The Forbidden Question: Are You Still Using A QSA?
Written by David TaylorGuestView 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.
The other day at a security conference on retail and PCI security issues, I was in a group of retailers and saw one retailer ask the other a deliciously revealing question: “Are you still using a QSA?” The entire question is nice, but it’s the emphasis on the word “still” that makes it art. That’s the killer word, as it was designed to make this other retailer feel small about still using a qualfiied security assessor.
About a week earlier, at a different conference hundreds of miles away, I witnessed a similar exchange, with a group of about eight retailers and only one said he was using a QSA. And that guy was clearly on the defensive, half-blaming his management for forcing him to still use one.
Merchants with “mature” data security strategies and a technically skilled Internal Audit team don’t need to use Qualified Security Assessors (QSAs) to evaluate and sign off on their PCI compliance efforts. This sort of PCI one-upmanship is a perfect way to launch our analysis of the evolving relationship between merchants, service providers and PCI assessors.
From the beginning, the QSA relationship with merchants has been complex. Although some QSA companies pitched themselves as auditors, others pitched partnership. But regardless of the pitch by the QSA company, the vast majority of merchants have been hiring QSAs to do their PCI assessments because they were forced to by the card brands and strongly encouraged to do so by their merchant bank or processor.
As a result, once the use of QSAs for Level 1 (the largest) merchants stopped being mandatory, we are finding more and more large merchants no longer use QSAs, or use them strictly in an advisory capacity, then do their assessment themselves. This has resulted in some erosion of the QSA business, with the attending layoffs among the less well-established assessment companies.
I would argue that part of this was a result of the poor definition of the QSA role in the first place, such that QSAs have been allowed to do a gap analysis to identify security gaps, then sell merchants the technology or services to fill the gaps, then sign off on the result as being compliant. Our research database is rife with complaints by merchants about QSAs who engage in such practices. It’s no wonder that larger merchants are running away from certain QSAs as fast as they can.
When I began specializing in PCI consulting in 2005, it was very rare to find an Internal Audit department that had sufficient IT talent to do a PCI self-assessment. Even when organizations have dedicated IT auditors, very few had any training on the complexity of doing PCI assessments or how to develop and/or evaluate the necessary documentation. Now, that situation has changed. Our research shows that nearly three fourths of the larger merchants we interview have “geeked up” their internal audit groups and are conducting (or preparing to conduct) their own PCI assessments.
In fact, I have found that the internal auditors I speak with have been the ones who are most critical of the QSA companies’ “partnership” approach and some have actively pitched their departments to take over the PCI assessment role, in order to bring greater objectivity as well as company-specific knowledge to the PCI assessment process. The implication is that a PCI assessment by the Internal Audit department may be tougher than using a QSA, but it’s less likely to result in a mandate to purchase security products and services that do not match the risk management profile of the merchant.
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.
-Marc
