It’s no secret that I haven’t always been the biggest fan of PCI (the Payment Card Industry Data Security Standard). I believe that rather than blowing massive amounts of cash trying to lock down an inherently insecure system, we should look at building a more fundamentally secure way of performing payment transactions. Not that I think anything is ever perfectly secure, but there is a heck of a lot of room for progress, and our current focus has absolutely no chance of doing more than slightly staving off the inevitable. It’s like a turtle trying to outrun the truck that’s about to crush it- the turtle might buy itself an extra microsecond or two, but the outcome won’t change.
That said, I’ve also (fairly recently, and due in no small part to debates with Martin McKeay come to believe that as flawed as PCI is, it’s also the single biggest driver of security improvements throughout the industry. It’s the primary force helping security pros gain access to executive management; even more so than any other regulation out there. And while I’d really like to see us focus more on a secure transaction ecosystem, until that wonderful day I recognize we need to live with what we have, and use it to the best of our ability.
Rather than merely adding new controls to the PCI standard, I think the best way to do this is to fix some of the inherent problems with how the program is currently set up. If you’ve ever been involved with other types of auditing, PCI looks totally bass ackwards. The program itself isn’t designed to produce the most effective results. Here are a couple of changes that I think could make material improvements to PCI, possibly doubling the number of microseconds we have until we’re a steaming mass of roadkill:
- Eliminate conflicts of interest by forbidding assessors from offering security tools/services to their clients: This is one of the single biggest flaws in PCI- assessors may also offer security services to their clients. This is a massive conflict of interest that’s illegal in financial audits due to all the problems it creates. It will royally piss off a few of the companies involved, but this change has to happen.
- Decertify QSAs (assessors) that certify non-compliant companies: Although the PCI council has a few people on their probation list, despite failure after failure we haven’t seen anyone penalized. Without these penalties, and a few sacrificial lambs, QSAs are not accountable for their actions.
- Eliminate the practice of “shopping” for the cheapest/easiest QSA: Right now, if a company isn’t happy with their PCI assessment results, they can fire their QSA and go someplace else. Let’s steal a rule from the financial auditing playbook (not that that system is perfect) and force companies to disclose when they change assessors, and why.
There are other actions we could take, such is publicly disclosing all certified companies on a quarterly basis or requiring unscheduled spot-checks, but I don’t think we necessarily need those if we introduce more accountability into the system, and reduce conflicts of interest.
Another very interesting development comes via @treyford on twitter, pointing to a blog post by James DeLuccia and an article over at Wired. It seems that the auditor for CardSystems (you know, one of the first big breaches from back in 2005) is being sued for improperly certifying the company. If the courts step in and establish a negligence standard for security audits, the world might suddenly become mighty interesting. But as interesting (and hopefully motivating, at least to the auditors/assessors) as this is, I think we should focus on what we can do with PCI today to allow market forces to drive security and program improvements.