Properly Mobilizing the PCI Resistance: Lessons Learned From Fighting Prior Wars (SOX-404)"
I have noticed that there is a growing wave of discontent and disenchantment from information security and compliance practitioners around the PCI DSS. Josh Corman has been an effective voice for these concerns, providing an intellectually honest and earnest analysis in his talk “Is PCI The No Child Left Behind Act For Infosec?”
The problem are well-known and significant: too much ambiguity in the PCI DSS, Qualified Security Assessors (QSAs) and consultant using subjective interpretations, existing guidance either too prescriptive or too vague, scope missing critical systems that could risk cardholder data, overly broad scope and excessive testing costs, excessive subjectivity and inconsistency, poor use of scarce resources, no meaningful reduction in risk of data breaches, and so forth.
For years, I have been studying the PCI DSS compliance problem, as well. I have noticed many similarities to the PCI compliance challenges and the “SOX-404 Is The Biggest IT Time Waster” wars in 2005. I was part of the leadership team at the Institute of Internal Auditors (IIA) where we did something about the it. We identified inability to accurately scope the IT portions of SOX-404 as the root cause of the billions of dollars of wasted time and effort, while not reducing the risk of financial misstatements.
I propose to present the two-year success story of the IIA GAIT project and how we changed the state of the IT audit practice in support of SOX-404 financial reporting audits. We defined the four GAIT Principles, which could be used to correctly scope the IT portions of SOX-404. We mobilized over 100K internal auditors, the SEC and PCAOB regulatory and enforcement bodies, as well as the external auditors from the 8 big CPA firms (e.g, Big Four and other firms doing SOX advisory work). In short, we made a difference, in a highly political process that involved many constituencies.
I am attempting to do something similar with the PCI Security Standards Council, through my work as part one of the leaders of the PCI Scoping SIG (Special Interest Group). My personal goal is to find a “third way” to better enable correct scoping of the PCI Cardholder Data Environment, and create a risk-based approach of substantiating the effective controls to ensure that cardholder data breaches can be prevented, and quickly detected and corrected when they do occur.
My desired outcome is to find fellow travelers who also see the pile of dead bodies in PCI compliance efforts, and work with those practitioners to catalyze a similar movement to achieve the spirit and intent of PCI DSS.
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