
Check-off PCI requirements! Learn how to get the low-hanging fruit with a free, on-demand webcast: "Security Testing: The Easiest Part of PCI Certification." You'll see how security testing with CORE IMPACT provides compliance with Requirement 11.3 and validates multiple other PCI mandates for successful compliance audits. View the webcast now
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Maintaining your PCI compliance and managing the assessment process are challenging even when you have a solid security program. Everything from a bad assessor to a rogue business unit to simple documentation mistakes can derail the process and increase costs. Based on conversations with hundreds of security professionals, here's my list of the top five mistakes to avoid when managing PCI DSS assessments:
Mistake #1: Not interviewing your assessor. While they may graduate from certified training courses, not all Qualified Security Assessors (QSAs) are created equal. One of the most common complaints among organizations struggling with a bad assessment cycle is an uninformed or disorganized QSA. When interviewing a potential QSA, it's important to evaluate both their technical knowledge and their project management skills/philosophies. Make sure the person you are interviewing will be the one actually assigned to your project.
Mistake #2: Failing to prepare before the assessment starts. If you talk with QSAs, one of their most common complaints is unprepared clients. QSAs will arrive to begin an assessment and a project team isn't set up, there's no current documentation, and no one has contacted the key business units involved with the assessment. Before your assessment starts, you need to have the following components in place:
Mistake #3: Treating PCI as an annual event. PCI DSS compliance doesn't begin and end with the annual assessment; ir is actually a continuous compliance requirement that happens to have an annual assessment. Therefore it's important to continually assess the organization and follow proper security and compliance procedures throughout the year leading up to the assessment. If an organization happens to fall out of compliance between assessments (as is common) and suffers a breach, it will be treated as if it were not in compliance, exposing the organization to fines and penalties. By maintaining security posture and ongoing documentation (most security tools contain PCI reports), you can reduce your potential liability and gain more negotiating leverage should a breach occur. Maintaining documentation and continued assessments are also far less costly than trying to update all PCI DSS documentation only once a year. Like balancing your checkbook, keeping up with incremental changes is more effective (and cheaper) in the long run.
Mistake #4: Waiting until your assessment to discover orphan data. According to the Verizon Data Breach Investigations Report, one of the most common deficiencies discovered during assessments is unencrypted cardholder data stored in violation of PCI. In my experience, orphaned, unencrypted cardholder data is one of the top deficiencies and a very common source of real security breaches. Content discovery tools, such as those in Data Loss Prevention products, can continuously scan the environment for cardholder data sitting around where it shouldn't be. Ongoing scanning produces reports that can be correlated and handed to the QSA to save significant time and money during the assessment.
Mistake #5: Letting PCI drive your security program. Security programs should be prioritized based on the risks to each particular business, not just based on one external standard protecting one subset of an organization's systems and data. So keep PCI in context: PCI isn't a security regulation, it's a contractual requirement for any organization handling credit card numbers. It's far better to focus on good overall security than to merely respond to assessment deficiencies. To hear more PCI DSS assessment advice, tune into a WHW round table webcast I moderated on May 19 on the same topic here.
As our globally competitive and hyper-connected digital marketplace has grown, so too has the field of risk management. Organizations are establishing comprehensive enterprise risk management programs to streamline security processes, mitigate risk, and meet compliance.
This shift is leading to the ‘operationalizion’ or embedding of IT security into broader business and IT functions. As such, security professionals can expect to see growth in operational process and control areas including risk assurance, data governance, technology governance and risk compliance, legal compliance and standards, digital rights management, privacy, cybercrime investigation, forensics and e-discovery, and identity management.
Job titles are already showing movement in this direction: Hybrid and newly created roles such as Chief Data Officer, Legal Technology Risk Officer, Information Risk and Compliance Officer, Cyber Law and Compliance Officer, etc., are already emerging and creating new disciplines and direction for security professionals.
This means that practitioners have broader opportunities for specialized and converged areas including information risk management, data governance, technology law, regulatory compliance, operations, cyber assurance, and intelligence, to name a few.
However, as more experienced professionals become available, technical competencies that were once highly sought in the marketplace eventually become a commodity, become redundant, or move offshore. So the question becomes, what are the keys to career advancement and success?
A strategic and tactical plan that outlines key goals and resources and is helpful. The plan should include:
- Self-Assessment. Who are you? Where are you now? Where do you want to be?
- Career Assessment. What have you accomplished? What experience, education
training and soft skills do you still need?
- Goals & Objectives. Match your goals with a timetable and strategy to get there. If
you are not sure what that is, that’s OK; keep going and keep mapping.
- Consideration of Key Strengths. Leverage your expertise, what you like and what
you do best.
- Resume & Bio. Develop an impressive, polished, well-written and up-to-date
resume. It should be a synopsis to showcase your experience and background,
highlighting areas of accomplishment, business acumen, and expertise. Also
maintain a short, one paragraph bio of career highlights. It’s also a great way to
track your accomplishments!
- Credentials. Continuing education, training, certifications, licenses and advanced
degrees will always be a part of staying relevant in the IT-related workforce. Keep
an eye out for certification trends going forward.
- Positioning. Get involved in your organization’s initiatives, special projects,
community and volunteer activities. Increase professional recognition with
speaking engagements, white papers, media briefings, presentations, and
publications.
- Plugging In. Join professional social networks and industry forums, increase your
knowledge and expand industry relationships and contacts.
Mentoring. Find a mentor, a coach or trusted person who has skills and insight to
help you evaluate, identity and achieve your goals.
- Characteristics of Champions. Integrity, confidence, emotional intelligence, and
business acumen are sought-after traits for any employee. Risk management
professionals will also need the ability to engage, communicate, strategize,
collaborate, execute, lead by example, and provide mentorship.
The shift toward risk management brings growth opportunities for security professionals to broaden their partnerships and alliances across business units and among their greater community of peers. To nurture a career in a changing risk climate, focus and determination are critical. Keep in mind opportunities for advancement, professional fulfillment, earning power, respect and recognition while on your career journey.
With the summer success of "The A-Team" (and it's theme song ringing
in our ears), we surveyed and received a little over 1,100 responses to the
following question:
Q: Which TV show from the 80's would you be most willing to go to the
movies and see the same weekend it opens?
1) "Seinfeld"
2) "Knight Rider"
3) "MacGyver"
4) "Fantasy Island"
5) "ALF"
6) "The Jetson's"
Please note that this poll is unscientific and basically worthless unless you
have time to kill and someone available to argue the Pro's and Con's of the
true meaningless value which would be experienced by resurrecting one of
the above mentioned TV shows into a full length movie.