Ask security professionals what the most painful part of PCI security compliance is and most will start grousing about the auditors.
Some will describe the auditor who came in and started faulting their controls without first taking time to understand the specific business dynamics the controls were designed to address. Others will lament that their auditor required them to buy an expensive new appliance from a specific vendor to attain a passing compliance grade.
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Robert Duran and Allan Kintigh have endured the auditing process, but one man's experience was more unpleasant than the other's. Nevertheless, each has come away from it with a solid security programme.
Duran is information security and privacy officer at Time Inc., the New York-based media giant of 10,000-plus employees. Under PCI DSS, Time is a level 1 company, which means it processes more than six million credit card transactions a year and is subject to an annual on-site audit and quarterly network scans performed by an approved vendor. [Level 2 and 3 companies process 20,000 to 6 million credit card transactions a year and must fill out an annual self-assessment questionnaire and have an approved vendor do quarterly network scans.]
His experience is that the auditors often don't know what they're talking about.
Kintigh is a software engineer with Minnesota-based National Bankcard Services, a payment card transaction processor with fewer than 20 employees. Though tiny compared to Time Inc., the company is still level one because it too processes more than six million credit card transactions a year.
His experience is that the auditors are fair and genuinely helpful.
Don't believe what they say
During a panel discussion on PCI security CSOonline held in New York last month, Duran suggested merchants learn as much as they can about the standard so they'll know when an auditor is sending them in the wrong direction.
"You need to understand PCI yourselves, because the auditors will tell you things that you may not like and probably shouldn't believe," he said. "The more you understand, the more you can challenge them."
Duran's department has to deal with two auditors - one in the U.S. and one in Europe. They often give different answers to the same questions because they are looking at it from different perspectives. He has also come across people who lack the proper understanding of such technical matters as firewall and VLAN configuration.
"Not all [auditors] are the same and not all of their responses will fit your situations," he said. "And so we have to manage them against each other and get what we need from them. They don't always understand the specific security needs of the business."
For example, he said, a department can get into trouble for not having a firewall installed on certain systems, even though the more appropriate course for the business unit may be to segment parts of the network from other areas.
Merchants who take the time to truly understand the mechanics of PCI are therefore in a position to debate the auditor's findings and avoid wasteful technological investments that are sometimes made for the sake of a passing grade.