Why PCI DSS Compliance Is Not Like The Flu

Written by Walter Conway
February 20th, 2013

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

PCI DSS compliance is not like the flu. You can’t “catch” it from your service provider, even though that provider might be PCI compliant. Merchants must go beyond reading the marketing materials and taking a quick glance at the service provider’s attestation of compliance (AOC). The path to PCI

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compliance starts with PCI-compliant service providers, but it then takes the extra step of performing effective due diligence.

This lesson has been reinforced at least three times in the past few weeks in separate PCI Security Standards Council (PCI SSC) guidance documents. One question is whether merchants—particularly small and midsize merchants—will ever hear this advice. We all will have to leave the answer to that question to the industry associations. They have a key role to play in educating and protecting their members on all things PCI-related, including dealing with their service providers. The other, and possibly more relevant, question is whether all service providers will listen and be forthcoming with the information. If not, then all the guidance documents in the world will not be worth the electrons used to deliver them.

As a QSA, I occasionally get the impression that clients might not spend more time researching their next smartphone, laptop or sailboat than they do reviewing their service provider contracts and service-level agreements (SLA). It is particularly important for merchants to realize the source of the advice. It comes not from the PCI SSC staff but from active PCI practitioners with first-hand experience.

Section 5.4 of the PCI DSS E-Commerce Guidelines released in January lists a set of best practices for assessing the security of E-Commerce service providers. The special interest group (SIG) that prepared that document counsels merchants to develop a detailed SLA that specifies not only the responsibilities of the merchant and service provider, but also how each party will meet its obligations.

I was member of that SIG. Although I won’t discuss our deliberations (all SIG members are governed by a non-disclosure agreement), it is pretty clear that meeting this due diligence standard means going beyond looking at the service provider’s AOC. In some cases, service providers readily deliver this information when requested. Where they don’t, however, it is up to the merchant to get it.

If this advice is good for E-Commerce merchants, should it not be equally good for all merchants? That is, there is nothing particularly unique or risky about E-Commerce service providers. Merchants should heed the E-Commerce Guidelines even if they never have a Web-based transaction.

The recently released PCI DSS Cloud Computing Guidelines crisply summarizes the situation when it states: “Use of a PCI DSS compliant [cloud service provider] does not result in PCI DSS compliance for the clients.” Truer words were never written. The problem is that the SIG members—PCI professionals, all—felt it necessary to say them.


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