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Is PCI Lovelier The Second Breach Around?
You will have to ask these questions directly to the processor or merchant. If you get good answers and the merchant’s or card processor’s current ROC is compliant, then I’d say you can have confidence in that entity. I would not hold a previous data breach against it, and I might even agree that it could be safer given its experience. Just be sure to verify the situation and not believe something just because you want to believe it.
I would be remiss if I didn’t address this issue as it relates to QSAs, too. The PCI Council maintains strict standards for QSAs, and it has a program “that ensures their consistence, credibility, competency and ethics.” To this end, the Council conducts quality assurance (QA) reviews of all QSA firms on a rotating basis.
Any QSA firm can enter remediation and “go red” (its name is printed in red on the Council’s Web site) when there is a need for improvement in one or more areas of its operations. The reason can be a lack of documentation in a series of reports, failure of the QSA’s own internal QA program or a lapse in insurance coverage, among other reasons. As the Council points out, however, being in remediation does not nullify the QSA firm’s knowledge or ability to perform assessments. Nevertheless, any QSA in remediation is going to work closely with the PCI Council to return to good standing.
So it seems only fair to ask whether a merchant or processor can feel comfortable hiring a QSA that is in or has emerged from remediation.
In response to this exact question at the recent Community Meeting in Orlando, a PCI Council staffer observed that hiring a QSA firm that had been “red” but is now out of remediation could be a particularly good idea. The reasoning was that that QSA was now confirmed by the PCI Council to be observing the highest standards.
We all like to think that we benefit from both good and bad experiences. In the case of PCI, merchants and processors have an opportunity to ask questions and determine whether a situation has changed for the better. And the merchant or processor may indeed be stronger and more secure after experiencing a data breach. Therefore, a “trust, but verify” approach seems to be a sensible approach.
What do you think? I’d like to hear your thoughts. Either leave a comment or E-mail me at wconway@403labs.com.
-Marc
January 14th, 2011 at 5:56 pm
I agree with the argument that a company that has suffered through a breach and survived is stronger and less likely to be in the breach headlines again. But I don’t attribute it to PCI; I attribute it to a self survival instinct for the company as a whole, or the individuals in charge of preventing future breaches for that company. As the saying goes: “What doesn’t kill us makes us stronger.”