Educause Security Discussion mailing list archives
Re: PCI Compliance
From: "Penn, Blake" <pennb () UWW EDU>
Date: Fri, 23 Mar 2007 10:07:50 -0500
True, you can limit your PCI DSS non-compliance risk contractually by "passing the buck" to the vendor if they are comfortable with signing such contracts. However, even if you are hosting "compliant" applications, there are many variables for which you are going to be responsible for maintaining compliance. Think of system configuration, for example. A vendor may attest to the compliance of their product, but no vendor in their right mind is going to sign a contract whereby they accept financial responsibility for non-compliance in the case of system that is configured in manner by which it is rendered non-compliant. An exception to this might be truly "turn-key" solutions that involve no interaction from the customer. Most solutions, however, are going to allow some level of administration, configuration, etc. from the customer as well as the vendor. It is going to be the customer's responsibility to administer, configure and maintain such systems so that they are in compliance with the standards. And true, banks are passing the buck contractually as much as they can. However, most banks of any significant size also have massive internal compliance programs for PCI DSS and other infosec-related regulations (SOX, GLBA, etc.). I personally know from former infosec colleagues at a large bank that I used to work for that their current PCI DSS compliance efforts are being tackled on a massively enterprise scale both technically and procedurally and not just solely through contractual risk mitigation. ___________________________________________ Blake Penn, CISSP Information Security Officer University of Wisconsin-Whitewater (p) 262-472-7792 (f) 262-472-1285 pennb () uww edu | http://www.uww.edu/security -----Original Message----- From: Roger Safian [mailto:r-safian () NORTHWESTERN EDU] Sent: Friday, March 23, 2007 8:42 AM To: SECURITY () LISTSERV EDUCAUSE EDU Subject: Re: [SECURITY] PCI Compliance At 08:23 AM 3/23/2007, Kees Leune put fingers to keyboard and wrote:
Hello, On Thu, Mar 22, 2007 at 01:38:29PM -0400, Theresa M Rowe wrote:Has anyone had success with achieving compliance to the PCI standard? We've hit some confusion here. If we: * license software that takes credit card payment over the web * and the web servers are located on our campus Aren't we obligated to make sure that the software is "PCI compliant"
from the
vendor? All organizations that handle credit card payments in any form (store, forward, accept, etc.) are required to ensure that they, but also all their vendors (the entire chain) are PCI compliant. So, technically, even if your entire organization is secure, but you use
non
pci-compliant software to process credit card payments, you are in
violation
of the standard.
Here's my understanding, IANAL. PCI requires that you use products and services that are PCI compliant. If you use software, you need to ask the vendor if they are PCI compliant. You also need to ensure that the contract they sigh states they are compliant. Beyond that, you have to do nothing. If the vendor is wrong about their compliance, then they have legal issues because of the contract and you should be able to pass the buck. Basically that's what the banks are doing. -- Roger A. Safian r-safian () northwestern edu (email) public key available on many key servers. (847) 491-4058 (voice) (847) 467-6500 (Fax) "You're never too old to have a great childhood!"
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Current thread:
- PCI Compliance Theresa M Rowe (Mar 22)
- <Possible follow-ups>
- Re: PCI Compliance Penn, Blake (Mar 22)
- Re: PCI Compliance Kees Leune (Mar 23)
- Re: PCI Compliance Roger Safian (Mar 23)
- Re: PCI Compliance Lovaas,Steven (Mar 23)
- Re: PCI Compliance Penn, Blake (Mar 23)
- Re: PCI Compliance Bill Ogle (Mar 23)