Should Your Assessor Be Your Partner?

Guest Columnist David Taylor is president of the PCI Alliance and a former E-Commerce and Security analyst with Gartner.

One of the hottest debates among people participating in the PCI Knowledge Base is whether your PCI assessor should be your partner, or should function more like an auditor.

A few of the retailers I've spoken with have cited the relationship between Enron and Accenture as an example of why they do not use their PCI assessor for remediation services, or purchase security products from their assessor. Others insist that if they are going to spend many thousands of security, they want some assurance that these expenditures will result in a "green ROC." What's the right answer?

I have also spoken to many PCI assessors about this issue. Some are very critical of other assessors who are eager to re-sell security software because they believe this compromises the integrity of the whole assessment process. Trustwave is cited most often in this regard, but maybe that's because they're the dominant assessor. Yet, the clear majority of all assessors also provide remediation services which, one could argue, amounts to the same thing: The assessor winds up signing off on their own work.

The "Assessor as Partner" argument makes a lot of sense: Why should a merchant spend, say $500K in order to achieve PCI compliance, only to have a PCI assessor tell them, after they spent the money, that they can't sign of on the control, because something is not right? By having the assessor design the controls, and even implement the security software, the merchant is at least assured of a passing grade.

The merchants who say "This is Enron all over again" also have a point. If a breach should occur, then the merchant's decisions will all come to light and if a government agency or a court were to find that the merchant wasn't working to proper oversight and an objective review of their security systems and procedures, that could result in some negative publicity and associated fines.

Most merchants I've interviewed for the PCI Knowledge Base have switched assessors at least once. Part of the reason is to find an assessor who "shares their view" of the assessment process and the interpretation of specific controls. Some assessors are former auditors and insist on an arm's length, objective relationship, and will not provide remediation products or services to an "audit client." Other assessors have a technical or consultative background, and emphasize that they are partners with the merchant. Background and perspective are important things to ask a prospective assessor.

Here's the Best Practice: I've talked to two different retailers who have the same best practice when dealing with assessors. They have a questionnaire that they use to interview assessors, to test for "compatible interpretations" of PCI standards, as well as technical acumen. They then find two assessors with similar perspectives, and have one of them do the assessment, and the other provide the remediation. Although some larger assessors have two different divisions for this, these two merchants said that this approach is more objective and "audit proof" if bad things should happen. We recommend this approach to all who read this. If you wish to discuss this or any other security or compliance topic, send E-mail to [email protected].