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RE: PCI Compliance required if outsourcing?
From: Craig Wright <Craig.Wright () bdo com au>
Date: Thu, 12 Jun 2008 08:45:06 +1000

Outsourcing does not move risk. Your company is responsible for being compliant whetrher or not the outsourcer is. On 
top of this, hosting providers have a number of additional requirements that they need to fulfil. The following are 
required from a hosting provider:

A.1.1 Ensure that each entity only has access to own cardholder data environment
A.1.2 Restrict each entity's access and privileges to own cardholder data environment only
A.1.3 Ensure logging and audit trails are enabled and unique to each entity's cardholder data environment and 
consistent with PCI DSS Requirement 10
A.1.4 Enable processes to provide for timely forensic investigation in the event of a compromise to any hosted merchant 
or service provider

Also Note:
"Even though a hosting provider may meet these requirements, the compliance of the entity that uses the hosting 
provider is not necessarily guaranteed. Each entity must comply with the PCI DSS and validate compliance as applicable."

So you need to contract PCI into the agreement, but this does not pass the risk. If the outsourcer fails, your company 
is still non-compliant and can be hit with the fines.

Craig Wright GSE-Compliance GPCI

Craig Wright
Manager, Risk Advisory Services

Direct : +61 2 9286 5497
Craig.Wright () bdo com au
+61 417 683 914

BDO Kendalls (NSW-VIC) Pty. Ltd.
Level 19, 2 Market Street Sydney NSW 2000
GPO BOX 2551 Sydney NSW 2001
Fax +61 2 9993 9497

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-----Original Message-----

From: listbounce () securityfocus com [mailto:listbounce () securityfocus com] On Behalf Of Eggleston, Mark
Sent: Wednesday, 11 June 2008 6:29 AM
To: security-basics () securityfocus com
Subject: PCI Compliance required if outsourcing?

Hello PCI experts,

I've seen a lot of info re: PCI on this listserve and was wondering if
someone can help me.  If a company chooses to outsource PCI compliance
to a vendor, what are the PCI regulation requirements?  Specifically, if
a company uses a vendor/outsources for card payment processing what are
the compliance ramifications?  From what I can tell section 12 applies:

"If cardholder data is shared with service providers, then contractually
the following is required:
12.8.1 Service providers must adhere to the PCI DSS requirements
12.8.2 Agreement that includes an acknowledgement that the service
provider is responsible for
the security of cardholder data the provider possesses."

Anything else here to be concerned with?


Mark Eggleston
Manager, Security and Business Continuity
Information Services
(215) 991-4388
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