PCI’s ISA Program: How Independent Can An Employee Ever Be?

Written by Evan Schuman
October 12th, 2011

In the PCI alleys, there has been some back-and-forth recently about the PCI Council’s Internal Security Assessor (ISA) program and some MasterCard changes about whether participants needed to be auditors. Although the impact of the back-and-forth is relatively trivial, it brings up an interesting question: How independent does an independent assessor really need to be?

The essence of the ISA program is for retailers to have someone on their team who is trained in PCI nuances and who can help the chain maintain compliance between assessments. Most of the retailers that are working with the ISA program plan to continue using their QSA. If ISA works, it would enable much faster and less painful assessments, because someone internal at the merchant is constantly watching for anything that could cause a compliance problem.

To be candid, none of the players involved is independent at all. The internal folk are all on the retailer’s payroll, and the external QSAs are all being paid by the chain to conduct the assessments. What keeps everyone honest—more or less—is the overall infrastructure. Between the banks and the card brands and the QSAs and—for publicly held chains—shareholder attorneys, there’s simply not that much opportunity for anyone in an ISA role to get away with much.

After all, their prime function is to make the assessments go more quickly.

This gets us back to the auditor question. Given the infrastructure surrounding it, an auditor is an excellent choice. But if the auditors are busy with 40 other projects and a mid-level IT security manager is available, why not go for it? It doesn’t make a lot of sense for MasterCard—which originally pushed for an auditor for more independence, but which now seems to have backed off—or the PCI Council to insist on an auditor. If the senior person at the chain wants to use a non-auditor, there’s not much reason to object. If the non-auditor ISA doesn’t end up accelerating the assessments, the boss will have just wasted her own time. But it’s her time to waste.

The practical fact of the matter is that the vast majority of the people who work in the security arena on a retailer’s payroll care very deeply about security and will function well for their chain. The training of an auditor is helpful, but I have to side with the Council on this one. It’s a nice to have, but hardly essential. At least for this specific program.


Comments are closed.


StorefrontBacktalk delivers the latest retail technology news & analysis. Join more than 60,000 retail IT leaders who subscribe to our free weekly email. Sign up today!

Most Recent Comments

Why Did Gonzales Hackers Like European Cards So Much Better?

I am still unclear about the core point here-- why higher value of European cards. Supply and demand, yes, makes sense. But the fact that the cards were chip and pin (EMV) should make them less valuable because that demonstrably reduces the ability to use them fraudulently. Did the author mean that the chip and pin cards could be used in a country where EMV is not implemented--the US--and this mis-match make it easier to us them since the issuing banks may not have as robust anti-fraud controls as non-EMV banks because they assumed EMV would do the fraud prevention for them Read more...
Two possible reasons that I can think of and have seen in the past - 1) Cards issued by European banks when used online cross border don't usually support AVS checks. So, when a European card is used with a billing address that's in the US, an ecom merchant wouldn't necessarily know that the shipping zip code doesn't match the billing code. 2) Also, in offline chip countries the card determines whether or not a transaction is approved, not the issuer. In my experience, European issuers haven't developed the same checks on authorization requests as US issuers. So, these cards might be more valuable because they are more likely to get approved. Read more...
A smart card slot in terminals doesn't mean there is a reader or that the reader is activated. Then, activated reader or not, the U.S. processors don't have apps certified or ready to load into those terminals to accept and process smart card transactions just yet. Don't get your card(t) before the terminal (horse). Read more...
The marketplace does speak. More fraud capacity translates to higher value for the stolen data. Because nearly 100% of all US transactions are authorized online in real time, we have less fraud regardless of whether the card is Magstripe only or chip and PIn. Hence, $10 prices for US cards vs $25 for the European counterparts. Read more...
@David True. The European cards have both an EMV chip AND a mag stripe. Europeans may generally use the chip for their transactions, but the insecure stripe remains vulnerable to skimming, whether it be from a false front on an ATM or a dishonest waiter with a handheld skimmer. If their stripe is skimmed, the track data can still be cloned and used fraudulently in the United States. If European banks only detect fraud from 9-5 GMT, that might explain why American criminals prefer them over American bank issued cards, who have fraud detection in place 24x7. Read more...

Our apologies. Due to legal and security copyright issues, we can't facilitate the printing of Premium Content. If you absolutely need a hard copy, please contact customer service.