Evan Schuman's StorefrontBacktalk

To my knowledge, the cloud guidance was the first document to tell merchants and their QSAs that they need to go beyond checking the service provider’s AOC. The guidance instructs merchants to review “applicable sections” of the report on compliance (ROC), including “the Executive Summary and Scope of Work sections.”

The Cloud SIG provides merchants (and service providers) with a comprehensive responsibility matrix (Appendix C) that details what a merchant needs to know from its cloud service provider. Section 6.1 of the guidance is a virtual “how-to” list for risk management, due diligence and SLA construction.

My question is worth repeating: If this due diligence is needed for cloud service providers, should it not also be needed for all of a merchant’s service providers?

The third, and most recent, recommendation for merchants to know about their service providers is the PCI SSC’s Mobile Payment Security Guidelines for Merchants. You have only to read Appendix C to know merchants are going to need a lot more than a service provider’s AOC to validate their PCI compliance. Yes, the first item on the list essentially tells the merchant to review the vendor’s AOC. The advice then proceeds to instruct merchants to document their mobile vendor’s warranties, logging, training and reporting. None of the latter items is in the AOC.

The unasked issue in all three documents is whether service providers will deliver the information. Smart service providers offer the necessary documentation, and they do it happily. They view evidence of their PCI compliance, security and cooperation with their customers as major selling points that differentiate them from their competitors. These service providers are true partners with their merchant customers.

Merchants whose service providers are not in this group may want to note that one of the two SIGs this year is addressing third-party—i.e., service provider—compliance. No member of that SIG (including me) can discuss any of our deliberations. The important message, though, is that participating organizations around the world saw the need for further guidance and voted for this SIG. Hopefully, the existence of this SIG will be further support for service providers and their merchant customers to work more closely together to create powerful and secure long-term partnerships.

What do you think? I’d like to hear your thoughts. Either leave a comment or E-mail me.