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Question about PCI audit results and reality....


From: vlape at me.com (Vincent Lape)
Date: Wed, 12 Aug 2009 11:56:16 -0700

in this economy good luck. its hard to justify spending money if the  
helmets are "good enough to pass". i have found in the past that if a  
brick fell down and hit a squirrel in the head, and the squirrel died,  
something was done at a quick pace. OR if the squirrel helmets  
experienced a catastrophic failure they would need to be replaced.



On Aug 12, 2009, at 10:23 AM, Jason Wood wrote:

So I have a "hypothetical" situation that I'd like some ideas on.

Say you go through a PCI audit and certain things that you know are  
a problem are not marked as such by the auditor.  (we can get into  
getting a new QSA later)  To make up a completely fake scenario,  
lets say that item 15.3 requires all squirrels to wear helmets when  
running the credit card numbers from the web server to the database  
server.  (squirrelNet anyone?)  The QSA says that there are no  
problems and that the squirrels are wearing helmets properly.  The  
issue is that the helmets are made of newspaper and don't look like  
a helmet from anything beyond a passing glance.

As the admin/squirrel handler, I want to justify getting proper  
helmets on the squirrels.  However, here's this audit report which  
states that there's no problem here.  How do you go about justifying  
"real" squirrel helmets when the QSA says everything is good.   
Chances are good management is going to look at the report and tell  
you to leave the newspaper hats in place because it is good enough  
for the QSA.

Short of calling up the QSA and asking him WTF (and getting in hot  
water for doing so), how do you deal with this?

Here's some of the ideas that have occurred to me:
Explain to management what squirrel helmets really are supposed to  
be and that not every QSA is going to be so... casual about them.
Explain that PCI is a minimum set of requirements and doesn't insure  
actual security.
Club a squirrel on the head and demonstrate that newspaper isn't an  
adequate helmet.
How do you deal with justifying security improvements when an audit  
report says that everything is blue skies and happy days?

Thanks,
Jason

P.S.  SquirrelNet was inspired by @beaker and no actual squirrels  
were used to run credit card numbers or were clubbed on the head  
while writing this email.

-- 

irc: Tadaka
Twitter:  Jason_Wood
jwnetworkconsulting.com
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