"Careless" Systems Integrators Now Directly Under PCI DSS

A 403 Labs QSA, PCI Columnist Walt Conway has worked in payments and technology for more than 30 years, 10 of them with Visa.

Mistakes made by careless or incompetent payment application installers or system integrators have led to far too many data breaches over the years. In each case, even though the reseller or integrator made the mistake, the merchant bore the ultimate responsibility.

Unfortunately, system resellers and integrators formerly fell in a governance gap in PCI, and their actions were outside the PCI Council's jurisdiction. I say "were," because that situation is about to change, and merchants are the ones who will benefit the most. Beginning later this year, system resellers and integrators will be held to training and testing standards as high as merchants and service providers. The winners will be merchants, for sure, but those competent system resellers and integrators will also find their high standards rewarded.

The PCI Council is in the process of rolling out a new program to train and approve (certify?) software resellers and system integrators. The Council will list on its Web site those organizations and individual employees who pass the training and meet its standards. The Qualified Integrator and Reseller (QIR) program is designed to improve merchant security, reduce risk and achieve PCI compliance. This program may prove to be one of the most significant developments since the introduction of the Payment Application Data Security Standard (PA-DSS).

As with any program, the burden ultimately rests with merchants to make this work. Merchants, as I have pointed out many times, can outsource the installation and maintenance of their payment applications, but they cannot outsource their responsibility. That fact has not changed: If your system is breached and you lose cardholder data, it is the merchant's breach regardless of who installed the system. What is changing, however, is that the QIR program will give merchants the information and resources they have needed to have confidence their payment application is securely installed and maintained.

The QIR program will be particularly great news for small and midsize merchants, franchisors and their franchisees. It also will be welcome news for the many software resellers and system integrators who perform quality work for their customers and take security seriously. Although most resellers and integrators are competent, the reality is that some are not. And when a system is installed improperly or insecurely, the merchant pays the price.

The PCI Council is talking about the QIR program in "open mic" sessions for Participating Organizations. It also recently shared program details at a briefing for QSAs. Based on that QSA briefing, here is how we can expect program to work.

The Council will issue a QIR Program Guide by mid-year. This guide will spell out the implementation lifecycle and detail responsibilities for both the merchant and the reseller/integrator. QIR companies will be required to have an internal quality assurance (QA) program that double-checks the work of each individual installer.

After the implementation, the QIR will provide to the merchant a written report documenting that the software was installed securely and according to the software vendor's PA-DSS Implementation Guide. Merchants will retain that report to show their QSA and/or processor and as evidence of the payment application's proper implementation.

Approving QIR companies alone would be a positive step, but the PCI Council went further. Each individual employee who installs payment applications needs to be trained and tested to be included in the program. Merchants will be able to check that the particular individual who shows up to implement their payment software, configure their firewall, and configure encryption and key settings knows what he or she is doing. Merchants also will understand their responsibilities for maintaining the application and supporting the implementation.The QIR program will be modeled closely on the current QSA program. That is, there will be QIR companies and individual QIRs, who will be the people installing the application. QIR employees will go through PCI Council training (which is under development) and take a written exam. Approved QIR companies, together with individual qualified installers, will be listed on the PCI Council's Web site.

The message for merchants is clear: If you use a software reseller or system integrator, make sure the company and the person who shows up on your doorstep to install the application are both on the QIR list. If they are not, you cannot be certain that your PA-DSS validated payment application is properly implemented.

Merchants will determine whether the whole QIR program will succeed or fail. There will be no PCI Council or card-brand mandate (more on this later). Merchants will be encouraged to use QIRs listed on the Council's Web site, to follow the program guide and, importantly, to read the program guide and maybe look over the shoulder of their implementer.

It will be interesting to observe how this program unfolds and how the market reacts. One wild card is price: Will it cost more to have a QIR implement a payment application? QIRs will have some added costs—I'm sure the PCI Council will charge for QIR training and listing. Will QIRs absorb these costs, or will they pass them along in the form of higher prices?

Could we see a two-tiered market where merchants can have a QIR install their application for one price or have a less qualified, less experienced, less professional person do it for a lower price? If we have a two-tiered market, how will merchants react, particularly small merchants, who may be more price sensitive and less security aware.

Another wild card will be how the software application developers themselves react. Will they insist that their resellers be QIRs? It makes sense that software vendors would take this step to ensure the quality of their product and brand in the marketplace. It also costs the software vendor nothing, because the reseller or integrator will pay the training and listing fees.

Will QSAs and processors accept the QIR's report of a secure implementation at face value? If a report is challenged, I have to believe the QSA's opinion would still carry the day. But it certainly would lead to some touchy discussions between the QSA and his or her merchant.

Lastly, although neither the Council nor the card brands will mandate using QIRs (as noted above), will processors insist that merchants prove they used a QIR? Or will the QIR report be required as part of each merchant's Self-Assessment Questionnaire (SAQ)? The PCI Council is in its feedback period, and I get the impression that the SAQs, too, are fair game for revision and updating to reflect both new programs and current attack vectors. Visa and MasterCard have already mandated PA-DSS-validated applications for those merchants who use packaged payment applications. Will the PCI Council and the card brands similarly mandate QIR implementation where resellers or system integrators are used?

Clearly, there are lots of questions, as is expected with any new program. Nevertheless, none of these questions detracts from the fact that the QIR program is a very positive development for merchants. I understand that the PCI Council consulted with leading software vendors, system resellers and system integrators as it developed the QIR program and guidelines. Hopefully, when the program is implemented it will reflect best practices and reduce data compromises at merchants, franchises and franchisors.

What do you think? Do you use a system reseller or integrator? Would you pay a little more to have a QIR do your installation and provide you with documentation? I'd like to hear your thoughts. Either leave a comment or E-mail me.