This week’s Vendorcom Secure Payments Special Interest Group (SIG) met to discuss P2Pe and it became clear that there are many ways to achieve a compliant outcome.
My first impression was the large number of attendees at the SIG, 50+, only one of them was a Merchant. The rest were a mixed bag of Acquirers, PSPs, QSAs, Vendors and Consultants making it more of a Vested Interest Group than a Special one.
The Logic Group (TLG) started the presentations and covered their listed P2Pe solutions and how they achieved compliance. They explained all the hard work getting all the elements through the audits and the 970 P2Pe Controls (more than double that of PCI DSS).
TLG cited the issues of key custody and management and how once during the development period it required 6 people to cover the physical as well as the logical security requirements.
The Q&A session before lunch was mostly aimed at John Elliot of VISA Europe who handled even the most difficult questions very well and delivered the answers with humour. He even confirmed that next week there is a gathering in the US to ratify the much discussed Tokenization standard and some clarifications to the PCI DSS version 3.0. He however was wrong on one prediction that the new Self Assessment Questionnaires (SAQ) would be out on Thursday and they weren’t but to be fair to John almost everyone associated with PCI has tried to predict the arrival of the new SAQs and got it wrong. They finally came out today (28th February 2014).
Next up were Vodat International with their alternative to P2Pe. The Vodat solution is a managed end to end solution with encryption and resilience. Ian Martin’s presentation was supported by VISA Europe as a way to achieve PCI DSS compliance.
Some other discussion point
- Linked Encryption combined with EMV could make a significant security improvement for the US market
- Some merchants think switching to Ingenico gives them P2Pe
- Some merchants and the PCI SSC are concerned that there are only two listed P2Pe solutions
- PCI SSC would like to make P2Pe modular e.g. if you want to do your own key management or choose your own PEDs, etc.
- An April deadline for moving to TLS 1.1 or above is not true, maintaining secure software is always required.
- All mobile payments are mandated to have P2Pe
- P2Pe will probably never be mandatory, except for mobile
- If you have a certified P2Pe solution you can complete an SAQ no matter what size of merchant you are
It was an interesting day and after all the presentations and discussions what became clear is there are many ways to achieve PCI DSS compliance; Point to Point Encryption (P2Pe), Pseudo-P2Pe, End-2-End Encryption and Linked Encryption or a combination of them.
What is not in doubt is the chosen solutions must meet the business profile of the merchant and help them achieve PCI DSS compliance. The solution itself will not achieve compliance because there is more to compliance than installing a solution for example there is the on going maintenance of compliance and the human element.
Whichever solution you represent or are looking to buy lets hope it is installed and maintained well enough to meet and maintain continuous security and PCI DSS compliance.