PCI-DSS IATA: Dissecting the New FAQs

A few significant things occurred this week for the IATA PCI-DSS Program, summarised below:

a) We finally have a very clear way forward thanks to some clarifications direct from IATA, and in some parts due to our dogged persistence to get some answers

b) The new FAQs were published end of June and an updated version was done yesterday (11 July) and is now online at http://www.iata.org/services/finance/Documents/pci-dss-faqs.pdf

Firstly, the significant news.

IATA confirmed that Level 3 and Level 4 Merchants do not need a QSA to signoff their AoC/SAQ – which, to many agents, means they can do SAQ on their own, or using their own IT resources, or external consultants (not necessarily QSA, but if you prefer a QSA, by all means, go for it)

IATA also confirmed that they are considering exemptions for agencies that do not have any credit card transactions in their business channels.

These two clarifications address some long running questions agencies had for PCI-DSS. Do they need external consultants, do they need a QSA, do they need any compliance even if they don’t have credit card, etc etc.

Regarding point b) above, there was a quick iteration on the FAQs to clarify a few items. So here are some of the changes between the newest FAQ on 11 July and the one on the 29 June, and we can go through it.

The first 4 FAQ questions remain more or less the same although we do have a nitpick on 1, which is

FAQ#1 Who do I approach for PCI DSS compliance?
We suggest that you contact your acquirer.

Technically, this is correct, however, it’s not exactly complete. Because their (travel agents) acquirer wouldn’t have visibility over the agencies’ channel of credit card via GDS and BSP (or soon to be NGI – the new gen ISS). Acquirers have no idea of this because when the agents uses GDS credit card facility, they are doing in BEHALF of airlines! So even if they were to correspond with the payment brands directly as per FAQ#3, the brands wouldn’t know, nor care about the agency. Because in the GDS-BSP channel, the agency is not the merchant – it is the airline. (lightbulb).

Therefore, it must be the airlines who must be PCI compliant in that channel – however, because they make use of agents, the agents end up having to be compliant as well. But the airlines don’t deal directly with agents for this channel – they have an aggregator in between the agencies and airlines. And yes, this aggregator, this glue that holds everything together is the ecosystem of GDS-BSP/NGI. So if the agency connects to BSP, IATA is the ‘service provider’ offering this service – therefore, it is IATA that needs to clarify the requirements. Which they are doing – so technically FAQ 1 should read

FAQ#1 Who do I approach for PCI DSS compliance?
Yo, it’s us, man! That’s why you’re reading this on an IATA page!

In our clarification request, we didn’t point this out to IATA because our email at that point was already too long. It’s like we were writing the Titanic of emails, and we had to cut some scenes to fit into a readable email size.

Next, FAQ #6 is also important. Only for our own selfish self satisfaction.

FAQ #6 Are compliance certificates recognized for PCI DSS validation?
The answer to this question is no. Any sort of documentation which is not under the authority and validation of PCI DSS, will not be accepted for indicating the company’s compliance with PCI DSS.

And this is what we have been telling clients for YEARS. There is literally no such thing as a certification of compliance as far as PCI is concerned. Yet, everyone wants to see your ‘certificate’ and even go as far as to reject the AoC and RoC and SAQ documents. There is NO SUCH THING as a PCI-DSS compliance certificate. If someone prints a certificate out for you, it cannot bear any logo from the PCI-DSS council because it is not part of PCI. It’s a nice piece of paper to put up in your lobby but that’s it. When we work with our principal QSA, they also have this “certificate”, but we always make it clear that this is only issued as an aesthetic by the QSA and not considered acceptable to the PCI-DSS program formally. You MUST have the AoC and RoC/SAQ combination of documents at least – and also whatever ASV scans etc you might have. So, we would suggest not to go about calling yourself PCI-certified agency – just say you are compliant to PCI is enough. It sounds less sexy but those are more accurate terms to use.

FAQ#7 was corrected to refer to Question 14, instead of Question 13 as previous FAQ stated. Innocent error, of course, no harm done. It doesn’t mean that the writer of the FAQ can’t count.

FAQ#8 was also corrected whereby the previous FAQ stated (emphasis ours)

“The latter has to be completed as a declaration of the results of the service provider’s assessment with the Payment Card Industry Data Security Standard Requirements and Security Assessment Procedures (PCI DSS).”

and now correctly states

The latter has to be completed as a declaration of the results of the merchant (or travel agencies)’s assessment with the Payment Card Industry Data Security Standard Requirements and Security Assessment Procedures (PCI DSS).

Because technically, travel agents are merchants not service provider, so it might be just a copy and paste error.

FAQ#11 Can a QSA that is not listed in a specific country but listed in another country conduct a certification process in the non-listed country?

Originally it stated

“Yes. By definition, Qualified Security Assessor (QSA) companies are independent security organizations that have been qualified by the PCI Security Standards Council to validate an entity’s adherence to PCI DSS.”

This might not be exactly accurate as there are certain regional restrictions based on fees. So, the change became

“Overall speaking, yes. Nevertheless it should be noted that under the QSA program guide, section 6.3.1, there are qualified regions in which QSA can or cannot perform in as noted “QSA Companies are authorized to perform PCI DSS Assessments and QSA-related duties only in the geographic region(s) or country(s) for which they have paid the regional or country fees, and as indicated on the QSA List.”

Once again, that’s more accurate. And there are more words. And it has a quote from an official document from PCI, so it sounds very important.

FAQ#14 has the big change in the new FAQ version compared to the one in June, whereby under level 2 merchant column we have this “note” to clarify that level 2 merchants under Mastercard requires either an onsite ISA or onsite QSA to validate their SAQ. This is what we call “Validated SAQ”, and this is what Mastercard was telling us earlier, that this must be done by the QSA onsite (if they do not have an ISA – which is “internal security assessor”, which is as rare as an albino beluga whale).

FAQ#18 is the one applying to agencies without any credit card transactions. Now you do need to be careful. IATA does state that PCI applies to agencies processing credit card with the IATA GDS-BSP channel or any other channel (including your acquiring bank direct channel). This means if you have an EDC or POS device, or do internet transactions, you STILL need to undergo PCI-DSS. Who you send your AoC/SAQ to is another story, because IATA wouldn’t know much about your POS/EDC channel since you are not their merchant. Technically you send it to whoever you have a merchant account with – your acquirer. But again, your acquirer isn’t even asking for it! So. We suggest that you still do it, and keep it in case someone asks for it. We hear some cynical snorts in the background but we are going to ignore it. Be nice.

FAQ#23 – they decided to completely change this one. The previous answer seemed slightly confusing and in contradiction to FAQ#6 and FAQ#14. Previous FAQ in end June stated:

It should be noted that the third party should be authorized by the PCI DSS Council as a Qualified Security Assessor (QSA) to accept the PCI DSS compliance certificate. The scope shall cover the BSP card sale transactions.

a) Again, as FAQ#6 already confirmed – there is no such thing as a compliance certificate, so technically all compliance certificates issued by whoever, whether QSA, ISA, consultant or the Queen of England should not be accepted as formal documentation of PCI. One more time we hear this certificate of compliance being bandied around like its some sort of Ark of the Covenant, we are going to collectively walk out of our office and lie down on the main road in silent protest.

b) It’s sounds slightly confusing because it seems that this statement is saying a QSA is needed to be involved for all merchant level compliance as well which is contradicting FAQ#14.

To give them credit, their explanation to this was:

“We have had instances in which the agent was providing us with some sort of certificate issued by a third party, under the assumption that the certificate was issued by a QSA therefore we wanted to make clear that in the case an agent were to go this way they should be checking out the authorized QSA list available in PCI DSS council site.”

Yes, completely agreed. But not the certificate part. D@mn it, that’s it! We are headed out tomorrow and lying down on the street in protest!! Watch the news!

Anyways, now the current FAQ#23 reads a different:

Because most large merchants have complex IT environments, many hire a QSA to glean their specialized value for on-site security assessments required by PCI DSS. The QSA also makes it easier to develop and get approval for a compensating control. However, for Level 3 and Level 4, PCI DSS provides the option of doing an internal assessment with an officer sign-off if your acquirer and/or merchant bank agrees. Mid-sized and smaller merchants may use the Self-Assessment Questionnaire found on the PCI SSC Web site to assess themselves.

If this sounds familiar, it’s because it is. It’s lifted from Myth 6 in the famous PCI document at https://www.pcisecuritystandards.org/pdfs/pciscc_ten_common_myths.pdf

It’s certainly reads better, although, it doesn’t really answer the FAQ#23’s questions, but hey who cares? It makes sense!

So anyway, from this we learnt a few things

a) IATA is really keen to be on the ball on this PCI-DSS compliance and has put in effort in getting the right information out to the agencies – kudos to them and really impressed with their management’s response to queries.

b) The industry as a whole is still grappling a lot on PCI-DSS and needs to move forward with the right information and decision.

c) As QSAs, consultants, auditors, advisors or IT experts, we all need to work together to get our clients up to speed with the right information so they can make decisions and we can assist them.

PCI-DSS is never easy. Even those doing SAQ A-EP are having headaches, what more agents going through SAQ D-MER and all its 340++ questions. IATA seems to understand that and has PCI on their agenda.  We are willing to work with anyone on this – we have our clients who are travel agencies, but we also want to help other agencies get up to speed with PCI, what is required, and how to get compliant from the different validation requirements per PCI’s standpoint.

So to summarise this long winded post, from the horses’ mouth themselves:

a) There is no need for QSA involvement in Level 3 and level 4 merchant self assessment questionnaire (SAQ). Merchant officer signoff on section 3b is enough. However (and this is our opinion) if you can get assistance from QSA, ISA, consultants, IT experts, auditors,the Queen of England or even your own internal IT person familiar with PCI, go for it. You’ll need all the help you can get.

b) For those without credit card transactions in ALL channels (not just IATA), consider the exemption in FAQ#18. But please contact IATA on this as you should truly understand what might be the consequences in the future.

OK, that’s it for now. Drop us a note at pcidss@pkfmalaysia.com. We are preparing a complimentary talk on PCI-DSS specific to this travel agency industry soon, so stay tuned!

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