PCI DSS pre-assessment: Managing the process to limit liability

Conducting a PCI DSS pre-assessment can save quite a few headaches later on in the compliance process. However, it can create a lot of new ones if it isn't managed with liability in mind. Contributor Rick Lawhorn offers a brief primer on the pre-assessment process and explains why financial services firms should seek out participation from their legal departments.

Financial institutions that handle credit card transactions must comply with the Payment Card Industry Data Security Standard (PCI DSS). As a part of the compliance process, most financial companies will conduct a pre-assessment audit prior to the official PCI audit to discover and remediate problems before they turn up in the real audit.

These pre-assessments not only help build a baseline to ensure that compliance is achieved as efficiently as possible, but can also highlight findings that may be a liability for the company if not handled properly. This tip will briefly outline the pre-assessment process and explain what to do when less-than-desirable results turn up.

The pre-assessment process explained
Performing a pre-assessment prior to the anticipated visit of the PCI Qualified Security Assessor (QSA) is an extremely valuable exercise. The pre-assessment will help an organization identify and learn about existing gaps between its current security posture and the PCI DSS. In addition, it will provide a head start for organizations in remediating identified gaps prior to the official PCI audit.

In planning a pre-assessment audit, there are a number of factors that need to be considered. First, determine the PCI level the issuing bank has assigned to your organization. This level is based on the volume of transactions that occur over a certain time period. Identifying your level will assist in developing the appropriate breadth and depth of the pre-assessment engagement. Next, you will want to schedule enough time to allow for your organization to internalize the findings and complete the remediatation work. Additionally, factors such as the number of systems and processes to review and the depth of testing can be used to estimate the time and cost associated with the pre-assessment activity.

The process of selecting the right partner to conduct a pre-assessment is also critical. Many financial institutions will look for a trusted advisor to assist in translating the risks to the executive team in order to make the most cost efficient decisions. Other financial institutions will want to change third-party auditors each year to have variations in approach and, thereby, variations in potential findings. No matter which method works best for your organization, the services offered by a third-party auditor should include on-site reviews of IT infrastructure, network design, application architecture and policies. Upon concluding the pre-assessment audit, an initial gap analysis and recommendations report should be provided to define the scope, findings and prioritization of remediation activities.

Once a pre-assessment is conducted and the pre-assessment team validates the findings, they must be presented and understood by the executive team. Executives are ultimately responsible for correcting or mitigating issues identified in the pre-assessment. Conversely, if the executive team chooses to accept certain risks instead of taking corrective action, the analysis and decisions have to be documented, in case PCI auditors later note a discrepancy about any control objectives.

For more information:
 Mike Chapple reviews how PCI DSS has changed and how these changes will affect compliance and business processes

In this tip, Roger Nebel unveils how corporations can comply with Requirement 3.1 of the PCI DSS.

Learn why a consistent compliance program that adheres to basic principles can ease the compliance process.

Managing pre-assessment findings
Even with a pre-assessment, there are important legal considerations to plan for. A best practice is to start by officially asking your organization's legal team for advice on conducting a pre-assessment. Make sure the legal team is involved at an early stage -- prior to having any discussions with third-party companies -- to ensure that the final results will be protected appropriately, namely from future discovery requests that may reflect negatively on your organization or its security posture. For example, the legal team may position items so that they hire the third party to aid in the legal work. By doing so, the producer of the pre-assessment results will report directly to the legal team confidentially and can be protected from future discovery.

Failing to protect pre-assessment results early in the process can have dire results at a later date. For instance, if the company is involved in litigation involving a breach or identity theft, a discovery request may cause the results to wind up as "exhibit A" in a future lawsuit.

After pre-assessment remediation
Based on the final outcome of the pre-assessment and the remediation work identified and completed, the internal legal team would have the opportunity to extend the protection of the pre-assessment findings. This will allow your organization to determine if the pre-assessment findings would be made available to the PCI auditors during the official audit.

Without question, a financial services firm puts itself in the best possible position to manage pre-assessment results, both in the short term and the long term, by including the legal team from the earliest stages of the process. You will discover that your PCI compliance objectives can be met and the legal liability to the company can be kept in check while building better compliance life cycle management into the process.

About the author:
Rick Lawhorn, CISPP, CISA, is the chief information security officer (CISO) at PlanIT Technology Group and previously was CISO for GE Financial Assurance and Genworth Financial. He has more than 17 years of experience in information technology including extensive security experience, and has created a working group focused on developing meaningful metrics for CISOs. He can be reached at rick.lawhorn@mac.com.


This was first published in June 2008

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