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RE: PCI Compliance required if outsourcing?
From: "Daniel I. Didier" <ddidier () netsecureia com>
Date: Thu, 12 Jun 2008 14:31:17 -0400

You've provided some excellent information.  It seems many organizations
believe that if they outsource, they have no risk.  As you've pointed
out, this is not the case and organizations need to be aware of this!


-----Original Message-----
From: listbounce () securityfocus com
[mailto:listbounce () securityfocus com]
On Behalf Of Craig Wright
Sent: Wednesday, June 11, 2008 6:45 PM
To: Eggleston, Mark; security-basics () securityfocus com
Subject: RE: PCI Compliance required if outsourcing?

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
A.1.2 Restrict each entity's access and privileges to own cardholder
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
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
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
risk. If the outsourcer fails, your company is still non-compliant and
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
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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,
a company uses a vendor/outsources for card payment processing what
the compliance ramifications?  From what I can tell section 12

"If cardholder data is shared with service providers, then
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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