Sep 11 2012

Scoping was too scary to handle

Published by at 5:25 am under PCI

One of the biggest challenges for a QSA is deciding the exact limits of an assessment.  Deciding which systems store, process or transmit credit cards and all systems connected to them sounds like a straight forward and easy to follow, but in practice, the QSA’s two favorite words, “It depends” come into effect all to often.  Drawing the lines around the systems that store or process card data is fairly easy, but when you get to the ‘transmit and all systems connect to them’ it get’s a lot fuzzier.  Not only is it hard for a QSA to make those judgements, it can also be hard to argue with the customer about the specifics of scoping.  And it can cause some very, very heated arguments.

So when i heard that the PCI Council had a Special Interest Group formed specifically to create a Scoping Toolkit, I was excited and filled with trepidation at the same time.  I knew or had worked with many of the people who were involved with and leading the effort.  This gave me hope that the PCI Council would be releasing something that would give QSA’s a good platform to base their scoping decisions.  But from the first time I talked to the people who were working on the scoping document, I discovered that the Scoping Toolkit would probably never see the light of day; apparently this group put the ‘Special Interests’ in SIG.  What one member of the group thought was absolutely necessary was anathema to another member at almost every turn. The entire effort was doomed from the start, with rabbit holes of edge cases and ‘what ifs’.

The Scoping Toolkit never did get released by the PCI Council, but the Open PCI Scoping Toolkit has been released.  While it’s not an official document from the Council or even one that’s being publicly acknowledged by them, it’s an important piece of reading for any QSA to dig into, especially on the plane flight to his or her next on-site assessment.  As Walter Conway says, it addresses the three fundamental scoping questions, gives the QSA a better understanding of how other QSA’s might scope the client, and gives the QSA more ground to stand on when explaining their decisions.  And anything that helps take the variation between QSAs out of the assessment process is a good thing.

I’m glad this document finally got released into the wild.  I know a lot of hard work and sweat went into hammering out these guidelines and they can help stabilize some of the ongoing concerns about PCI and the variation in scoping between QSAs.  It’s too bad that the PCI Council couldn’t step up and endorse the document directly, but I’m glad they’re not standing in the way of it getting published either.  Which gets them the best of both worlds; the Scoping Toolkit gets published and they don’t have to stand behind it as an official document.  All the upside, none of the liability.  We wouldn’t want them to actually make a stand and improve the overall security of the merchant community, now would we?

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