M/SP Says:

    Is anyone seeing movement towards revoking the “free pass” for transferring data unencrypted over private networks? In both Heartland and Hannaford data was being sniffed “on-the-fly”. Will the continuing trend towards malware-based data collection attacks drive the council to consider requiring the encryption of data “in flight”?

  2. Janice Gaines Says:

    Anyone else here reading “I.T. WARS”? I had to read parts of this book as part of my employee orientation at a new job. The book talks about a whole new culture as being necessary – an eCulture – for a true understanding of security, being that most identity/data breaches are due to simple human errors. It has a great chapter on security. Just Google “IT WARS” – check out a couple links down and read the interview with the author David Scott. (Full title is “I.T. WARS: Managing the Business-Technology Weave in the New Millennium”).

  3. Walt Conway Says:

    The focus of DSS is data at rest, but as you observe, data in transit can be vulnerable. Like you, I would not be surprised to see some move by the Council addressing unencrypted data over private/internal networks. I just don’t know when. I can think of two arguments for sooner rather than later. First, they update the DSS to reflect current attack vectors, which as you point out applies here. Second, the Council is looking at “emerging technologies,” a couple of which can in theory address this issue.

    Will PCI DSS reflect this as a new requirement? I’d say it will someday. The uncertainty is when that day will be. Merchants and processors truly interested in security will address this issue without waiting for the Council to mandate it.

  4. Don Giddens Says:

    Interesting article. I’m curious. What happens to the PA-DSS validation status of a payment application once the Security Council implements a new standards version? Does it have to be re-validated under the new standard in order to remain compliant? It was my understanding that an application would remain compliant and acceptable for new deployments until it hits the re-validation date listed on the Security Councils web-site for that application even if a new standard was issued. Once that date is reached, it would then have to be re-validated under the current standard. Is this a correct interpretation?

  5. Walt Conway Says:

    Thanks for your comment and question. My understanding is the same as yours. That is, you would revalidate your app against the new/revised PA-DSS when you next assessed, whether that is at the current expiry date, or when you either introduce a new version or make a significant change to the app. Don’t forget those last two events, either which triggers a revalidation.


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