I was getting a little excited when I read this article over at NetworkWorld about how the PCI council will be releasing a prioritized roadmap for companies facing compliance. It’s a great idea- instead of flogging companies with a massive list of security controls, it will prioritize those controls and list specific milestones.

Now before I get to the fun part, I want to quote myself from one of my posts on PCI:

Going back to CardSystems, a large majority of major breaches involve companies that were PCI compliant, including (probably) Hannaford. TJX is an open question. In many cases, the companies involved were certified but found to be non-compliant after the breach, which indicates a severe breakdown in the certification process.

Now on to the fun (emphasis added by moi):

Businesses that are compliant with PCI standards have never been breached, says Bob Russo, general manager of the PCI Security Standards Council, or at least he’s never seen such a case. Victims may have attained compliance certification at some point, he says, but none has been in compliance at the time of a breach, he says.

What a load of shit. With the volume of breaches we’ve seen, this either means the standard and certification process are fundamentally broken, or companies have had their certifications retroactively revoked for political reasons after the fact. As I keep saying, PCI is really about protecting the card companies first, with as little cost to them as possible, and everyone else comes a distant second. It could be better, and the PCI Council has the power to make it so, but only if the process is fixed with more accountability of assessors, a revised assessment/audit process (not annual), a change to real end-to-end encryption, and a real R&D effort to fix the fundamental flaws in the system, instead of layering on patches that can never completely work.

You could also nominate me for the PCI Council Board of Advisors. I’m sure that would be all sorts of fun.

Seriously – we can fix this thing, but only by fixing the core of the program, not by layering on more controls and requirements.

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