This depends on the complexity of the task. But we believe in efficiency and fair
value for fair service. We’re happy to be open on rough costs in initial discussions as
we understand the cost factor is very important and if we’re miles apart then we
shouldn’t waste each other’s time!
It means we have no vested interest in recommending third parties or do not receive a commission. There are vendors we know and trust but we have no formal alignment with them and would only facilitate referrals if it’s in your interest.
To get there takes a lot of hard work! All of our assessors require at least 3 separate certifications and a wealth of experience. It’s not an easy task to become a QSA and there’s a reason why there’s only a select few of us. As a firm, we require stringent processes on auditing, data protection and retention, quality assurance, code of conduct, and background checking. And we require significant levels of insurance coverage.
It has to be a fit for both parties. This is a two-way street and we’ve refused projects also when we don’t think we’re aligned. But generally, our approach is that of honesty, pragmatism and working in your best interests with little red tape. We believe our track record over the years speaks for itself and hopefully, it means we must be doing something right.
Achieving compliance is a journey. Unless your scope fits SAQ-A, the reality is it’s going to take significant effort, resources, and a reasonable budget. For some entities, compliance takes years to achieve. But knowing you’ve taken all reasonable steps to secure your environment in the age of breaches and data theft will be worth the effort.
You need to re-certify annually. After your initial compliance, there are a number of controls you need to maintain annually to demonstrate. Any drop-off of these controls can cost your compliance renewal.
The PCI DSS is a global standard. If your core business is certified compliant, you can take this certification globally. It’s only if the PCI DSS scope changes in line with any expansion efforts that you need to consider further assessments. An example is opening an office in another country that takes card payments.
We would stress a key point here: stakeholder management. Any third party asking you to be PCI compliant also recognises it doesn’t happen overnight. Often committing to the process, planning the journey, and presenting the plan itself can be enough in the short term, provided there’s a realistic commitment and timeframe for the end goal. Don’t panic when a request comes in. Do your research, make a plan and most importantly stay in communication.
In our experience, this rarely works. The scope may be wrong or critical BAU tasks not being performed. If you have been on the journey for a while, we often suggest a readiness assessment rather than the full gap assessment. Less time and commitment and we believe a balanced solution rather than jumping into an assessment likely to end in failure.
You should be completing Attestations of Compliance for both. Being a service provider means there are a few additional requirements to consider which are deemed out of scope for merchants.
No. Merchants have multiple SAQ templates to choose from. Service providers must complete SAQ-D. It should be understood there is a difference between scope and template. Just because you have to fill in the SAQ-D template does not automatically mean all those requirements are in scope. There may be a significant number of ‘N/A’ answers completed.
No. Any serious payment gateway is always PCI compliant. The method of integration with the payment gateway is the defining factor in determining scope. Even if all payment data is entered directly into the gateway’s payment page you will still have a handful of PCI obligations.
The key test here is remembering if you can impact the security of card data. Examples include: 1) Your web server handles the redirect to the payment gateway. If it gets compromised, an attacker could create a mirror site to a gateway looking payment page. 2) You manage an entity’s firewall. If you mismanage this configuration an attacker may enter the network. 3) You develop a payment page that is pushed to the customer’s browser and data transmitted to the gateway. In this scenario, you have numerous PCI obligations as the security of the payment page and underlying infrastructure is your responsibility.
This really depends on your budget and also internal capabilities. We will always recommend some level of support but we try to be honest in our appraisal. As these entities do not need a full audit there’s more flexibility in the level of assistance.
If card data is stolen from your environment, you’re still likely to suffer reputational damage. We suggest you do your research into PCI DSS; assess the likely benefits v costs; and make a balanced business decision.