Tag: self assessment

The Biggest (Real) Myths of PCI-DSS: Part 1

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Sometime back, PCI-DSS published the Top 10 Myths of PCI-DSS which we debunked in our series of Myths of the Top 10 Myths here. In this article, we are going to jump into the real actual Myths of PCI-DSS and we will explain it as we go along. We are not going to touch on the original myths published by PCI Council, but this is really very much based on our experience in PCI-DSS for more than a decade here in Malaysia, and what we often hear companies going about.

Often this misinformation is because the client facing PCI-DSS finds it hard to dissect all the information needed for the standard. Unlike standards like ISO27001, PCI-DSS is like a journey with different routes to the same destination: PCI Compliance. There are 3 separate destination for PCI – Level 1 Certified with QSA, Level 2 Self Assessment with QSA/ISA signoff, and Level 2 Self Assessment with Self Sign off (no QSA, no ISA signoff). Of course if you are a merchant, then you have level 3 and level 4, but those are the same as the third iteration where you signoff the SAQ on your own without involvement of QSA/ISA.

But while the destination itself can be clarified, the whole process to obtain PCI can be convoluted. Some clients are told by their banks, that because they do not store credit card, they are considered SAQ level 2. Or some are told because they have a website, they must do ASV scans. Or some are told that QSAs must be involved in everything. Some are even told, that local QSAs must be hired, and not any other QSAs. Some are of the opinion that PCI is a license they need to purchase, or a training they need to do. And some are of the opinion that the ASV scan will make them PCI compliant.

Hence, it’s easy with all the above misinformation and more, that customers get frustrated with the expectations of PCI. When they hear a level 1 certification may set them back 15 – 20K USD or more, or that it would take them 6 months or so, they balk at it. It’s funny because often I would start my sales pitch by saying: “At the end of our conversation, it would be goal to try to get you to avoid getting services from us if possible.” Because it’s essentially true. Our job at the beginning isn’t to peddle services or consulting or audit that our clients may not need. Our goal is to provide them with enough information of PCI-DSS so they can make informed decisions. And yes, even if those informed decisions would be that they can avoid PCI, or do their own SAQ without any consultation or ASV scans or certification, or get exemption from their banks/customers or anything else that can lower their requirements for PCI-DSS. And yes, many people who have called us actually just pay us by saying ‘thank you’ and we never hear from them again. Because as advisors, it’s better we start doing the right thing at the very beginning instead of focusing to sell services that customers do not need. This philosophy has been adopted from the start of our company – which is one of the reasons why I failed so miserably in my previous corporate role as regional head of professional service sales. Or also why I was once told off by a potential business partner that I was a poor sales person and that he preferred to work with an organisation with someone better handling sales. Ah well.

So here are some of the top REAL myths of PCI-DSS that needs to be debunked, burned, destroyed and thrown out of the window for the garbage that it is.

1) All PCI-DSS Projects Require ASV Scans

2) ASV scans makes you PCI compliant

3) All PCI-DSS requires (local) QSA

4) All PCI projects are the same (One Certificate to Rule them All)

5) All PCI-DSS services must be outsourced

6) All service providers MUST be certified to do implementation services

7) PCI scope and application of controls can be determined by the customer

8) PCI-DSS gets easier and cheaper every year

9) A company is considered PCI compliant even after the expiry of certification, due to 90 days grace period from the council

10) If the company is an ISMS certified company, they have already complied to 90% of PCI-DSS

So there is quite a bit of stuff – some may be half truths and other are utter nonsense – we need to uncover, likely will need to break this article up into two parts. Let’s jump into it.

Real Myth 1: All PCI-DSS projects require ASV scans

This myth is often peddled by those who are selling ASV scans as part of their service. Don’t get me wrong, we also do ASV scans through our ASV partners for sure, but you can’t go around town telling people that all PCI requires ASV scans when it doesn’t! Read SAQ A. Read SAQ B. You don’t see ASV being mentioned anywhere in the SAQ except for this portion in Part 3a:

ASV scans are being completed by the PCI SSC Approved Scanning Vendor (ASV Name)

And under “PCI DSS Self-Assessment Completion Steps”:

Submit the SAQ and Attestation of Compliance (AOC), along with any other requested documentation—such as ASV scan reports—to your acquirer, payment brand or other requester.

The thing is, if you go through each control under the SAQ, the ASV control 11.2.2 isn’t mentioned, so therefore it’s not required. It’s highly frustrating to us, especially when travel agencies for instance who are just doing EDC terminal business (SAQ B) that connects directly via cellular or phone line to acquirer coming to us and asking us to quote for an ASV scan for their website. We tell them, you don’t need to do ASV scan for your website unless its in scope. You can force us to sell to you, but it’s against our moral code to sell you stuff you don’t need. We take a look at it, find its a simple site with only information and they tell us, “Well, their PCI advisor previously told them to scan their website.” No. You don’t need to. Don’t waste your money, and don’t do it unless you have a website in scope or you are doing an SAQ requiring ASV scan or you consciously make a decision to do it out of best practices and security requirement – NOT as a mandatory PCI-DSS activity.

So, please, take a look. Even SAQ A, usually adopted by e-commerce sites that redirects to a payment gateway for card input – where there is likely a website, the myth is that ASV needs to be done. Read SAQ A. Again, no requirement for ASV scan. You can still do an external scan for security purpose, but strictly for compliance? No. Not needed, unless requested specifically by the acquirer.

And yes, we do have ASV scans as part of our service. But that shouldn’t make us charlatans peddling services to customers when it isn’t mandatory. If the client still wants to pick it up, ok, fine – but don’t say it’s compulsory when it’s not!

Real Myth 2: ASV scans makes you PCI compliant

We have flogged this one half to death in our earlier article here: ASV scans=/ PCI Compliance

I won’t repeat what we have said there but by far, this is a myth that gets peddled a lot. One, sadly, is because the propagation of this nonsense seems to be acceptable by banks. I hear: “Oh, no problem, the bank says all we need to do is to run an ASV scan on our website.” I interject: “Wait sir, you aren’t doing that e-commerce business. You are doing a call center with virtual terminal payments..” <Click> <Dial tone due to hang up>

So there you have it : companies and merchants that have no business doing ASV scans , but using ASV scans as a means to ascertain PCI compliance. We get this even weirder ones when we are trying to obtain an AoC from one of our client’s service providers and they pass us their passed ASV scan report. We ask what the heck that is and they go – that’s our PCI compliance, so please shut up and stop bothering us. And it’s so difficult to go out and explain to them that whoever told them that, is wrong, and they have to go through the actual PCI compliance, which their wonderful ASV scan may (or may not) be part of that overall PCI Compliance.

Real Myth 3: The Auditor (QSA) must be Local

This is one of the strangest myths ever.

We get calls from customers going, “Is your QSA a Malaysian?” And I go, “No, we work with our partner QSA, from India, US or Singapore”. And they go, “Well we want a Malaysian QSA.” And I ask, “Why?”, and most of them are not able to ascertain why they need the QSA to be local, except that it may be a requirement checkbox in their document or policy.

Ok, I can’t argue with your policy, if you have nationalist preferences to your auditors for whatever reason. But it’s not logical for companies to have that requirement, that only local QSAs must be used. PCI-DSS never stated that. In fact, its preferable to have a QSA with regional/global experience as opposed to a local QSA. If PCI-DSS had this requirement for local QSAs to carry out audits, how can QSAs then say they have ‘regional experience’? You see the conundrum? You want an experienced QSA company, yet you want a QSA that is only local. If every enterprise in the world thinks that way, how would QSAs have regional/global experience? By that argument, then all QSAs would be local to that country – not just Malaysia – but each country would only have QSAs auditing in that country and nowhere else. And immediately you can see the fallacy and illogical argument attached to this myth. But this myth still prevails, for whatever reason (we sort of know the reason actually).

PCI-DSS requires a lot of experience. The last thing we need is a QSA with only a handful of experience and no operational idea of how to run things or recommend solutions and just rely on a checkbox and some cute marketing gimmicks. I’ve seen plenty of good auditors overseas, a whole lot better than the local ones I come across and vice versa. “Local QSA requirement?” It could be peddled by local auditors attempting to block off better equipped, or even cheaper auditors from overseas (better or worse) and really narrowing the options for their clients, who would be hemmed in by such requirement, thinking its a PCI-DSS requirement. It’s not.

If you mean by local support- that they can respond faster since they are local, then, yes, there is some sense in that. If you mean they are cheaper compared to a guy in US, then yes, but let that be a commercial decision and not a technical one. Sometimes even overseas (good) QSAs can be cheaper. Local support I agree, 100%. Nothing is more frustrating than sending a message to someone and them taking 24 hours to reply due to them being in another timezone. Local presence, local support – yes. But they technically don’t need to be a QSA. They could be consultants and there is a very good case in that. We noted it here in this article “PCI-DSS – So Why Aren’t We QSA?”. We consciously made a decision NOT to be a local QSA a few years ago to avoid possible conflict and to support our clients a lot easier and not to be bogged down by auditor responsibilities in PCI.
QSAs are a busy and itinerant lot. Aside from handling other audits, writing reports, they also need to be careful of overstepping their independent role by advising and implementing for their clients and then auditing this same control they devised.

There is really, if you come down to it, no perceivable value in saying having a “local QSA” is better or not. Having local support throughout the PCI-DSS compliance is important – and whoever is supporting should have at least the same or more knowledge than the QSA.

In some QSA Companies, they have a set up to differentiate the auditor and the consultant. Whereby the consultant is different from the auditor to ensure there is more independence. We have the same set up – PKF is the consulting arm and we deal mainly with implementation, testing and assistance of our client to get past PCI. The QSA is well, the QSA in this case, and they can do their audit without being too involved in the implementation. We know as much (and if not more, sometimes) than the QSA due to our operational experiences, and this puts us in a better position – conflict free- to get our clients certified.

So, no, in this opinion, there is no real value or even PCI requirement in having a local QSA, because that generally does not make sense and is counter-intuitive to peg a customer to only select local, less experienced auditors. Most QSAs can (and should) be able to do regional or even inter-regional work because a QSA Company, by its very nature is a regional or global company anyway (QSA pays to be auditors based on regions, and not country specific). Again, while our opinion may be biased because of the strategic decision we made years ago, we made that decision with all these considerations in mind.

Select the best QSA option based on experience, pricing and quality, not because they are local or non-local.

Real Myth 4: All PCI projects are the same (One Certificate to Rule them All)

A customer once said that we didn’t have much value and all we did was to forward their emails to the QSA for validation (not true). He said he had his team done PCI across other countries and we were just making it more complicated than necessary since they have already been experienced, implying that we hoodwinked them.

It’s very difficult to talk to people who are in this position because you can see from the onset, they do not support outsourcing advisory and consulting and they have a personal vendetta against this profession. So we don’t need to speak reason to them. In this case, we decided to pull out of the deal for advisory and all other works of implementation except for the ASV scans.

Two years from starting their PCI project on their own, and they are still in the wilderness. We ended up supporting them in any case, and perhaps their thought process had somewhat soften now because we are now finally seeing the end of the project, with us (ironically) leading them to it.

And their ‘experience’ from other PCI compliance projects? Different experience. Some were basically e-commerce SAQ A, A-EP type, some were their retail arm SAQ B or B-IP. But what they were doing in Malaysia was the outsourcing, call center and BPO – all of which involves credit card storage, processing and transmission.

Not all PCI-DSS projects are created equal.

Another company employed the ‘One Certificate to Rule Them All’ philosophy. They were providing warehouse storage facility to one of our clients, essentially storing physical copies of forms containing credit card information. So, this is a service provider, providing storage that needs to be assessed for their physical security.

They immediately told us they are already PCI compliant and they will send us the certificate. We insisted on AoC but they obliged us with their ‘certificate’ anyway, emblazoned with their QSA logo proudly, stating – SAQ C-VT Certified.

Huh? What has SAQ C-VT (merchant SAQ) got to do with the warehouse storage you are offering to my client?

Apparently that SAQ C-VT cert is from one of their parent companies overseas or something and has as much relation to our current project as me running to become the president of the United Sates. It means, One Certificate 100% does not rule them all. It’s a completely different business function and you can’t just use another SAQ or AoC from another parent/child company that is selling ice-cream cakes and had their call agent processes certified and say this applies to your warehouse storage facility half a world away!

Ok, we are halfway there, bear with us. Writing all these myths really can drag an article and you can probably read the frustration oozing out each paragraph. I’ll admit, we get extremely frustrated, but we also must remind ourselves – most of them (customers, banks – NOT QSAs, they don’t get any free passes for giving misinformation!) do not know better and they are just doing what they think it’s right or what they have been told by so called consultants or QSAs. That’s why we need to set their paths correctly so they know what options are there before them. So, we need to stop getting frustrated and blaming them for bad decisions, and get more involved in educating and providing information so they can make good decisions.

We will continue the next time once we catch our breath and go through the other wonderful misinformation on PCI-DSS we have heard over the years. Till then, drop us a note at pcidss@pkfmalaysia.com on anything to do with this standard or other standards like ISMS/ISO27001 etc.

FAQ on SAQs Once Again

Over the past few months, we have been absolutely busy with a fair amount of work. One of the things that we  have seen an uptick are merchants coming to us requesting PCI compliance. We have had some small ones, big ones and mega huge companies coming to us, but the trajectory discussion is always the same:

a) Bank wants us to do PCI

b) Bank says we are Level 2 Merchant because they say we store card data

c) Can you audit and certify us ?

I don’t blame them actually because their core isn’t PCI. Heck, most of them aren’t even into payment systems! Unlike service providers where they have a fair bit of knowledge of how payment via credit card functions, most merchants are basically: OK, give us the EDC and let’s make some money. Or set me up on my e-commerce and let’s get it done.

The Banks are obviously not helping by giving half-baked information on PCI-DSS. And PCI-SSC isn’t helping by making PCI so….confounding to the lay person.

So, here are some basic FAQs on SAQs (Self Assessment Questionnaire)

a) What Level Merchant are we?

This depends on your volume of card data being processed. Many assume that it’s more than 6 million volume (not value) transactions a year that puts you to Level 1, but actually this is defined by individual card brands. That 6 million is more popular because that’s what Visa and Mastercard go by. Amex goes by different volumes. A nice chart here can get us started:

b) Wait. We were told to be level 2 because we store credit card.

That unfortunately is not that accurate. Type of levels are defined by your volume transactions. This determines HOW you get PCI – either by a 3rd party ROC audit (level 1), a 3rd party validation on your SAQ (Level 2), or self signed SAQ (Level 3 and 4).

Whether you store credit card or not, that has nothing to do with your credit card volume. Remember – for PCI, as long as you store, process and transmit credit card, you get hit with compliance.

c) So if we are just transmitting credit card in high volume, we could be considered level 1 or 2 without STORAGE?

Yes, of course. It’s highly possible that you do not store credit card but trillions of card data flow through you, then yes, technically you would be level 1. You don’t store, which is good, but you have high volume, which determines your level, and that determines how you get PCI (either audited by 3rd party of self signed in SAQ)

d) But what if I have LOW volume but store credit card? Don’t I get bumped up into level 2 or level 1?

In theory, no. If you have low volume, then your level could be 3 (for e-commerce) or 4. Then once your level is determined and you know how to validate PCI, you need to decide what to validate to. That’s where the different types of SAQ come in. If you store credit card, you immediately have to use SAQ D, which is tough and have 340++ questions to whet your appetite over. If you do not store, then you need to understand which SAQ (there are 9 types) to apply – it could be A (which has the least questions) or C-VT (which has more, but less than SAQ D) etc. An example for A would be an e-commerce entity fully outsourcing all payment processes and pages to a PCI compliant provider.

e) So you are saying, I could be a level 1 merchant doing SAQ A because I fully outsource my payment? What do I need to do then?

If you are level 1, SAQ is out of the window. You need to get a QSA in to do a full Report on Compliance. But you can use SAQ A as an internal guideline to prepare for the audit of course, because basically the auditor will be utilising those controls if they determine that you are truly SAQ A.

f) What do you mean by “Truly SAQ A”?

In the auditing world, we can’t take your word that you are really saying what you are. It’s not that you are dishonest, it might be that there are processes you are not aware of that might for instance cause you to store data and that makes you ineligible for SAQ A. Just sayin’.

g) So basically, I can go and tell my bank they are wrong to force me to be Level 1 or 2 just because I store credit card?

Yes and No. Because those level volumes are guidelines. At the end, its the bank that’s taking a risk at you so they get the final say of what levels you need to eventually be.

h) So what’s the POINT?! 

The point is that a lot of banks have no idea on this, so they dump you into SAQ D even when your volume doesn’t add up. Or they think that you are Level 1 or 2 just because you store credit card. Both are disadvantageous to you because you end up doing more than what PCI requires. The point here is for you to head back to the bank with this information and confirm with them if they are aware of these requirement and that they are purely requiring you to go through MORE than what is required by PCI just based on their internal risk assessment of your business.

i) At the end, we are still at the same place. The Bank is telling us what to do.

Yes, but you can now reason with them further. Because if they are the only bank asking for this, merchants might look for other banks to be their acquirer. It’s business. So, at least now you know!

j) So can we go through all the SAQ types now with you?

Not really because this article is too long and I have lunch to go to. Next time maybe! Have a great 2019!

PCI-DSS: SAQ A and SAQ A-EP differences in a nutshell

OK, we are tackling this wonderful subject for the second time. We have last year touched on this through this post. Unfortunately there are still so many questions on this, that we feel that we need to re-tackle this matter again.

One response a company received regarding this issue from their payment processor was as follows (when merchant requested if they can do SAQ A-EP)

“No. SAQ A-EP you are still not allowed to transmit card data. Please have a look at below snippet taken from the SAQ A-EP AOC:

* All processing of cardholder data, with the exception of the payment page,is entirely outsourced to a PCI DSS validated third-party payment processor.

* Your e-commerce website does not receive cardholder data but controls how consumers, or their cardholder data, are redirected to a PCI DSS validated third-party payment processor.

If you want customers to enter their card data on your website you require the
PCI SAQ D.”

And so, our lengthy reply was as follows:

Your payment processor could be correct (or incorrect) depending on how your page is set up. They are sort of correct in saying you are not allowed to ‘transmit card data’. Because in the SAQ A-EP example, you serve the payment page, and then the card data is transmitted from the user desktop directly to the Payment processor. It is the way the SAQ A-EP is worded that makes it so confusing. You can clearly see that these two statements may sound like they actually conflict each other:

* All processing of cardholder data, with the exception of the payment page,is entirely outsourced to a PCI DSS validated third-party payment processor.

* Your e-commerce website does not receive cardholder data but controls how consumers, or their cardholder data, are redirected to a PCI DSS validated third-party payment processor.

If you read the above, it actually says that, all processing must be outsourced except the payment page (meaning the merchant can host the payment page). The below statement seems to shoot itself in the foot by putting in “The website does not receive cardholder data but controls how cardholder data is ‘redirected’ to a payment processor.” Unfortunately this is not the only place where PCI SSC mucks up its documentation. I can name like a dozen more times they read like its written in Hebrew and translated to English after that.

The only way to really explain is to refer to two documents I will refer to here – first, the “Understanding SAQ document” and the other is from VISA itself, the “Processing Ecommerce Payments Guide” which is what SAQ A vs SAQ A-EP is based on.

Read Page 4 of Understanding SAQ document and tell me how you interpret the table.

Its basically saying the payment page can come from EITHER the merchant website OR a PCI DSS website. As if that’s not enough to clarify, the next page, PCI even gives an example, whereby the “MERCHANT SITE CREATES THE PAYMENT FORM”. So this is clear. The payment form CAN BE IN YOUR WEBSITE.

Apparently they differentiate “receive cardholder data” and creating a payment form doing a direct post to the payment processor. Because in the form, you can send it directly to the processor to process the form posts and input, or you can process it on your own (I used for instance <form action=”PHP_SELF”> which was many years back to reprocess the form input in the same page). The latter example is what they mean by “receive cardholder data”. Not by creating the form itself, but by actually processing what the form is sending when user clicks submit.

You can process it, and then send it to the processor; or you can send it to the processor direct and have them process it.

The first one is SAQ D, the second one is SAQ A-EP. Both occasions the form is still residing on your merchant page. It is what happens after the ‘submit’ is clicked that is important.

If you want to read further, Visa has a better document, the “Processing Ecommerce Payments Guide”. In page 5, the bottom table clarifies a lot.

Basically if you are a merchant 3 and 4 doing either a direct post or javascript, with payment page sitting on your website, then you are eligible for SAQ A-EP.

Lets look at direct post in page 10 and tell me what you are interpreting.

  1. The merchant website CREATES a payment form and SENDS it to the customer computer
  2. The customer computer displays the payment form
  3. The customer enters their card data into the payment form and presses the OK button
  4. The customer computer SENDS the card data to the PSP

The red parts are all done IN YOUR ENVIRONMENT or your customer. Only in step 4 is the card data sent directly to the PSP. So yes, technically, your website is only “serving” the payment page. Once the page is ‘served’, it goes via direct post to the PSP when the submit button is clicked.

SO, in conclusion:  The key thing here is that if your website is directly processing the entries of the forms, then it falls under XML or ‘anything else’ and that’s SAQ D and your processor is correct. This is page 14 of the ecommerce payments guide from VISA. We sometimes see this in merchants who create the form, then for some reason or another prefer to process the information entered into the form and then only sends the information on its way to the processor. They don’t store it, but they process it first before shooting to the processor.

Once more, you can see this by your form. If you have a <form action=”to your own page” or current_page or whatever> then basically you are processing the form before sending to your processor. If your action is to direct to the processor site, then SAQ A-EP can be used.

Hopefully this matter is put to rest!

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