Delegation Can Be Good, And A Half-Dozen Other Security Tips

Written by Evan Schuman
May 15th, 2008

Guest Columnist David Taylor is Research Director of the PCI Alliance, Founder of the PCI Knowledge Base, and a former E-Commerce and Security analyst with Gartner.

In the world of security, delegation can be good.

Some of the retailers with the best strategies have figured out how to "deputize" internal audit, HR, data owners and store managers and give them specific things to do, from employee education to access monitoring to policy enforcement. These leaders also tend to be more successful at getting business units and other departments to share the cost of PCI compliance with IT.

Over the last several months we’ve conducted more than 100 hours of anonymous interviews with retailers, hotels, banks, card processors, PCI assessors, service providers and security technologists. We are about to issue the first report based on those interviews, called the PCI Leadership Report.

Beyond the delegation discovery was the realization that data security can go well beyond payment. One of the best examples of going beyond PCI is the organization that applies the PCI security controls to social security numbers, account numbers, and other confidential data. The key is defining and enforcing a "data classification" scheme. (We addressed this in an earlier column and still recommend a near-term focus on adding SSN protection to credit-card data protection.)

The key point of the new report is to provide an in-depth examination of what leading merchants are doing to go beyond the "minimalist" approach to the PCI "checklist" and to prepare their enterprises to protect all types of confidential data against any type of security breach. What follows are some of the "highlights" of the report, without all the statistics and quotations that would, frankly, take up too much space. If you want the whole "shootin’ match," just register at the PCI Knowledge Base. I sense you’re getting excited already!

  • Use Control Data To Predict Breaches. Many merchants rushed to get PCI compliant quickly, implementing controls as needed. Leaders focused more on Security Information and Event Management (SIEM)—using control data to predict or stop problems before they became serious.
  • Monitor The Environment. Security and compliance must be monitored continuously. A good approach means implementing automated log monitoring and alerting tools to sort through the vast reams of log data. Other merchants lack the time or staff to review the logs.
  • Track Individual Actions. It’s critical to use Identity and Access Management and Data Loss Prevention tools to automate the provisioning of access and to monitor privileged user access, as well as role-based access, to confidential data so that when roles change permissions do too. The actual types of tools implemented vary widely, as do the costs.
  • Use Risk Management Tools. Because PCI requires a 100-percent score to pass, only leading firms have gone beyond this to manage their security based on a thorough risk analysis. Beyond a basic "stoplight" rating spreadsheet, a risk analysis requires that companies take specific actions to address identified risks, based on priority.
  • Monitor Service Providers and Partners. PCI only requires a letter of agreement stating that a service provider will adhere to PCI. Leading firms are doing real due diligence with their service providers and partners. Some are sending out questionnaires; others are sending auditors to review the security of their service providers.
  • Use Fewer Compensating Controls. Very few enterprises require no compensating controls (CCs) to achieve PCI compliance. But leaders typically have five or fewer CCs, while the typical enterprise requires 10 or so CCs. Areas where the compensating controls are applied could be the subject of a whole series of columns or a whole separate report from the PCI Knowledge Base.

    I’ll end with a question, just to see if you read this far: We’re trying to decide if our next report should focus on: (1) an in-depth examination of how compensating controls are created and where they are used; (2) a study of merchant readiness to comply with PCI DSS 6.6, which comes due the end of June; or (3) a review of the various technologies, vendors and products, and the positive or negative recommendations of the interviewees. If you have an opinion, please send me an E-mail at or visit and click "Register" to join the PCI Knowledge Base.

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