Companies large enough to process millions of credit card transactions are likely to be subject to other regulations, such as Sarbanes-Oxley, or standards such as ISO and the SAS 70 security audit, as well as state laws that mandate the protection of consumer information. Many companies treat each requirement separately, so that every audit becomes a disruptive event, says the Neohapsis QSA. A more proactive approach is to dovetail as many requirements as possible so that audits are less of an issue.
For instance, regulation X might mandate seven-character passwords, while regulation Y says eight. "Set it to nine and satisfy all those controls," he says. "I haven't seen a lot of effort there. People wait for the auditor to come through and correct you instead of doing it as a unified effort."
4. Your Assessor Isn't The Enemy
It's hard for overworked and underfunded IT and security teams to watch some dude stroll in with a scorecard and tell them where they've failed--and then send a bill. A certain coolness, if not downright animosity, is to be expected.
But your company has an obligation to protect cardholder data, and the assessor can help achieve that goal. Companies should view assessors "not as opponents, but as partners in developing sound security programs," says Fabian J. Olivia, a QSA and global PCI competency leader at IBM.
Some IT teams realize that they can use the findings from an assessment to get funding they've been asking for to implement critical projects, says Branden Williams, a QSA and senior director of consulting at AT&T Consulting's PCI group. If you know a PCI assessment is coming, document areas where your controls are weak, outline a plan to address them, and get that information in front of management immediately. Once the assessment is over, you'll have third-party validation that the issues you've raised are important, and funding may come your way.
5. This Is A Pass/Fail Test
Unlike many regulations that emphasize risk management, PCI is a prescriptive compliance standard. It requires specific controls and processes, and organiz- ations have to meet all the requirements, or they won't pass. "There is no partial compliance," says the Neohapsis QSA. "You either are, or you are not. It's not something the QSA can change for you."
PCI critics say the standard is complex and costly, and that compliant companies can still lose data. We agree. But despite its flaws, PCI is an opportunity for companies to get serious about their obligation to protect cardholder data and implement sensible controls. "PCI compliance should be a by-product of sound security practices and programs," says IBM's Olivia. We also agree.
