PCI-DSS under the gun

Have you been wondering how some of the statements coming from the credit card processing industry seem a little contradictory? You hear about PCI compliant entities being hacked but the PCI guys are still claiming they have never had a compliant merchant successfully breached. Perhaps not, but if both statements are true, you certainly have an ineffective real world standard or problematic certification process at the very least.

Not to pick on Heartland again but Heartland passed their PCI mandated audit and were deemed compliant by a certified PCI Auditor approximately one month prior to the now infamous hack. Yet, at Visa’s Global Security Summit in Washington in March, Visa officials were adamant in pointing out that no PCI compliant organization has been breached.

Now, granted, Heartland was removed from their list of certified vendors after the breach although perhaps this was just a bizarre Catch 22 in play – you are compliant until you are hacked, but when you are hacked the success of the hack makes you non-compliant.

Logically it seems 4 things or a combination of the 4 could potentially have occurred at Heartland. 1) The audit could have been inadequate or the results incorrect leading to a faulty certification. 2) Heartland in the intervening month made a material change in the infrastructure such that it threw them out of compliance. 3) The hack was accomplished in an area outside of the purview of the DSS, or 4) Ms. Richey (and others) is doing some serious whistling past the graveyard.

What is happening in the Heartland case is the classic corporate litigation-averse response to a problem. Anytime something bad happens the blame game starts with multiple targets, and as a corporation your sole goal is to be sure to get behind one or the other (preferably larger) target because when the manure hits the fan the person in the very front is going to get covered. Unfortunately this behavior does not seem to really foster solving the problem as everyone has their lawyers and are not talking.

Regardless, maybe the PCI should not be saying things like “no compliant entity has ever been breached” and maybe say something like “perhaps we have a certification issue here”, or “how do we reach continuous compliance?” or even “what are we missing here?”

-Steve Lafferty

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