Re: We hit half-million: The Cidr Report

[joel jaeggli <joelja () bogus com>]

On 4/30/14, 9:30 AM, Valdis.Kletnieks () vt edu wrote:
> On Wed, 30 Apr 2014 15:40:43 -0000, Jamie Bowden said:
>
> > You're not funny.  And if you're not joking, you're wrong.  We just went over
> > this on this very list two weeks ago.
>
> And in that discussion, we ascertained that what the PCI standard actually
> says, and what you need to do in order to get unclued boneheaded auditors to
> sign the piece of paper, are two very different things.
>
> Yes, the PCI standard gives a list of 4 options and then continues on to
> say that other creative solutions are acceptable as well.  But if you
> discover mid-engagement that your auditor *thinks* it says "Thou shalt NAT",
> you have a problem.
>
> Anybody got recommendations on how to make sure the company you engage
> for the audit ends up sending you critters that actually have a clue? (Not
> necessarily PCI, but in general)

So, I've been (fomerly) involved in the design/build/operation/refresh
of pci environments as part of application services for enterprise with
~ order of .8 billion annually in online sales. The process starts at
the beginning e.g. before you build it.

If you parachute in a consultant or auditor totally cold, you are going
to have to educate them to the nuances of your particular operation,
it's is very similar with SOX controls.

In any event your documentation should be order. and actual operation
should be as documented.

Ultimately as was my experience with FIPA/HERPA compliance  in the
educational environment these should not taken as mysterious
externalities foisted on operations by hostile regulators, or industrial
cartels, but as part of normal business operations, and internalized as
such.

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