--- On Mon, 7/27/09, Michael Graham <jmgra...@gmail.com> wrote:

> PCI means well, and it's relevant (and sometimes useful) at the
> smaller merchant levels because many of them will just
> ignore security concerns otherwise, but it's _well_ past time that we in
> the security profession stopped acting like PCI has anything to do with
> security posture or risk exposure in large or high-volume
> companies.

I still think PCI is fine for what it is, but confusing it with "all I need to 
do to secure myself" is the problem.  What the DSS is is a 
least-common-denominator of some of the things that should be done, as could be 
agreed to by a committee of lawyers.  As far as that goes it is correct: you 
should in fact have a firewall, configure it, separate data....  But thinking 
that achieving PCI compliance is all anyone needs to do - particularly, as you 
say, in large shops - is rank madness.

I'll take them at their word that they passed a PCI audit, the SSC will be 
extremely cranky with them if they say they did when they didn't.  But I would 
want them to have at least setup serious monitoring of traffic (as is not 
required by PCI) and preferably application behavior if at all possible, too - 
which is highly unlikely what they did.

I'm thinking you could argue that the DSS actually makes things worse by 
lulling folks into a false sense of security, but I'm willing to be that these 
same folks would have done no more (and maybe less) without it...

-chris


      
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