BreachExchange mailing list archives

Re: Visa Puts Heartland on Probation Over Breach


From: A K <platsakos () gmail com>
Date: Fri, 13 Mar 2009 20:17:01 +0200

The problem is that PCI-DSS is a manifestation of "having controls just
to please the auditors". Yes, it is a step in the right direction but
when security dissolves into boxes to tick and automated tools (i.e. you
can be PCI-compliant even if you are "ownable" by chaining a couple of
vulnerabilities that by themselves do not break compliance), then things
are sure to go downhill.

Jamie C. Pole wrote:
Just a quick clarification...

I was not trying to say that ALL QSA provides were incompetent.   
However, I do feel obligated to say that the overwhelming majority of  
the ones I have worked with have displayed a level of competence and  
technical acumen that was far below the level at which I would  
consider hiring someone for an entry level position in my firm.

My problem with the QSA program is very simple - I believe that it's a  
pay-to-play scheme.  If I was a construction contractor, and I was  
asked to pay a fee to be able to bid on city or state construction  
contracts, that would be considered an act of corruption.  The  
official would get in trouble for asking for the fee, and I would get  
in trouble for paying the "bribe".

I believe that a certain governor was just removed from office for  
playing this kind of game.

By making the QSA process a pay-to-play scheme, the PCI people have  
ensured that the QSA population will not be representative of the  
population of security professionals as a whole.

Put another way, wouldn't any CISSP that paid the QSA fee be in  
violation of the ISC2 Code of Ethics?  If a pay-to-play scheme is  
criminal-enough to get a governor impeached and removed from office,  
how is it not criminal enough to violate the Code of Ethics?

Let's be perfectly clear - the QSA program is not some kind of vendor  
partner program where you pay to get priority access to support or  
resources.  A QSA is paying for the ability to enter into a captive  
market.  Technical acumen or experience does not matter - all that  
matters is whether or not the check clears.  I wonder if they publish  
statistics on the percentage of QSA applicants that are turned down?

Just something to think about...

Obviously, this is not the entire problem with PCI, but it is  
definitely a significant part of it.  Any process will only be as good  
as the people that administer it.

Jamie


On Mar 13, 2009, at 8:38 AM, lyger wrote:

  
(courtesy Anthony M. Freed)

http://information-security-resources.com/2009/03/13/visa-puts-heartland-on-probation-over-breach/

*Removal from Visa~Rs List of Compliant Service Providers - Visa has
removed Heartland from its online list of Payment Card Industry Data
Security Standard (PCI DSS) compliant service providers. HPS has  
advised,
however, that it is aggressively working on remediation and re- 
validation
of its systems to comply with PCI DSS standards. The company will be
relisted once it revalidates its PCI DSS compliance using a Qualified
Security Assessor and meets other related compliance conditions.*

*System Participation - HPS is now in a probationary period, during  
which
it is subject to a number of risk conditions including more stringent
security assessments, monitoring and reporting. Subject to these
conditions, Heartland will continue to serve as a processor in the  
Visa
system.*

[...]
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Dataloss Mailing List (dataloss () datalossdb org)

CREDANT Technologies, a leader in data security, offers advanced data encryption solutions.
Protect sensitive data on desktops, laptops, smartphones and USB sticks transparently 
across your enterprise to ensure regulatory compliance.
http://www.credant.com/stopdataloss

  

_______________________________________________
Dataloss Mailing List (dataloss () datalossdb org)

CREDANT Technologies, a leader in data security, offers advanced data encryption solutions.
Protect sensitive data on desktops, laptops, smartphones and USB sticks transparently 
across your enterprise to ensure regulatory compliance.
http://www.credant.com/stopdataloss


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