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PCI Is Just the Beginning…

August 13, 2009

It’s not surprising that many of the folks I talk to continue to focus on PCI-DSS. They handle credit card data, so they have to. What is surprising is the amount of institutional apathy to going beyond the guidance of the regulation, and this doesn’t just apply to PCI, but also to all the other regulations and frameworks. Most of these organizations continue to look for a band-aid. They want to be “compliant” and be done with it. They come up to our stand at a show or call on the phone and want to know how they can make their assessor happy and get back to their business.

Even worse, you have some organizations that won’t accept responsibility when something does go wrong. I won’t rehash the discussion here, but Heartland’s CEO Bob Carr stepped on the security industries toes in this interview with CSO by trying to throw his QSA under the bus. That didn’t really sit well with me, so I posted a response (BTW the response is my opinion and my not reflect the views of eIQ – how’s that for a disclaimer?)

Regardless of whether someone is looking to check the box or make the auditor go away, they are delusional. You see, PCI is only the beginning of the process. Hats off to the PCI Security Standards Council that have proscribed a set of practices that will improve security. Any organization in compliance with PCI is in decent shape, but they are far from done.

Let me make sure I’m absolutely clear, COMPLIANCE DOES NOT EQUAL SECURITY. If you have any misconceptions that it does, get up to the white board and write it about a zillion times. Compliance is a lowest common denominator, by definition. A rubber stamp is not going to keep you secure.

The regulations are also moving targets, which is a good thing. As new attacks emerge, they will keep moving the bar for PCI compliance. The updated version (1.2) hit last October, and subsequently there was additional guidance on securing applications and wireless in-store networks. Yet the fact remains, PCI is looking backwards and responding to the issues, but about 2-3 years behind.

For example, PCI 1.2 specifies that retailers can no longer use WEP to protect wireless networks. A few retailers learned that lesson the hard way. But the industry has known WEP has been broken for years.

Let me repeat this again, if you are serious about security, any regulation should be a lowest common denominator to base your security program on. That being said, we all need to spend a lot of time documenting what we do and preparing reports for the auditors. This is tremendously resource intensive and something that can and should be automated.

But that’s another topic for another day. Let’s stay focused on the reality that the technical controls to meet a compliance mandate is a subset of what you need to do to actually protect your organization.

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