Re: PCI DSS & Firewalls

[david () lang hm]

On Thu, 2 Apr 2009, Paul D. Robertson wrote:

> > The standard is not the leading instrument here, it's the experience and
> > common sense of the assessors. The PCI doc merely serves as a checklist
> > to demonstrate to the PCI council that requirements have been fulfilled.
> > Either verbatim, or in any other shape or form that still fulfills the
> > desired goal.
>
> The banks, CEOs and IT workers I've all talked to see it as a checklist to
> compliance, or more importantly a checklist to not getting sued.  Avoiding
> the stick is the goal- and those who actually want the carrot look at the
> standard and say "This doesn't help me."  That's bad, because the people
> most likely to know what's wrong in an environment are those who're most
> familiar with it.  The desired goal is not getting sued...
>
> Also, we all know that businesses like efficiency and that time costs
> money- so are you going to check the box or are you going to write out an
> exception and justify it?

worse yet, are the auditors going to accept the exception, or are they 
going to say "I don't care, the standard says X, they know more than you 
do"

I've seen this happen with other things, where what we were doing was safe 
(or safe enough) in our opinion, but management got tired of fighting with 
auditors and told us to change to shut them up.

> > If you have to be compliant and look at the PCI requirements document,
> > and say "this is sad" or "that is not defined", talk to a decent QSA. He
> > can help make this a less confusing and painful experience.
>
> That doesn't make them any less sad or more defined.  This is the best the
> multi-billion dollar payment card industry can do?

worse yet, you end up getting a personal opinion of the QSA, next year you 
may deal with a different one who has a different opinion.

David Lang
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