Tags ArchivesSeven Deadly Sins of a QSA

Sin #3 – Drunk with Power QSAs are often in a position of perceived power.  They sometimes exhibit authoritarian behavior, often times enabled by the very people they are assessing. QSAs are just people. You are hiring them to evaluate your performance against a detailed set of requirements. They are not peace officers, and they are most definitely not auditors ((Although some may be CPAs.)). Smart companies will use this knowledge to their advantage and work the psychology of the situation. The Psychology of the Situation The QSA is acting in a position of authority based on his role in the assessment process, passing the QSA training class, and his education and experience. Individuals inside companies being assessed rarely know or ...

The Role of the Acquirer Ultimately it is the Acquiring institution that must approve the compensating control. If you are like most companies, you most likely are dealing with more than one Acquiring institution, so remember, any control you propose should be approved by ALL of them before proceeding. Imagine the difficulty of getting your Visa/MasterCard acquirer to agree with American Express, and then Discover! It’s hard enough to get one institution to agree, but three? Consider this before you bet the farm on a flimsy compensating control that doesn’t solve the underlying problem. How to Avoid Compensating Control Chaos There is really only one way to avoid getting into a tug-of-war on compensating controls—don’t use them. Unfortunately, for most ...

The Liberal Assessee If you are tasked with helping a company comply with PCI DSS without all the resources you need to do the job appropriately, you may end up taking a more liberal interpretation of the standard as a shortcut to compliance. Let me be frank: the only shortcut to compliance is to completely outsource your payment processing environment to someone else. It will cost you more money to process transactions which might be what you should spend on PCI Compliance anyway ((For more hot sports opinions on how we ended up in this situation, read this blog post.)). Assessees become stage actors at this point in the conversation. I’ve seen some fairly silly controls argued with Oscar worthy ...

Sin #2 – Compensating Control Chaos Compensating controls are a challenging and somewhat confusing nuance to PCI DSS. In Chapter 12 of PCI Compliance: Understand and Implement Effective PCI Compliance I delve into this perceived “Get out of jail free” card. Many companies have found this a useful guide for creating compensating controls during their PCI DSS journey ((This chapter is freely available at our book’s website,http://www.pcicompliancebook.info/.)). Compensating controls are designed to allow companies to meet the controls laid out in PCI DSS in alternate ways. For example, a company that cannot put Secure SHell (SSH) on all of their routers and switches due to technical constraints may be able to do something different that would meet requirements for a ...

How to Avoid a Made Up Requirement The only way to avoid a made up requirement is to ensure that there is material in the PCI DSS that supports a recommendation before a it’s made. There are two main areas where you can find information on how to handle strange situations—PCI DSS itself as well as the FAQ that can be found on the PCI Security Standards Council’s website. The “Navigating PCI DSS” series is also useful, but supplementary and cannot be assessed against. Any guidance taken from documents other than the PCI DSS should be written up as a compensating control where appropriate. Additional documentation such as Special Interest Group (SIG) whitepapers, do not indicate changes in the standard ...

Mis-hearing the Trainer QSAs must be pass evaluation from the Council every year in addition to earning at least forty CPEs in order to maintain their QSA designation. Prior to 2010, this meant finding a QSA Requal class near you and having your primary contact book your attendance in said class ((You can now do your requalification online.)). Trainers come and go as we have seen over the years, and I sat through a session with a good number of my team lead by a new trainer a few years ago. One of the most important steps a QSA must get right is choosing the correct scope for the assessment. Getting that step wrong sets the whole assessment and the PCI ...

Those of you that attended HoustonSecCon or #BSidesDFW, you saw my presentation entitled “The Mistakes QSAs Make.” After presenting, I thought the overall message needed to get to a wider audience and not just the slides I present. I set upon this endeavor and came up with the following series entitled, the Seven Deadly Sins of a QSA. I’m going to be posting this over the next couple of months (and a single PDF in its entirety when I finish) for you guys out in the tubes. Here is a brief intro to get things going! People make mistakes—and in a people business like consulting, you can expect to see more than a few of them. This series explores seven ...