“Careless” Systems Integrators Now Directly Under PCI DSS
Written by Walter ConwayA 403 Labs QSA, PCI Columnist Walt Conway has worked in payments and technology for more than 30 years, 10 of them with Visa.
Mistakes made by careless or incompetent payment application installers or system integrators have led to far too many data breaches over the years. In each case, even though the reseller or integrator made the mistake, the merchant bore the ultimate responsibility.
Unfortunately, system resellers and integrators formerly fell in a governance gap in PCI, and their actions were outside the PCI Council’s jurisdiction. I say “were,” because that situation is about to change, and merchants are the ones who will benefit the most. Beginning later this year, system resellers and integrators will be held to training and testing standards as high as merchants and service providers. The winners will be merchants, for sure, but those competent system resellers and integrators will also find their high standards rewarded.
The PCI Council is in the process of rolling out a new program to train and approve (certify?) software resellers and system integrators. The Council will list on its Web site those organizations and individual employees who pass the training and meet its standards. The Qualified Integrator and Reseller (QIR) program is designed to improve merchant security, reduce risk and achieve PCI compliance. This program may prove to be one of the most significant developments since the introduction of the Payment Application Data Security Standard (PA-DSS).
As with any program, the burden ultimately rests with merchants to make this work. Merchants, as I have pointed out many times, can outsource the installation and maintenance of their payment applications, but they cannot outsource their responsibility. That fact has not changed: If your system is breached and you lose cardholder data, it is the merchant’s breach regardless of who installed the system. What is changing, however, is that the QIR program will give merchants the information and resources they have needed to have confidence their payment application is securely installed and maintained.
The QIR program will be particularly great news for small and midsize merchants, franchisors and their franchisees. It also will be welcome news for the many software resellers and system integrators who perform quality work for their customers and take security seriously. Although most resellers and integrators are competent, the reality is that some are not. And when a system is installed improperly or insecurely, the merchant pays the price.
The PCI Council is talking about the QIR program in “open mic” sessions for Participating Organizations. It also recently shared program details at a briefing for QSAs. Based on that QSA briefing, here is how we can expect program to work.
The Council will issue a QIR Program Guide by mid-year. This guide will spell out the implementation lifecycle and detail responsibilities for both the merchant and the reseller/integrator. QIR companies will be required to have an internal quality assurance (QA) program that double-checks the work of each individual installer.
After the implementation, the QIR will provide to the merchant a written report documenting that the software was installed securely and according to the software vendor’s PA-DSS Implementation Guide. Merchants will retain that report to show their QSA and/or processor and as evidence of the payment application’s proper implementation.
Approving QIR companies alone would be a positive step, but the PCI Council went further. Each individual employee who installs payment applications needs to be trained and tested to be included in the program. Merchants will be able to check that the particular individual who shows up to implement their payment software, configure their firewall, and configure encryption and key settings knows what he or she is doing. Merchants also will understand their responsibilities for maintaining the application and supporting the implementation.
-Marc
May 3rd, 2012 at 4:08 pm
Walt,
Great article. This exact issue has been bothering me for years, and I was JUST talking about it with someone only yesterday. This may well be my favorite article from you, mostly because I’m biased and have hated this particular problem forever. Keep up the good writing, kind sir, and keep those insights coming.
-KJ Valentine
May 4th, 2012 at 10:35 am
Good article, but how does this have anything to do with the DSS?
May 5th, 2012 at 1:20 am
Thanks for your comments.
Kat: I guess timing is everything!
Nathan: Actually, the QIR program has a lot to do with the DSS (or PCI). Since merchants rely on their reseller or integrator to implement their PA-DSS validated application, these resellers and system integrators play a critical role in merchants achieving and maintaining PCI compliance. As far as I can tell, the QIR program is designed to help merchants stay compliant by making sure their payment applications are installed according to the PA-DSS Implementation Guide, for example ensuring default passwords are changed (and protected), that the data encryption keys are properly set and secured, that the merchant’s data retention policy is set, that no sensitive cardholder data are stored, and often that a firewall is in place and properly configured.
Right now, a good reseller or integrator will make sure the payment application is installed and maintained securely. However if your reseller or integrator does things like install the wrong version, fail to implement security patches, use the same password for all their customers, or retain sensitive cardholder data, then the merchant is vulnerable to a damaging security breach that could potentially put them out of business. BTW, if you don’t believe this can and has happened, see here: http://storefrontbacktalk.com/securityfraud/retailers-suing-card-processor-questions-raised-as-to-where-pci-duties-stop/ or here: http://storefrontbacktalk.com/securityfraud/when-it-comes-to-pci-compliance-
franchisors-are-screwed/ .
As I said in the column, as a QSA I am a big fan of the QIR program. It is not a panacea for merchants, nor is it a silver bullet. But it can be one step to helping small and medium sized businesses (including franchisees) continue to stay in business and operate in a secure manner. And after all, that is really the purpose behind PCI.
Walt
May 9th, 2012 at 8:25 am
Although this is a great move forward in pushing the issue of highly trained people, it is also a good marketing ploy for the council. It begs the question: How much do they stand to make? The problem for this is that for people (like myself) that are just starting out their own business venture, PCI has typically charged a premium for their training and certifications. This change will likely force those of us with less capital to spin into the abyss. I have more than 15 years in the security and compliance fields with heavy hitter certs like CISSP, CRISC, and Sec+.There should not be a guide but a free test or a pre-requisite of either the PCI cert OR other heavy hitter certs. I just don’t want the good guys in small places to get flushed out.
May 11th, 2012 at 1:06 pm
The ETA recently launched the Certified Payment Professional program, which charges $425 for non-members to take the test, assuming they meet the ‘experience’ requirement, to PROVE they are a professional. And they’ll have to take it every 3 years. Worthy program, but high cost. Plus, only a select few were allowed to be in the first class, and there are only 4 test windows per year currently. So being on the registry simply means, you were lucky enough to get picked, nothing to do with skill level. Will this be the same? It’s almost like getting a new tax for each segment in the industry.
I suggest a low cost- say $35- to take an online exam or to get an exemption based on other credentials, and $35 would then cover administrative costs.
One final point- I have strong reservations about the ‘individual’ certification and posting of that information for merchants. Can you imagine the potential employee poaching that might occur? The implications when competitors can look up how many are certified with each of their competitors? This digs into ‘trade secret’ information, don’t you think?
May 13th, 2012 at 7:45 pm
@Cory: Thanks for your comment and question about the pricing of the QIR training. I raised that question in a conversation with Bob Russo last week, and I will address it in a follow-up column in a few days. While the pricing is not yet set, hopefully it will not be too great a burden for you or other integrators/resellers. We’ll have to see, though.
@Christine: That is an interesting point about employee poaching. I wonder, though, if it isn’t any worse that we have today with listing QSA and ASV employees, or even all the other online social/professional media sites. Wouldn’t it be great — especially for retailers — if we ended up launching a race to the TOP instead of the other way around!?!
Again, thanks for the thoughtful comments (and the emails, too, from the rest of you).
Walt