Blackboard is a level 1 service provider, a hosting provider, a level 3 
merchants and a PA-DSS application developer.  I am actually in the middle of 
my on-site audit for the service and hosting provider portions.  It is far more 
in-depth and picky then it has been in the past.  Considerably more 
documentation, testing and narratives have been involved as well as several 
discussions on increase in scope (which I am arguing... the first rule of PCI 
is segment to limit the scope and expanding it outside turns the whole thing on 
its head).  So regardless of your level of PCI touch points, the council is 
really cracking down.  The Heartland breach scared the hell out of everyone.

At the merchant level obviously the direct oversight is less.  The risk falls 
to your acquiring banks and processors.  If you do not complete the SAQ or if 
after a breach you are found to be non compliant you may lose your merchant 
status and your acquiring banks and processors could face significant 
consequences.

Fudging the SAQ is not a good idea.  It's very much like software piracy; you 
may get away with it for a long time or maybe forever but the consequences are 
severe if you get caught.

And just as an aside the automatic jump after a problem to level 1 requiring an 
onsite assessment is a nightmare.  We're required by virtue of our service 
provider status (we operate our own payment switch for our transaction/commerce 
LOB clients) but it is incredibly painful and as of this year competing with 
SOX for things that gray my hair, increase my blood pressure and make me a fan 
of scotch.

-rd

-----Original Message-----
From: [email protected] [mailto:[email protected]] On Behalf Of Brad 
Knowles
Sent: Wednesday, June 03, 2009 11:44 PM
To: Tracy Reed
Cc: [email protected]
Subject: Re: [lopsa-tech] PCI-DSS: Is this for real?

on 6/3/09 2:08 AM, Tracy Reed said:

> So what has your experience with PCI been? Is anyone really enforcing
> it on level 3 merchants?

I know a guy who works at cybersource.com, which is located here in
Austin.  They specialize in outsourcing eCommerce payment solutions and
PCI compliance, and have recently bought authorize.net, which is one of
the best known small business payment handling systems.

He told me that Visa has recently really started cracking down, and that
has caused a *huge* increase in the amount of work being sent their way
-- way too many companies have decided they just can't handle PCI
compliance internally.


Regretfully, that's all I really know on that subject.

--
Brad Knowles <[email protected]>
LinkedIn Profile: <http://tinyurl.com/y8kpxu>
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