Prioritized Approach to PCI Compliance Doesn’t Go Nearly Far Enough

Written by David Taylor
March 4th, 2009

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

After breaches of at least two major card processors, the card brands and the standards committee are on the defensive and have finally bowed (somewhat) to the complaints of the merchant community by introducing a risk-based “Prioritized Approach framework” as a response to the recent data breaches of supposedly PCI compliant companies. Unfortunately, it does not go nearly far enough

The Prioritized Approach is basically a spreadsheet that uses numbers from 1-6 to roughly approximate the sense of risk that would be reduced by implementing each specific PCI requirement. This is the sort of tool that many security and compliance managers have been using for several years to prioritize their PCI projects. However, the spreadsheet is generic for all business types. There’s no sense of customization of “risk weighting” based on the characteristics of a business (i.e., card acceptance channels) or IT infrastructure (i.e., network and data management).

  • Milestones Are Better Than Going 1 to 12
    The best aspect of the Prioritized Approach is that makes it clear that merchants should not begin their PCI compliance efforts with requirement 1 and work their way through to 12, assuming that any organization actually manages PCI that way. The other useful aspect is that the tool provides the ability of merchants to visually show progress. Adding some risk focus shows that the card brands and the SSC are definitely moving in the right direction. But note that there is no guarantee that any acquiring bank or the card brands themselves will actually “honor” the submission of this tool as a show of progress and actually delay the imposition of fines. Remember, the PCI SSC has nothing to do with the enforcement of compliance, which is done by the card brands and acquirers.

  • The Standards Have Not Changed
    In case anyone should read this and think the PCI standards have suddenly become “risk based” because they mentioned risk when they announced the tool, such is not the case. The 1.2 version of the standards is not scheduled to be updated until the fall of 2010.

    Although I agree with the order and manageability that such a schedule provides, it does make it more difficult to adjust such an explicitly detailed standard to emerging threats and technologies that can change the “effective risk” associated with specific controls. Obvious examples that need to be addressed include the impact of tokenization on PCI scope, the impact of server virtualization on data access controls, and the impact of SaaS on data ownership and management.

  • The Bottom Line
    Every organization that collects, processes or stores credit or debit card data still has to comply with all 12 of the PCI DSS. The PCI SSC makes that very clear. The Prioritized Approach does not change the standards. It is a useful tool to help “beginners” understand security risks and help them proceed with the implementation of PCI compliance in a way that addresses the largest risks first. I see this primarily as “first pass” at adding risk awareness, as well as an interesting artifact of the industry’s scramble to address merchant complaints and avoid increased regulation or even “nationalization” of the payment card industry along with the banking industry.

    The PCI Knowledge Base is a research organization, and our views tend to reflect those of the merchants, service providers, processors and assessors with whom we speak on a daily basis. If you’d like to get involved in our Research Community, just visit our website and register or send an E-mail if you’d like to participate in our research, to

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