Re: Visa Puts Heartland on Probation Over Breach

["DAIL, WILLARD A" <ADAIL () sunocoinc com>]

I've met some very sharp QSA's, and some who could use a lot of training
or experience.  I'd say pretty much at the same rate as other security
professionals. 

The notion that PCI companies are somehow worse off than the general
business community is, I think, inaccurate.  Security has to be
functional at some point and yes, PCI leaves room for improvement as a
program, but it sure as heck is better than nothing, and nothing is
exactly what most merchants were doing before PCI was forced on them by
the card brands. 

A comparison would be to look at the rate of breaches among PCI-scoped
Acquiring Banks, and non PCI-scoped issuing banks.  The issuing banks
have top security people, operate under GLBA and other tight federal
requirements, and they still get breached.

I've also observed that IT Security is still very much an art, rather
than a science (meaning it is not always repeatable and verifiable given
the same set of circumstances).  As an art, it requires an artist.
Artists do seem to think they have "the correct interpretation" and
their way is the right way.  I've also been amazed at the egos present
in this field, by people who really shouldn't indulge the luxury of
having one.

It's very easy for inexperience IT Security staffers to get caught up in
the technology of the job.  The real truth is that the technology is
merely a set of tools to help observe, and to some degree regulate,
human behaviors.


-----Original Message-----
From: dataloss-bounces () datalossdb org
[mailto:dataloss-bounces () datalossdb org] On Behalf Of Jamie C. Pole
Sent: Friday, March 13, 2009 8:18 AM
To: dataloss () datalossdb org
Subject: Re: [Dataloss] Visa Puts Heartland on Probation Over Breach


Oh wow!  That's going to make a HUGE difference!

Let's not forget that they WERE PCI "compliant" when they got breached.
How is hiring another clueless QSA going to change the basic facts here?

The whole PCI "standard" is a joke.  The PCI Standards Body needs to go
the way of the dodo, and the whole QSA concept needs to be eliminated.
The only way there will ever be any reasonable level of assurance that
credit card transactions are safe is for a body made up of COMPETENT
security professionals to come together to define meaningful controls
that will actually make a difference.  And the whole "pay to play" QSA
game needs to be replaced with a process whereby COMPETENT security
professionals are able to demonstrate proficiency by actions, NOT by
virtue of the fact that their application fee check cleared.

Actually, I wonder if they take credit cards for the QSA fees?  :-^  
Maybe the QSA criteria should be "show us that you have breached a
payment processor, and we'll let you test other payment processors..."
If that happened, the list of approved QSA providers would be VERY small
- and I'd bet that VERY few, if any of the people on the current list
would be on the new list.

This same thing is going to keep occurring over and over and over until
the PCI program itself is overhauled.  With the current "controls" in
the PCI DSS, I'm not sure how any of these people sleep at night.
Especially when you consider that the QSA providers seem to all be
relying on automated scanning tools when they do their assessments.  Two
words come to mind - unlimited liability.

I love the part about "more stringent conditions"...  What?  They have
to run Nessus or Qualys ONCE a month instead of quarterly?  That's
definitely going to make a difference!  Twice nothing is still nothing.
I suck at math, but even I can work that one out.  (By the way, no
offense meant to Nessus - it's a great product that I use myself - I
just don't believe in basing C&A decisions on automated
tools.)

Gotta love this world we live in - the PCI people have mortgaged the
future of their industry in order to sell QSA "subscriptions"...

Jamie


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