The PCI Lessons From Google’s Employee Data Breach

Written by Walter Conway
September 23rd, 2010

A 403 Labs QSA, PCI Columnist Walt Conway has worked in payments and technology for more than 30 years, 10 of them with Visa.

When Google this month fired a programmer for using the search giant’s database to investigate an intriguing teenager, it showed that even the most sophisticated and respected technology brands can have a trusted employee go rogue. This lesson should not be lost on retail executives, who may rely on several third-party service providers to process or analyze their payments.

In Google’s case, the employee reportedly abused his privileges to access confidential user information. In a payments context, a similarly trusted employee at one of your service providers could have access to your payment card transactions and maybe even your systems. But could PCI prevent a data compromise?

The answer is probably not. But the more important question is: If a malicious employee at a service provider stole your payment data, would the fact that you are PCI compliant reduce your exposure? That answer is a more encouraging yes, quite possibly—especially if you thoughtfully complied with Requirement 12.8.2.

That requirement is the PCI Council’s way of telling retailers “we have your back.” Requirement 12.8.2 says that service providers should be responsible for your data.

Every retailer has at least one, and likely several, payment service providers. These third parties may provide payment processing, Web hosting, datacenter management, payment application support, customer service, a call center and even encryption or tokenization.

Requirement 12.8 addresses how you manage your service providers. Subsection12.8.2, in particular, says that a retailer will “maintain a written agreement that includes an acknowledgement that the service providers are responsible for the security of cardholder data the service providers possess.”

The test for whether your third-party contracts meet this requirement: An explicit provision in your written agreement that is an “acknowledgement by the service providers of their responsibility for securing cardholder data.”

I am a QSA, not a lawyer. It seems to me, though, that if a retailer working with its counsel develops an agreement that says each service provider is responsible for the data entrusted to it, then—should a Google-like episode occur—the service provider, not the retailer, will be on the hook.

For example, let’s say a service provider employee with broad access to a retailer’s payment data goes rogue and steals a few hundred thousand payment card numbers together with other information.


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