Wednesday, October 7, 2015

More Observations from the PCI SSC North America Community Meeting

[Our good friend Joe Tinucci also attended the Community Meeting and shares with us his impressions of this year's program. gaw]

I also was privileged to attend the PCI SSC Community Meeting in Vancouver. As with last year's meeting there were several trends that were apparent, both explicitly stated in the sessions and, equally important, discussed at the networking events and on the trade show floor.  Here is a summary of the major trends that I heard at the meeting:

Risk, Risk, Risk

The entire first day of the meeting was devoted to updates from the Council, virtually all of them focusing on risk and risk management.  This theme has carried over from last year, and I assume that it will carry forward to future years.  Using a risk management-based approach it becomes easier for merchants to prioritize what to do first and where to concentrate their scarce resources.  It also makes it easier to incorporate risk avoidance into ordinary business practices.

One major risk that came up repeatedly was third party service providers. It was noted that approximately 1/3 of retail breaches were due to third party vulnerabilities.  Remote access by vendors to merchant systems is particularly problematic; there are standard practices that should be in place to prevent vendors from accessing merchant systems any more often than is strictly necessary.

One excellent resource for managing third parties was the Responsibility Matrix found in the Council's Third-Party Assurance Information Supplement (  Not only does this document provide a framework for assessing the risks of third parties, but also a framework for negotiating the legal responsibilities of each party.  I highly recommend that you download and use this document to help provide the structure for your third party management program.


Another theme was collaboration.  I think it indicates an interest on the part of the Council to expand their purview so as to bring in additional revenues and resources, and to also work with other associations, interest groups, governmental agencies, and rule-making bodies to cooperatively secure payments. Sharing of information, whether officially sanctioned through ISACs or other mechanisms, is one of the few ways that the good guys can stay current with what the bad guys are doing.

Incident Response

There was a lot of discussion of incident response.  The Council recently issued a supplemental guide, Responding to a Data Breach ( that can serve as a checklist or guide to building your incident response program.  The guide's theme of "Preparing for the Worst is the Best Defense" was repeated in multiple presentations.  Prepare now to see more requirements surrounding this area in future versions of the standard.  And, if you haven't yet done so, you should consider holding a "tabletop" incident response exercise just to make sure that you have identified the key players that need to be part of your IR team and that they play well together.


Another recurring theme was segmentation of your cardholder data environment, of course, but also as applied to other environments.  Segmentation is a major scope-reduction tool for PCI DSS compliance.  The newest version of the DSS has an increased emphasis on this topic, particularly validation that your segmentation is working as intended both from inside and outside the network segment.  There was discussion of assurance for your segmentation efforts internal and external vulnerability scans as well as penetration testing to assure that portions of the network that are supposed to be isolated from the rest of the network / Internet truly are isolated and remain that way.  This is one area that will receive even more attention going forward; if not through more requirements then from your QSA / ISAs.

Being Compliant Does NOT Equal Being Secure

Over and over and over, just about every speaker repeated the mantra that being compliant does not mean that you are actually secure.  This is partly to guard against the checklist mentality of compliance, where you do stuff only in order to be able to check the box against the compliance checklist.  But it was also to remind people that we aren't infallible we might be compliant at this particular instant in time but the opportunity to get out of compliance presents itself with the next AV update, new machine added to the network, or vendor software upgrade.  Most of the breached merchants in the last few years considered themselves compliant but apparently not secure.  Hence, the continuing emphasis in the DSS on "Compliance as Business as Usual".  Look for there to be a new direction in future versions of the standard around the associated processes that keep a merchant compliant change management, software upgrades, log creation and review, equipment inspection, and so forth.


It appears that we are finally seeing the emergence of Point-to-Point Encryption (P2PE) solutions for merchants.  This can be another effective way to reduce the scope of your CDE, particularly when used with tokenization.  There are two routes for a vendor to follow when creating a P2PE solution for merchants: validated or unvalidated.  In a validated solution, the vendor integrates validated P2PE applications as components in their larger system, has their solution validated by a QSA specializing in P2PE, and then pays the Council to be listed on the validated solutions website.  (Similarly for validated applications.)  With the upgrade of the P2PE standard to version 2, validated components can now be used by merchants to "roll their own" solution.  One benefit of using a validated P2PE solution, or creating your own system from validated components, is that it makes the merchant independent of their acquiring bank; that is, they can move their merchant account to a different acquirer without junking their P2PE system.

Many acquiring banks have a P2PE solution available to their merchants that may not be listed by the Council as validated, but which is equally well vetted by a P2PE QSA.  The advantage to the acquirer of this route is that their merchants are more closely tied to them and less able to switch acquirers without starting over with another P2PE solution.  The advantage to the merchant is that assuming they do their due diligence with their acquirer to ensure that the offered solution is properly secure and meets their needs the recommended solution may cost less than a validated one and may be more closely integrated with the acquirer.

As noted in Mike's posting, I also was enamored with Vancouver what a lovely city!  Even the weather cooperated to produce picture-perfect days.  The only thing that marred the stay was that I often found myself apologizing (mostly to taxi drivers and waitresses) for being from such a backward country that didn't issue credit cards with chips...  (More on that topic in another posting.)

Joseph D. Tinucci recently moved from the University of Colorado Treasury to Coalfire Systems, Inc., a Colorado-based IT Security Audit and Consulting firm.  At CU Joe managed the PCI DSS compliance program for over 175 merchants across four campuses.  Now he is helping clients manage their compliance programs from the other side of the desk; he notes that it is a refreshing change of pace and duties to be on the "illuminating side"...

Joe can be reached by email to

Monday, October 5, 2015

The 2016 PCI SSC North America Community Meeting

[Mike Leach sent in this terrific summary of his time at the PCI Security Standards Council's North America Community Meeting, held last week in Vancouver, British Columbia, Canada. I wasn't able to attend this year, so thanks Mike! --gaw]

We wrapped up the PCI SSC North American Community Meeting in Vancouver, BC last week. Before I review a few key points of the meeting I want to highlight our host city: Vancouver, BC is a fantastic city! The streets are pedestrian friendly and clean, the people are friendly, the downtown is alive and vibrant after 5. I even stumbled into a shooting set for Minority Report on an evening walk. Then the waterfront and harbor called to us every day, making it hard to go back into meeting sessions. I recommend Vancouver as a vacation destination. I will be back.

This year the University of Indiana, Michigan State, North Carolina State, Oklahoma State, Penn State and University of the Pacific were represented as well as the British contingent: University of Surrey, University of Manchester and the University of Leicester. If I overlooked any Higher Ed schools I'm sorry we missed you at the meeting.

The theme this year was Educate, Empower, Protect. As a between-standards year much of the content was review and reinforcement of known topics. Building on PCI as Business as Usual the Council reiterated its focus on providing guidance and content for Small and Medium Businesses (Hey, that's us!).

To do that they are using a 4 pronged approach:

  1. Establishing a SMB task force
  2. Highlighting the QIR program
  3. Encouraging us to develop Acquirer relationships
  4. (The Council) Deepening relationships with Merchant Associations
There will also be a refreshed website with a preview offered here:

Another sub-theme was collaboration. We know the bad guys are sharing info and learning as a community. We need to do the same. As IU's Ruth Harpool reminded General Manager for the PCI Security Standards Council, Stephen Orfei, Higher Ed knows collaboration. This is one of our strengths we need to continue to leverage so none of us are left behind. When schools write to the PCI listserv with questions, please offer up your answers or experience. If you don't feel comfortable discussing with the larger group reply privately. Continue to ask and share.

Keynote speaker John Nance related his experiences in aviation and healthcare to information security. Humans are the weakest link. By admitting we will fail we can plan for failure and be ready to respond to failures.  John also supports the call for collaboration. Collaboration without a common goal is just disparate groups trying to cooperate.

Several presentations covered the importance of P2PE and Tokenization. We are starting to see more validated solutions listed. These two services provide real card data security and scope reduction. However in speaking with merchants who have started down this path some acquirers are trying to squeeze all merchants into a category that doesn't fit well. A complete implementation will take some time and planning so start now. Caesars Entertainment reviewed their 3 year project to implement P2PE at all 37 properties in 14 states.

Keynote Brian Krebs highlighted some of his adventures in learning and writing about card markets and ATM skimmers. His prediction for US EMV adoption is that we will see growth in new card/account fraud because so much of our US personal data is out there, unlike other countries with more strict privacy laws or less electronic personal data available.

Those are just some of the highlights. Please see the Council's meeting blog site for more meeting coverage:

Next year's North American meeting will be September 20-22 at the Mirage, Las Vegas, Nevada.
Thank you,
Mike Leach

Mike Leach is a System and Network Security Analyst in the Office of Information Systems at The Pennsylvania State University. As a primary function of that job he has been managing the PCI compliance program for nine years. PSU has successfully bridged the IT-Finance/Treasury gap and in cooperation with the Office of Corporate Controller Mike oversees 55 merchant areas using some 150 merchant IDs across 24 campus locations.

Mike Leach can be reached by using the Contact Form in this site’s sidebar.

Wednesday, June 10, 2015

Designated Entities Supplemental Validation

Who in security doesn't like the idea of making security (and thereby PCI compliance) business as usual, or BAU? The goal of BAU is to enable an entity "to monitor the effectiveness of their security controls on an ongoing basis, and maintain their PCI DSS compliant environment in between PCI DSS assessments." (PCI DSS v3.1, page 13) It's a terrific concept, but it hasn't really taken root yet.

The PCI Council offered some examples of how to implement PCI DSS into BAU activities but they didn't go much further than that in describing what BAU means for an entity subject to PCI DSS compliance. The example suggestions include but are not limited to:
  1. Monitor security controls for effectiveness.
  2. Detect and respond to security failures promptly.
  3. Review proposed CDE changes and follow complete change management practices.
  4. Review compliance impact and PCI scope after organizational changes.
  5. Communicate with personnel and review processes to confirm security controls remain in place.
  6. Review technology at least annually for vendor support and security effectiveness.
They also make a suggestion I think is very important: "Consider implementing separation of duties for security functions so that security and/or audit functions are separated from operational functions."

On June 5, 2015 the PCI Security Standards Council (PCI SSC) took the idea of treating PCI compliance as BAU a step forward. And it's a huge step. They created a new compliance validation program and published the PCI DSS Designated Entities Supplemental Validation For use with PCI DSS v3.1. This document takes a deep dive into the BAU idea and provides a lot more guidance on how to comply in a BAU manner. It digs into the organizational environment and operational processes of the assessed entity.

This new set of validation steps came about because investigations of data breaches revealed an important fact. That is, that too many entities are not maintaining PCI compliance between their annual assessments. If you read the 2015 Verizon PCI Compliance Report you learn that only 28.6% of assessed entities were still compliant less than a year after their assessment. While that's an improvement from a few years ago it's still disappointingly low. But now, if acquirers or card brands want to focus in on mid-year compliance problems with certain designated entities they have a new tool in their belt to help keep these entities in line.

My first reaction on reading this was Yikes! But there are some important things to stop and understand before succumbing to fear. First and foremost, Designated Entities Supplemental Validation (DESV) applies only to designated entities. That designation can only be assigned by an acquirer or card brand. A QSA can't require it during an assessment, and there is no set of self-assessment qualifications that would require you to follow it. It is an additional validation step required for particular entities. The Council provides some examples of which entities it may apply to, which could include:
  • Those storing, processing, and/or transmitting large volumes of cardholder data,
  • Those providing aggregation points for cardholder data, or
  • Those that have suffered significant or repeated breaches of cardholder data.
My take on it is that this would apply mainly to Level 1 merchants and service providers. I can't recall if I have met someone from a university that is a Level 1 merchant. Even with aggregation my school is a Level 2. If an acquirer or a card brand gets suspicious that an entity is not trying to make PCI compliance BAU, the entity may receive the DESV designation.
Secondly, the DESV does not create any new PCI requirements. Instead it tells an entity how they can meet the requirements already included in PCI DSS. It provides a path to demonstrate to their acquirer or card brand that they are maintaining compliance and it is not just an annual checkbox exercise. Each of the DESV requirements refers to the section(s) of the PCI DSS that it comes from.
Here is an example:

DE.1.1 Executive management shall establish responsibility for the protection of cardholder data and a PCI DSS compliance program to include:
  • Overall accountability for maintaining PCI DSS compliance
  • Defining a charter for a PCI DSS compliance program
  • Providing updates to executive management and board of directors on PCI DSS compliance initiatives and issues, including remediation activities, at least annually
PCI DSS Reference: Requirement 12
Each of these requirements also has a detailed testing procedure (often referencing specific documents) and a guidance column, just like you see in the standard itself. You will see things that you don't see in the standard, but those are often considered implicit in the PCI DSS. For example, in DE 1.1 above it references "a charter for a PCI DSS compliance program." This takes requirement 12 up a notch in terms of having tangible evidence that it is being followed.
The additional validation steps are grouped into five main areas to control. Those are:
  • DE.1 Implement a PCI DSS compliance program.
  • DE.2 Document and validate PCI DSS scope.
  • DE.3 Validate PCI DSS is incorporated into business-as-usual (BAU) activities.
  • DE.4 Control and manage logical access to the cardholder data environment.
  • DE.5 Identify and respond to suspicious events.

There are no surprises here. But I am particularly impressed with Area 2, scoping. It has concrete steps to assess and validate the scope of compliance. We all know how slippery scope can be sometimes. Area 2 sheds a lot of light on scoping here. It covers data discovery tools in some detail and also addresses data exfiltration. I particularly like the requirement to not only document the PCI scope, but also to document what is not in scope. That's thorough.

Some of these new DESV requirements are different from the PCI DSS simply because they go above and beyond in terms of frequency or reporting. For example, penetration testing is required at least annually in the PCI DSS. But in DE 2.4 it becomes a semi-annual process for organizations that use segmentation to limit scope.

I think the DESV program should not be a big concern for colleges and universities at this time. But things do change, and it's a rare day when PCI DSS requirements get looser instead of tighter. Take this example from the FAQ:
  • Q5: Can I use the DESV even if I’m not a Designated Entity?
  • A: Yes. The DESV can be used to complement any entity’s PCI DSS compliance efforts, and all entities are encouraged to follow the DESV as a best practice, even if not required to validate.

I would agree with that. If I had the security resources available to implement DESV now I would do it! However, not many of us in this sector have those kinds of resources. But do take note of the encouragement "to follow the DESV as a best practice." We know that sometimes best practices become requirements later on. Take heed, my friends.

The Designated Entities Supplemental Validation program was released with a good set of supporting documents, including a FAQ sheet, a reporting template, and its own specific Attestation of Compliance. You can read the press release on the PCI Security Standards Council's web site ( and you will find the related documents in the Council's documents library.

Payment Card Industry (PCI) Data Security Standard
PCI DSS Designated Entities Supplemental Validation
For use with PCI DSS v3.1

Monday, April 27, 2015

New PCI DSS SAQs for version 3.1

As Emma Sutcliffe mentioned to us at the PCI Workshop last week, the PCI Security Standards Council has today released version 3.1 of the Self-Assessment Questionnaires. At this time they are only available in Microsoft Word format. I expect the PDFs will come later.

In addition, there are two new updates to previous documents. First, there is new version of Understanding SAQs for PCI DSS v3. I wish they had called it v3.1 to distinguish it from that confusing InfoSupp released last May. I have not read it in detail yet, but I did take a look at the comparison tables. Hallelujah! They removed that horrible, undefined term “acceptance” from the document. That added so much confusion. They also removed the entire “Control of Cardholder Data” comparison completely.

The other updated document is SAQ Instructions and Guidelines v3.1, finally updated from PCI DSS v2. I haven’t had a chance to dig deeply into this either, but I’m sure it will yield some gems I can use in tomorrow’s PowerPoint!

You can find the new documents on the PCI SSC web site in the document library under the SAQs tab. There is also a SAQs v3.1 link on the home page:

Monday, April 13, 2015

Sunday Evening Reception

Hello all,

There are MANY attendees checking in on Sunday this year, so you may have noticed that the Treasury Institute has added a Welcome Reception on Sunday evening. This informal event will be a great opportunity to meet and greet old friends and new. The reception will be in the Opium Terrace (by the pool) from 6:00 to 7:30 PM, with beer, wine, and cheese served. (Please note, the time was incorrectly listed as 5:00-6:30 in an earlier post.)

Please make sure you hit the Workshop registration table, open from 4:00PM-6:00PM Sunday, so that you can pick up your badge for entry to the reception. As usual, many of us will join up into informal groups for dinner afterwards. Don't be shy.

I’m looking forward to seeing many of you next week in Las Vegas!


Friday, April 3, 2015

2015 PCI Workshop Sponsors

I'm really looking forward to the Treasury Institute's 2015 PCI Workshop in Las Vegas Henderson, NV, coming up in about two weeks. The frigid Michigan winter made a PCI popsicle out of me, and I am ready to thaw out!

But before I head out I want to make a mention of our workshop's Partners and Supporters. Without their generous support we would not be able to have this terrific workshop, especially at the low price for registration. Most of these supporters will be there with informational tables, and it would be great if you could stop by their display and say hello during the workshop this year. They offer solutions to help us get our jobs done, and they are generally very familiar with our sector.

Here is the group we will have with us later this month:

Founding Partner

Alliance Partners
Association for Financial Professionals

Bluefin Payment Systems

See you in Vegas, Baby!

Monday, March 30, 2015

2015 PCI Workshop Program Set

Update, 3/30/2015: I heard from one presenter that his description of his presentation did not match up with what appears on the Treasury Institute web site. If any other have seen this, please let me know and we'll get it worked out. Also, our Sponsors and Supporters page may not be complete yet, I think some paperwork still needs to be processed before all the supporters are listed. --gaw

FRIDAY, MARCH 30, 2015

It's here at last. The program committee for the workshop has wrapped up the schedule for the 2015 Treasury Institute PCI Workshop. You can see the summary on the Treasury Institute's Workshop information page at I will add more details in the days to come.

Something new this year - we will have a (semi-official) pre-workshop reception at the resort late on Sunday afternoon. Many attendees will be checking in on Sunday April 19, so we will have an informal Welcome Reception from 5:00 until 6:30 PM 6:00 until 7:30 PM. Talk about the week ahead or just relax after a day of travel with old friends and new. In years past groups have formed up on Sunday to sample the local restaurants and we will do the same. Dine at one of the Green Valley Ranch Resort, Spa, and Casino's 10 restaurants or head for the Strip! Or you can have a more laid-back night and take in the latest flick at the Regal Cinema, with 10 screens right on the resort property.

Whatever your arrival day plans may be, get ready for a fun and informative week at the 2015 Treasury Institute PCI Workshop.

Note: We may break attendance records for the second year in a row. If you have any problem booking your room (we're nearly sold out), our Meeting Planner Megan at the Professional Development Group will help you out. Information on Workshop rooms and Megan's contact info may be found here: