In this, my first installment of the PCI DSS ‘Going Beyond the Standard Series‘, I will begin where not only every PCI assessment should start, but where the development of every security program should start; the Risk Assessment.
Just because you take branded cards, or in any way transmit process or store cardholder data, does NOT mean you should drop what you are doing and dedicate an enormous chunk of your IT capital or manpower resources into achieving compliance. Unless a) there is a distinct business benefit for doing so, and/or b) you are actually increasing the security posture of your entire business.
PCI is not about compliance, it’s about not losing cardholder data.
Compliance with the PCI DSS does not equal security, and security out of context has no business benefit. Either start your PCI program with an eye to staying in business responsibly or don’t bother.
Also, there is a very good chance that taking card payments is not core to your business. If you’re a retailer, your core business function is to sell things, taking payment is just a means to that end. Payment acceptance channels in your business should therefore be simple, inexpensive, and secure. If you can do this well yourself, great, if not, why take the risk? And can you truly innovate away from credit cards if you have to do all the work yourselves?
Should you decide that your existing payment channels are fit for purpose, the second question to ask that is how much should you be spending to fix / mitigate / transfer / remove any problems. i.e. a Business Impact Analysis. You would not spend £100,000 to protect £1,000 worth of data, but you likely would the other way around. Do you know what that balance is for your organisation? From my experience, the answer is generally no, and countless hours and capital are/is lost chasing a goal that was never properly defined.
That said, in terms of PCI, if you were doing security properly, you would already BE PCI compliant (mostly anyway), so it makes sense to just focus on security first and achieve compliance in your own time. As long as you have a reasonable project plan to show your acquirer, report your progress on time, and actually work towards your plan, you will pretty much get as much time as you need to get there. It’s the organisations that couldn’t care less, or are egregiously lax in protecting cardholder data that get the negative attention, and possibly the fines.
Sadly, along with Policies, Standards & Procedures, the Risk Assessment is often one of the last requirements to close during a PCI assessment, when, if they were in place at the beginning, the cost AND level of effort to sustain compliance would have been cut in half.
However, the issue is that most organisations do not have internal resources qualified to perform, or dedicated to, this task. It’s far too specialised, and has never been seen as a true value-add to the business. And unfortunately, the resources available to you in the QSA consulting arena are on the whole inadequate to the task of doing anything other than a PCI ‘audit’. So unless you know security, you would probably not even know the right questions to ask.
I probably should have made choosing the right QSA / consultant for your business the first of this series, but I have basically covered that in previous articles / white papers;
- How to Sell Security: While designed primarily to help salespeople in the information security arena, it doubles as a paper for anyone looking to BUY security services;
- Selecting The Right QSA For Your Business: This could just as easily be called ‘Questions For Your QSA Request For Proposal (RFP)’ as getting the help of a real security consultant and not ‘just a QSA‘ is critical;
- It Takes a Consultant to Hire a Consultant: One of the most difficult aspects of choosing the right help for your organisation, which begins with asking the right questions.
Bottom line; If you haven’t performed a Risk Assessment, go back and do it, and if you cannot do this yourself, find someone who can.
If you don’t know the right questions to ask, ask someone who does.
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