Yes, Virginia, We Really <i>Do</i> Need A QIR Program

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

After my last column about the PCI Council's Qualified Integrator and Reseller (QIR) Program, reaction was unusually strong on both sides. And readers did force some questions to be addressed. For openers: Was it really necessary for the PCI Council to launch this program?

Bob Russo, general manager of the Council, said the program was "sorely needed, as evidenced by the number of data breaches" that happened due to implementation errors made by third parties such as system integrators and resellers. Russo pointed out that merchants buy Payment Application Data Security Standard (PA-DSS) validated applications to be secure, but those applications can't provide the intended security if they are not installed and maintained properly.

Russo's response reinforces what QSAs (including those who wrote to me, all of whom enthusiastically support the program) see too often: retailers spending good money hoping to get a secure payment application only to find out it has not been installed according to the vendor's PA-DSS Implementation Guide. QSAs, acquirers and forensic investigators see shortcuts—for example, using the same passwords across multiple installations or leaving debug logs enabled (recording all transaction details)—that supposedly make troubleshooting easier. But these sloppy practices put retailers at risk. Too often, the result—confirmed by published data breach statistics—is that the retailer risks a business-threatening data breach. Anyone wondering why the QIR program needs to exist only has to look at the numbers.

The next question I got from two readers was: Why did the PCI Council act in a vacuum and develop the QIR program on its own? Why didn't the Council reach out to trade organizations or other groups who have training programs already? Russo's reply was direct: The Council did work with not one or even two but a range of industry parties to develop the QIR Program. Russo, who appeared surprised at the question, said: "The Council created a task force that included representatives from the card brands, software vendors and acquirers. The task force received a series of briefings from forensic investigators and others on the sources of data breaches. They heard about the risks. Software vendors and their trade group representatives were an integral part of the QIR task force. They provided a lot of valuable feedback."

So much for the program being developed in a vacuum.

As to why the Council felt it needed to develop its own training and testing program, Russo said: "We want to concentrate on benefitting retailers. More training for integrators and resellers is a good thing, and any program that helps them do a better job installing applications correctly is better for everyone."

Russo was being a bit more diplomatic about the need for more training than I might have been.Russo was being a bit more diplomatic about the need for more training than I might have been (which is probably why he has his job and I have mine). You can't argue with the numbers. It should be obvious that any industry associated with three-quarters of reported security breaches in a year needs to do something differently than whatever it is doing today. That is not to say existing training programs should be dismissed, but clearly they are not very effective—at least by themselves. Whatever is available today is not working, and it is the retailer who pays the price. That's why the Council is launching—and retailers should be happy about and I am a fan of—the QIR program.

By now, I hope that everybody understands the need for a QIR program.

A couple of comments and E-mails asked about the next logical question: How much will QIR training cost? One person added: Is the PCI Council doing this just to raise money? Russo responded: "The pricing for QIR training is not yet finalized. The purpose of the program, though, is not aimed at raising dollars. You are asking the wrong question. We need to find a way to solve some of the problems we see. This [QIR training] is sorely needed, as evidenced by the data breach statistics. Acquirers, the card brands, everybody understands this is an area that really needs to be addressed. We are looking at ways to solve some of the problems facing retailers. Our objective is to make the training as accessible as possible so everybody who installs a PA-DSS application knows how to do it correctly. We want to open the class to the largest number of people as we can."

The final question I asked Russo was: What will the training look like? He told me the details are still being worked out. But it will be an online course, so nobody should have to travel. It will last approximately one day, and it will include a test. The training should be available by this summer, with the first QIRs listed on the Council's Web site shortly thereafter. Plans for annual retraining and revalidation (similar to what QSAs go through) are still being developed.

The Council is counting on the members of the QIR task force to help spread the word. It also launched a QIR landing page on its Web site. Russo plans to host a Webinar on the QIR Program for resellers and integrators in July. In the meantime, resellers, system integrators and any retailers (or QSAs) who are interested should point their browsers to that page and monitor developments directly.

In case it is not obvious yet, I continue to be a fan of the QIR program for one simple reason: It should benefit retailers, particularly small and midsize retailers who lack the technical expertise to install and maintain complex payment applications.

If you are a retailer, what do you think? I'd particularly like to hear your perspective on this program. Either leave a comment (and thanks to those of you who take the time to do so) or E-mail me.