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“Careless” Systems Integrators Now Directly Under PCI DSS
The QIR program will be modeled closely on the current QSA program. That is, there will be QIR companies and individual QIRs, who will be the people installing the application. QIR employees will go through PCI Council training (which is under development) and take a written exam. Approved QIR companies, together with individual qualified installers, will be listed on the PCI Council’s Web site.
The message for merchants is clear: If you use a software reseller or system integrator, make sure the company and the person who shows up on your doorstep to install the application are both on the QIR list. If they are not, you cannot be certain that your PA-DSS validated payment application is properly implemented.
Merchants will determine whether the whole QIR program will succeed or fail. There will be no PCI Council or card-brand mandate (more on this later). Merchants will be encouraged to use QIRs listed on the Council’s Web site, to follow the program guide and, importantly, to read the program guide and maybe look over the shoulder of their implementer.
It will be interesting to observe how this program unfolds and how the market reacts. One wild card is price: Will it cost more to have a QIR implement a payment application? QIRs will have some added costs—I’m sure the PCI Council will charge for QIR training and listing. Will QIRs absorb these costs, or will they pass them along in the form of higher prices?
Could we see a two-tiered market where merchants can have a QIR install their application for one price or have a less qualified, less experienced, less professional person do it for a lower price? If we have a two-tiered market, how will merchants react, particularly small merchants, who may be more price sensitive and less security aware.
Another wild card will be how the software application developers themselves react. Will they insist that their resellers be QIRs? It makes sense that software vendors would take this step to ensure the quality of their product and brand in the marketplace. It also costs the software vendor nothing, because the reseller or integrator will pay the training and listing fees.
Will QSAs and processors accept the QIR’s report of a secure implementation at face value? If a report is challenged, I have to believe the QSA’s opinion would still carry the day. But it certainly would lead to some touchy discussions between the QSA and his or her merchant.
Lastly, although neither the Council nor the card brands will mandate using QIRs (as noted above), will processors insist that merchants prove they used a QIR? Or will the QIR report be required as part of each merchant’s Self-Assessment Questionnaire (SAQ)? The PCI Council is in its feedback period, and I get the impression that the SAQs, too, are fair game for revision and updating to reflect both new programs and current attack vectors. Visa and MasterCard have already mandated PA-DSS-validated applications for those merchants who use packaged payment applications. Will the PCI Council and the card brands similarly mandate QIR implementation where resellers or system integrators are used?
Clearly, there are lots of questions, as is expected with any new program. Nevertheless, none of these questions detracts from the fact that the QIR program is a very positive development for merchants. I understand that the PCI Council consulted with leading software vendors, system resellers and system integrators as it developed the QIR program and guidelines. Hopefully, when the program is implemented it will reflect best practices and reduce data compromises at merchants, franchises and franchisors.
What do you think? Do you use a system reseller or integrator? Would you pay a little more to have a QIR do your installation and provide you with documentation? I’d like to hear your thoughts. Either leave a comment or E-mail me.
-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