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1 Comments
User Rank: Apprentice
5/5/2014 | 11:03:39 AM
Was their policy and supporting proceedures designed that way? If so, did they follow their defined process? If not, then what? Is the standard of due care in following the process as DESIGNED? In tests of operating effectiveness, Target "passed" for PCI, either their auditor did not properly test the controls, ignored residual risk issues, or that they reported on these issues and Target ignored the feedback. PCI does not do a good job forcing assessors to consider residual risk (the way accounting firms have to). Even if they did, then allowing QSACs and P's to opine on residual risk would be a mismatch in skills to activity being expected of the QSAPs.
Going back to design, what if the process and controls are not designed correctly, then who is responsible for determining that and what impact would that finding have? Right now the consumer and AG's are the option for accountability as there is no regulatory function in place to adequately manage this situation when it comes to consumer protection.