Response to Visa’s Chief Enterprise Risk Officer comments on PCI DSS

Visa’s Chief Enterprise Risk Officer, Ellen Richey, recently presented at the Visa Security Summit on March 19th. One of the valuable points made in her presentation was defending the value of implementing PCI DSS to protect against data theft. In addition, Ellen Richey spoke about the challenge organizations face, not only becoming compliant, but proactively maintaining compliance, defending against attacks and protecting sensitive information.

Recent compromises of payment processors and merchants that were stated to be PCI compliant have brought criticism to the PCI program. Our views are strongly aligned with the views presented by Ellen Richey. While the current PCI program requires an annual audit, this audit is simply an annual health-check. If you were to view the PCI audit like a state vehicle inspection. Even though at the time of the inspection everything on your car checks out, this does not prevent the situation of days later your brake lights go out. You would still have a valid inspection sticker, but are no longer in compliance with safety requirements. It is the owner’s responsibility to ensure the car is maintained appropriately. Similarly in PCI, it is the company’s responsibility to ensure the effectiveness and maintenance of controls to protect their data in an ongoing manner.

Ellen Richey also mentioned increased collaboration with the payment card industry, merchants and consumers. Collaboration is a key step to implementing the technology and processes necessary to continue reducing fraud and data theft. From a merchant, service provider and payment processor perspective, new technologies and programs will continue to reduce transaction risk, but, today, there are areas where these organizations need to proactively improve. The PCI DSS standard provides guidance around the implementation of controls to protect data. Though in addition to protecting data, merchants, service providers and processors need to proactively address their ability to detect attack and be prepared to respond effectively in the event of a compromise. These are two areas that are not currently adequately addressed by the PCI DSS and are areas where we continue to see organizations lacking.

See the following link to the Remarks by Ellen Richey, Chief Enterprise Risk Officer, Visa Inc. at the Visa Security Summit, March 19, 2009:

http://www.corporate.visa.com/md/dl/documents/downloads/EllenRichey09SummitRemarks.pdf