Analogy: A family member needs surgery, and you have two doctors in a side-by-side bake-off. One is respected, enormously experienced, and expensive. The other is fresh out of residency, inexperienced, and cheap.
Whom do you go for?
Unless you’re a sociopath, you pay for the one with the greatest expectation for success. So by a similar (though far less life threatening) extension, why would you cheap out on your choice of QSA? Or any consultant that matter?
Not only that, you probably expect the same results from every QSA, right? They all went through the standard training, so they should all be the same, right?
Are all doctors the same?
Like any profession, you have a MINIMUM standard to achieve before you start. For QSAs it’s 5 years in security (no-one lies on CV’s/resumes, right?), OR a CISA/CISM/CISSP (anyone can read a book and pass a multiple choice test), AND pass the QSA test. I can, quite literally, take ANY person and get them to a point they can pass that test in one week.
Instead of focusing the QSA test on their domain knowledge (networking, encryption, policy formation etc.) it focuses on merchant / service provider levels and a bunch of other stuff that does not test the consultant’s security or auditing skills in any fashion that makes sense to me. Can they read a firewall ruleset to determine if they have met the intent of requirements 1.X? Can they look at a netstat and see if their OS configuration standards are being followed per requirements 2.x?
The answer to those questions is; not necessarily, and while I cannot think of one security consultant who is an expert on all 12 DSS sections (I suck at encryption and anything to do with coding for example), you need someone with real-world experience to measure your compliance against not only the standard, but its intent. And if that intent does not align with the goals of the business in question, the process falls apart.
When it comes to PCI, you’re paying for experience / guidance / been-there-done-that, otherwise you’re better served doing it yourself. At least you know the business better than the QSA ever will.
I wrote something resembling a white paper on Selecting The Right QSA For Your Business a few months ago, and will be building on this process over the next few months. Anything is simple if you know how to do it, but that’s the point; YOU probably don’t know how to do PCI, nor would you then know the right questions to ask to find someone who does.
This may sound like I’m trying to push you into hiring only the expensive guys, but that’s not it, it’s never just about the money, it’s about VALUE for, and appropriate USE of, money. The issue most often is that businesses choose their QSA based on price. They didn’t want to do PCI compliance in the first place (believe me, no-one WANTS to do PCI), and therefore settled for the lowest bidder.
In my fairly significant experience, the cheapest QSA up front rarely ends up being the cheapest in the end. These are the top 5 things to watch out for, and reflect the SOPs of some of the less scrupulous vendors;
- Scope Creep – A proposal written in such a way that you THINK you’re buying what you need, but you end up having to buy additional services from them to finish the job;
- Cheap Labour – You get what you pay for, and if you pay pennies, you’ll get the least experienced QSA at their disposal (this one serves you right by the way);
- Pushing Other Services or Products – Some of the larger QSAs have entire suites of products and services they try and push your way. They will sell the QSA for cheap hoping to massively up-sell/cross-sell the more profitable managed services / products etc. This is permissible under the SSC regs., but hardly best practice, and in some cases even ethical, especially when the products don’t even support your compliance;
- Lack of Appropriate Guidance – Achieving PCI compliance the first time is a project, staying complaint is a process. At no time during the assessment should there be roadblocks that are a direct results of the QSA’s inexperience. Projects that should take months often take years, and the additional costs can be significant;
- The True Cost of Compliance – Usually the most significant cost of a PCI project is the labour cost of internal resources. Performed correctly, PCI can have significant benefits in terms of improved security posture, but unless the resources are used efficiently, the cost to the business can be very significant, especially in terms of availability for initiatives related to transformation or innovation.
In the end, you will get what you pay for, and if you have not chosen your QSA based on best-fit, you deserve what you get. Choosing a QSA / consultant is relatively simple, and I believe that It Takes A Consultant, To Hire A Consultant.
If you need help, do your homework, then ask the opinion of someone with zero vested interest.
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