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Verizon have recently launched their 2011 Payment Industry Compliance Report, which draws on their experiences as a Qualified Security Advisor (QSA) company, and their previous annual reports.

Below are exerts from their report:-

Unchanged from last year:-

  • 21 % of organizations were fully compliant at the time of their Initial Report on Compliance (IROC)
  • 78% of organisations met all test procedures at the IROC stages
  • 20% of organizations passed less than half of the PCI DSS requirements
  • 60% scored above the 80% mark

Organizations struggled most with the following PCI requirements:

  • 3 (protect stored cardholder data)
  • 10 (track and monitor access)
  • 11 (regularly test systems and processes)
  • 12 (maintain security policies)

The PCI Requirements showed the highest implementation levels:

  • 4 (encrypt transmissions over public networks)
  • 5 (use and update anti-virus)
  • 7 (restrict access to need to know)
  • 9 (restrict physical access)

Verizon concluded that organizations do not appear to be prioritising their compliance efforts against the PCI DSS Prioritized Approach (The Prioritized Approach is a free spreadsheet that can be download from the PCI Security Standards Council site, find it here).

Organizations that suffered data breaches were less likely to be compliant than a normal population of Verizon PCI clients.

In the pool of assessments performed by Verizon QSAs included in this report:

  • 21% were fully compliant at the completion of their IROC
  • This is just 1% less than in their last report, and effectively the same number

The lack of change disappoints Verizon, as many in the industry were hoping to see an increase in overall compliance as PCI DSS became more familiar to an increasing number of organizations.

79% of organizations were not sufficiently prepared for their initial assessment

Having established that only 21% “passed the test” the next question becomes “what was their score?”

  • 78% met of all test procedures defined in the DSS at the time of their IROC
  • This is down 3% from Verizon’s last report

Verizon deduce that another common Achilles heel of merchants and service providers in the PCI assessment process is overconfidence. “It was painful, but we made it through last year, so this year should be a breeze,” is a typical sentiment with which many organizations approach the yearly assessment. That can be a costly mistake.

When the QSA arrives on-site, a mere 1/5th of businesses are found to be compliant, even when given the extra time between the on-site visit and completion of the IROC.

Verizon believe that complacency and fatigue are two additional drags that make maintaining compliance year over year difficult.

Too many businesses approach PCI from the point of view that “what was good enough last year will be good enough this year.”

When examining the percentage of organizations passing each requirement at the IROC phase

  • Some requirements show percentages dipping below 40%, while others exceed the 70% range
  • Six of the twelve show an increase over last year, and the average is up two points
  • However, the average number of test procedures met within each requirement is down 4%
  • None of these numbers is indicative of a clear change given the size and makeup of the dataset, but it certainly reinforces the notion that organizations continue to struggle (at varying degrees) in all areas of the DSS

How do organisations perform against the 12 Requirement? The four highest rated Requirements are:

  • 4 (encrypt transmissions)
  • 5 (AV software)
  • 7 (logical access)
  • 9 (physical access)

Requirement 10 (tracking and monitoring) boasted the highest gain+13 %

Requirement 5 (AV software) may lose its place in the top three, which is an odd development, since AV software has for so long been among the most basic and widespread of security controls.

The improvement in compliance to Requirement 4 (encrypt transmissions) may indicate that administrators are deciding it is easier to direct all Internet traffic containing credit card data over SSL.

The small improvement in Requirement 7 (logical access) if significant at all could mean more strict attention is being paid to who is given access to cardholder data.

Requirements 3 (stored data) and 11 (regular testing) are once again in the bottom tier, while Requirement 12 (security policies) ousted 10 (tracking and monitoring) from the bottom. This suggests that the encryption of data at rest continues to be a major headache for organizations, especially the more detailed portions, such as annual key rotations.

Requirement 1 remains virtually unchanged since last year

  • 44% were compliant
  • 46% in the last report
  • Only 63% of companies met Requirement 1.1.5 regularly

The entire report can be found on the Verizon web site here.

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