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The Forbidden Question: Are You Still Using A QSA?
Speaking of risk management, the “high end” QSA companies (in terms of technical skills, industry expertise and global reach) will wind up taking on a more strategic role beginning next year, because I expect the outdated PCI assessment grading system will incorporate more “risk awareness,” as part of the PCI 2.0 version coming in the fall of 2010. (You might want to check out some of the comments from that grading system column.)
This will force merchants to improve their management and quantification of IT security risks. Some of the leading QSAs are quite expert when it comes to risk management and have been among the most vocal in criticizing the PCI grading system (at least in our anonymous interviews) for its lack of incorporation of risk.
Essentially, I’m suggesting a “forking” of the QSA industry, with some of the best companies adding more risk management, security strategy consulting, and “Beyond PCI” technology focus to their practices. For example: Assessing the effectiveness of tokenization, or end-to-end encryption, or secure cloud computing will require skills far beyond the checklist mentality, and really help differentiate the “cream” of the QSA companies.
But what about the QSA business overall? Is it doomed by the trend toward merchant self-assessment? Hardly. The lion’s share of the QSA business has been focused on getting service providers to be PCI compliant. The use of QSAs for larger service providers is still required.
Indeed, the QSA business will continue to grow as PA-DSS and PCI PED “white lists” of vendors, products and versions continues to grow. As these white lists become more complete representations of payment-related application market sectors, merchants will increasingly insist that their service providers and software vendors be “on the list,” even when the specific product or service isn’t a direct part of the payment flow.
This can already be seen in the diversity of the companies and products included in the PA-DSS white list. We haven’t reached the point where not being on the list can spell financial disaster for enterprise application vendors, but I’ve talked to several vendors who have lost business due to merchants insisting that their products be on the PA-DSS white list.
For those so inclined, there are ways to “get around” this, by using the customization provisions in the PA-DSS standard to argue that a packaged application is a really a “bespoke” application as it is used by a particular merchant. But the point of all this is that there are plenty of opportunities for QSAs, even as demand in the merchant community erodes.
QSAs provide some merchants (especially senior management) with a level of comfort about their data security, and some Internal Audit departments simply don’t want to own the task of PCI assessment, but I do expect the issues described here to drive the trend toward self-assessment. If you’d like to discuss this, please visit the PCI Knowledge Base and comment in our discussion forums, which are monitored by dozens of the best QSAs in the business – all of which have been referred to us by their merchant customers. Also, if you want to have a personal discussion about this, just send me an E-mail at David.Taylor@KnowPCI.com.
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
