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Re: [Dataloss] Visa Puts Heartland on Probation Over Breach

From: Jamie C. Pole (jpolejcpa.com)
Date: Fri Mar 13 2009 - 09:11:03 CDT


Just a quick clarification...

I was not trying to say that ALL QSA provides were incompetent.
However, I do feel obligated to say that the overwhelming majority of
the ones I have worked with have displayed a level of competence and
technical acumen that was far below the level at which I would
consider hiring someone for an entry level position in my firm.

My problem with the QSA program is very simple - I believe that it's a
pay-to-play scheme. If I was a construction contractor, and I was
asked to pay a fee to be able to bid on city or state construction
contracts, that would be considered an act of corruption. The
official would get in trouble for asking for the fee, and I would get
in trouble for paying the "bribe".

I believe that a certain governor was just removed from office for
playing this kind of game.

By making the QSA process a pay-to-play scheme, the PCI people have
ensured that the QSA population will not be representative of the
population of security professionals as a whole.

Put another way, wouldn't any CISSP that paid the QSA fee be in
violation of the ISC2 Code of Ethics? If a pay-to-play scheme is
criminal-enough to get a governor impeached and removed from office,
how is it not criminal enough to violate the Code of Ethics?

Let's be perfectly clear - the QSA program is not some kind of vendor
partner program where you pay to get priority access to support or
resources. A QSA is paying for the ability to enter into a captive
market. Technical acumen or experience does not matter - all that
matters is whether or not the check clears. I wonder if they publish
statistics on the percentage of QSA applicants that are turned down?

Just something to think about...

Obviously, this is not the entire problem with PCI, but it is
definitely a significant part of it. Any process will only be as good
as the people that administer it.

Jamie

On Mar 13, 2009, at 8:38 AM, lyger wrote:

>
> (courtesy Anthony M. Freed)
>
> http://information-security-resources.com/2009/03/13/visa-puts-heartland-on-probation-over-breach/
>
> *Removal from Visa~Rs List of Compliant Service Providers - Visa has
> removed Heartland from its online list of Payment Card Industry Data
> Security Standard (PCI DSS) compliant service providers. HPS has
> advised,
> however, that it is aggressively working on remediation and re-
> validation
> of its systems to comply with PCI DSS standards. The company will be
> relisted once it revalidates its PCI DSS compliance using a Qualified
> Security Assessor and meets other related compliance conditions.*
>
> *System Participation - HPS is now in a probationary period, during
> which
> it is subject to a number of risk conditions including more stringent
> security assessments, monitoring and reporting. Subject to these
> conditions, Heartland will continue to serve as a processor in the
> Visa
> system.*
>
> [...]
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>
> CREDANT Technologies, a leader in data security, offers advanced
> data encryption solutions.
> Protect sensitive data on desktops, laptops, smartphones and USB
> sticks transparently
> across your enterprise to ensure regulatory compliance.
> http://www.credant.com/stopdataloss
>

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CREDANT Technologies, a leader in data security, offers advanced data encryption solutions.
Protect sensitive data on desktops, laptops, smartphones and USB sticks transparently
across your enterprise to ensure regulatory compliance.
http://www.credant.com/stopdataloss