Now that I’ve had the opportunity to review the full draft standard, it’s clear that there’s very little that’s difficult for you to achieve in the short term if, and I mean IF, you were doing PCI properly from v2.0 onwards. The majority of the changes are simple clarifications, and if your QSA was doing their validation and QA correctly, you would already be doing 99% of them.
That’s really all v3.0 is; a closer approximation to the Report on Compliance (RoC) scoring mechanism that’s been around for years. I understand the clarifications and the guidance are supposed to bring everyone’s understanding of the INTENT of each requirement into closer alignment, but all that does is reflect very badly on the current quality of the QSAs and the available guidance. The corollary is that the QSA and ISA training needs some serious attention, and the DSS needs to focus less on the detail, and more on the senior management buy-in.
I also understand that it is VERY difficult to make dramatic changes to a standard when organisations have already invested significant capital and resources into achieving compliance. But even the SSC made it VERY clear from the beginning that the DSS was a MINIMUM set of controls around a single form of sensitive data, and should not be seen as a security programme that meets the entire business’s needs (per the PCI DSS v3.0: “PCI DSS comprises a minimum set of requirements for protecting cardholder data…“).
So why aren’t the changes in v3.0 more significant? Or more in line with good practices? I don’t really have a constructive (a.k.a. non-soapbox) answer to that, so I’ll focus on what I perceive to be the major flaws.
Here’s my Top 3 Flaws:
Governance: This has as many definitions as there are people defining it, but in the end it’s very simple; Governance is the Business side and the IT side having conversations. Business has the requirements (growth, profit, transformation etc.), IT has the enablement, and the organisation as a whole moves forward appropriately. Nothing should happen in an organisation outside of this framework if the business wants to grow/innovate/adapt effectively (for more see Security Core Concept 4: Governance & Change Control and Security Core Concepts: Tying it All Together)
Guess how many times the word ‘Governance’ (or equivalent) appears in v3.0?
Risk Assessment (RA): The whole business/IT/security life-cycle starts with a risk assessment. The business wants something, the RA determines the balance of risk/reward, and you move on to implementation if the balance is favourable. The DSS calls for a RA, but it’s still woefully understated, and stuck down in the ‘paperwork’ section (Section 12). This should have been performed even before you chose a QSA, should be intrinsic to services you eventually receive from them, and should have driven all purchase(s) of technology used to achieve both compliance and security in general (for more see Security Core Concept 1: Risk Assessment / Business Impact Analysis).
The Risk Assessment even had its own Special Interest Group (SIG) to improve the quality of the guidance, but the results were so watered down as to be ineffectual.
Sampling: MUCH better explanation than previously, but it’s missing the most important phrase; “There is no sampling in PCI DSS validation unless the client can reasonably demonstrate how all ‘like’ systems are configured and maintained identically, managed and monitored centrally, and are promoted into production through a well defined and documented process.”
For too long sampling has been seen as a right, it’s not, it’s a privilege (like spandex). Saying “Sampling is an option…” is not enough to avoid clients demanding ‘pragmatism’ from their QSAs in the ‘this-is-too-difficult’ sense of the word.
I have so much more to say, and some of it is actually positive (like pushing policy enforcement validation), but I’ve already overrun my self-imposed word limit.
Finally, every organisation that relies totally on PCI for their security deserves to be hacked – sorry, but you do – but the SSC and the card brands still have an obligation to do more to evolve the standard into something that can be integrated seamlessly into an established, and comprehensive good-security-practice framework. By the time the DSS catches up with the real world of security, payments will have moved on from payment cards.
Just ask any non-QSA security expert what you should be doing with your IT budget, I’ll bet it’s not PCI compliance.
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