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PCI Gurus?
From: shankl () hotmail com
Date: 14 Jan 2011 06:06:23 -0000

Heres a little scenario that I wanted to throw out there and get an opinion on by someone who knows PCI. I am starting 
to learn but couldn't help with this problem because I've never assisted in a PCI audit...
(I would think this problem has been encountered by many small companies that make network appliances)

====== Background =======

1) Company A is a small company (only 5 employees)

2) They provide a service which requires their customer, Company B, to install a small network appliance on their LAN 
in order to collect data from their onsite mechanical equipment.

3) Operating data is then pulled from these mechanical systems and then dumped to a remote server which processes the 
data and provides a dashboard for the customer to view (via SSL).

4) Company B bought a license for this service and was also handed over the keys to administer accounts and decide 
which employees it would like to give access to.

5) Now let’s say that Company B typically processes credit card payments locally and sends transaction data through 
their local LAN on its way out to their payment processor. 

====== Problems =======

1) Company A does not take credit cards and is not required to be PCI compliant however they do provide a service which 
requires their network appliance to be installed on Company B’s network.

2) In recent days Company A has come to the conclusion that in some of Company B’s newly acquired satellite offices, 
credit card data is being forwarded across the LAN in a variety of ways (some of which do not look to be 

3) In addition, several of these satellite offices are running consumer grade routers (ie: Linksys, Netgear) providing 
little in the way of segmentation. 

4)Company A would like to avoid being “In Scope” and having to charge the client for consulting fees. 

====== Questions =======

1) For the smaller satellite offices what might be a simple fix?

2) Does segregation provide an easy way to kick devices out of scope for PCI audits?

3) Would it be recommended/possible to have a firm produce a report which could be handed to an auditor and prove “Out 
of Scope” prior to being dragged into one of these audits? 

4) Could the network appliance be designed/situated in such a way as to be “out of scope” or at least easily verifiable 
as compliant even if it was sitting on the same logical subnet where the card data traffic was moving across?

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