How Many Will Join The Lone Systems Integrator On PCI's New List?
A 403 Labs QSA, PCI Columnist Walt Conway has worked in payments and technology for more than 30 years, 10 of them with Visa.
The PCI Council's Qualified Integrator and Reseller (QIR) program is officially up and running. Reliant Security is the first systems integrator to qualify under the QIR program and be listed on the PCI Council's Web site. Qualifying the first systems integrator is a significant milestone, one that follows last May's announcement of the QIR program and the beginning of formalized training this past autumn.
What everyone involved in retail payments will now want to see is how many other resellers and systems integrators will join Reliant. The ultimate success of the QIR program depends on the decisions made by retailers, payment application vendors and, quite possibly, the PCI Council and even the card brands, too.
The QIR program's objective is to provide training and qualification on the secure installation of payment applications that are validated by the Payment Application Data Security Standard (PA-DSS) to facilitate the merchant's PCI DSS compliance. The program exists because of two realities. The first reality is that a PA-DSS-validated application will simplify compliance only if it is installed and managed according to the vendor's PA-DSS Implementation Guide.
The second reality is that retailers and other merchants specialize in doing what they do best: sell stuff. That means they know about as much about implementing a payment system as I do about heart surgery.
Therefore, retailers and other merchants rely on systems integrators and software resellers to implement their payment applications and help them achieve and maintain PCI compliance. This system only works, however, if the integrator or reseller knows what it is doing. Sadly, experience tells us that is not always the case. As a result, merchants suffer costly and reputation-damaging data breaches.
The QIR program is designed to fix all this by training and testing companies and their staff so they can install payment applications securely. Will the program succeed? I hope so, but we will know the answer to that question once we know the answers to the following questions first.
Becoming a QIR is an investment (more on this below), and the integrator or reseller will want to see a return on that investment in time and money. I had the chance to speak with Mark Weiner, the president of Reliant Security, and he told me he hoped his company's QIR imprimatur would be a competitive advantage. I can't tell you how much I hope he is right. Whether that is the case won't be up to me, or any QSA, though. It will be up to retailers and other merchants to insist on a higher standard from their systems integrators. It is in the merchant's own self-interest, because they are paying for the implementation. Hopefully, education and support from industry associations like the National Retail Federation and the National Restaurant Association, in addition to large franchisors, will get the QIR word out—especially to smaller Level 4 merchants and franchisees.
If I have a software product and I end up in the headlines because merchants using it get breached, it cannot be too good for my business. Therefore, software vendors, too, have a stake in ensuring the success of the QIR program. On the one hand, they can work with their current resellers to encourage them to become qualified. That's the "pull" effect.A possibly more interesting "push" effect will happen when resellers and systems integrators who are QIRs pitch their qualifications to the software vendors. Will the QIRs push out some current resellers who are not so qualified? I think anyone can tell where this QSA's hopes lie, but it will be up to the software vendors. It will be interesting to see if and how software vendors use the QIR program to differentiate their own product offerings.
I can think of one way the card brands can support the QIR program: subsidize some of the cost, at least in the first few years. Based on the pricing on the PCI Council's Web site, a reseller with two qualified employees can expect to pay about $3,000 the first year and $2,400 each subsequent year. For a reseller with, say, five staff members to qualify, the cost is $6,000 initially and about $4,500 each subsequent year. There is a substantial discount for Participating Organizations, but that membership cost, too, is increasing this year.
These are only the out-of-pocket costs, and as Reliant's Weiner pointed out to me, the internal staff costs in time and resources to become a QIR can be higher. For some resellers the costs may not be too great, especially if they gain a competitive advantage, as I hope they will. But for some others it may be a barrier to having all (instead of just a few) installers qualified.
Because the ultimate beneficiaries of increasing PCI compliance and reducing cardholder data breaches are the card brands, could they consider footing part of the bill for becoming a QIR? It seems like this idea might merit at least some discussion among the card brands.
I give a lot of credit to the PCI Council staff for taking the lead with this program. I have spoken with a lot of QSAs—some of whom E-mailed me when I first wrote about the QIR program—and their support is very broad. A possible way to expand the number of QIRs quickly might be to allow trade or industry organizations to offer their own version of QIR training. Training fits with the associations' own charters, their costs may be lower and the competition with the official PCI Council's training could keep pressure on price.
Regardless of the training, all QIRs must pass the same test to guarantee the same high standard, and the PCI Council must control that test. The PCI Council could track pass and fail rates for each association and then assess whether they are doing a good job.
The QIR program is an important step to protect retailers and all merchants. The first QIR has come to the dance. Now we have to wait and see if retailers, software vendors and maybe even the card brands, among others, will come to the dance, too.
What do you think? I'd like to hear your thoughts. Either leave a comment or E-mail me.