RE: PCI Compliance required if outsourcing?

["Daniel I. Didier" <ddidier () netsecureia com>]

Craig,
You've provided some excellent information.  It seems many organizations
believe that if they outsource, they have no risk.  As you've pointed
out, this is not the case and organizations need to be aware of this!

Dan
www.NetSecureIA.

> -----Original Message-----
> From: listbounce () securityfocus com
[mailto:listbounce () securityfocus com]
> On Behalf Of Craig Wright
> Sent: Wednesday, June 11, 2008 6:45 PM
> To: Eggleston, Mark; security-basics () securityfocus com
> Subject: RE: PCI Compliance required if outsourcing?
>
>
> Outsourcing does not move risk. Your company is responsible for being
> compliant whetrher or not the outsourcer is. On top of this, hosting
> providers have a number of additional requirements that they need to
> fulfil. The following are required from a hosting provider:
>
> A.1.1 Ensure that each entity only has access to own cardholder data
> environment
> A.1.2 Restrict each entity's access and privileges to own cardholder
data
> environment only
> A.1.3 Ensure logging and audit trails are enabled and unique to each
> entity's cardholder data environment and consistent with PCI DSS
> Requirement 10
> A.1.4 Enable processes to provide for timely forensic investigation in
the
> event of a compromise to any hosted merchant or service provider
>
> Also Note:
> "Even though a hosting provider may meet these requirements, the
> compliance of the entity that uses the hosting provider is not
necessarily
> guaranteed. Each entity must comply with the PCI DSS and validate
> compliance as applicable."
>
> So you need to contract PCI into the agreement, but this does not pass
the
> risk. If the outsourcer fails, your company is still non-compliant and
can
> be hit with the fines.
>
> Regards,
> Craig Wright GSE-Compliance GPCI
>
>
> Craig Wright
> Manager, Risk Advisory Services
>
> Direct : +61 2 9286 5497
> Craig.Wright () bdo com au
> +61 417 683 914
>
> BDO Kendalls (NSW-VIC) Pty. Ltd.
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> -----Original Message-----
>
> From: listbounce () securityfocus com
[mailto:listbounce () securityfocus com]
> On Behalf Of Eggleston, Mark
> Sent: Wednesday, 11 June 2008 6:29 AM
> To: security-basics () securityfocus com
> Subject: PCI Compliance required if outsourcing?
>
> Hello PCI experts,
>
> I've seen a lot of info re: PCI on this listserve and was wondering if
> someone can help me.  If a company chooses to outsource PCI compliance
> to a vendor, what are the PCI regulation requirements?  Specifically,
if
> a company uses a vendor/outsources for card payment processing what
are
> the compliance ramifications?  From what I can tell section 12
applies:
> "If cardholder data is shared with service providers, then
contractually
> the following is required:
> 12.8.1 Service providers must adhere to the PCI DSS requirements
> 12.8.2 Agreement that includes an acknowledgement that the service
> provider is responsible for
> the security of cardholder data the provider possesses."
>
> Anything else here to be concerned with?
>
> Regards,
>
> Mark Eggleston
> Manager, Security and Business Continuity
> Information Services
> (215) 991-4388
> -----------------------------------------
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