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RS<br />

34 RS June - July 2012<br />

roundtable<br />

JK: It is for the small merchants – it’s just easier for them.<br />

AY: My question to you Jeremy is; where do they go? Some of<br />

them don’t even know what PCI is and they wouldn’t know who<br />

to outsource to if you asked them. There are great solutions<br />

out there, some with one vendor, others across several vendors.<br />

JK: They have a relationship with their acquiring bank and so<br />

that has to be the gateway for them. How good it is, I don’t<br />

know. Some of the acquirers will have hundreds of thousands<br />

of small merchants. Do they talk to them all individually or do<br />

they just blitz them? However, those acquirers will have access<br />

to suppliers who are PCI approved service providers so they can<br />

give the smaller merchants this information. Essentially I’ve got<br />

to work with the UK cards and the UK acquirer groups. Firstly<br />

we need to be able to get some information to the merchants<br />

and then once they’ve read that give them a list of people they<br />

should be talking to, let them know how much it’s going to cost<br />

and tell them what they’re going to get. And we need to let<br />

them know what could happen to them if they don’t go this<br />

route. The brands don’t differentiate between big and small<br />

merchants when there’s a data breach, they just come in and<br />

hit you. For small merchants it’s end of game.<br />

AY: When chip and PIN came out there was a whole load of<br />

education. Not just to the consumers but to the retailers as well<br />

and that was pushed down by the acquirers. We don’t have that<br />

same infrastructure for PCI and I think it’s that whole education<br />

process that’s lacking, that’s what the retailers need.<br />

JK: In some regard we’ve done a sort of top down approach.<br />

We’ve started off at the big retailers and we’ve gone down<br />

to the next level and now we’re getting down to the smaller<br />

merchants. Whether that’s right or wrong, I don’t know.<br />

“Outsourcing PCI is key for tier 3 and 4 retailers.”<br />

AH: I think there’s a vast difference between the council<br />

interpretation of the standard and the acquirer interpretation<br />

of the standard. And sometimes you almost get the feeling that<br />

they don’t want you to worry. They want you to be seen to be<br />

trying so therefore there’s a small, tiny penalty per merchant<br />

should you not register with the PCI DSS there’s a small monthly<br />

fee, but that is all. So if you don’t meet the requirements you<br />

tick a box for an implementation plan and this is never reviewed<br />

and that almost gives you the ability to perpetually say: ‘We’re<br />

working on implementation.’ At the moment acquirers don’t<br />

appear to be serious.<br />

CP: UK card acquirers, who come together on a monthly<br />

basis and meet in a non-competitive environment, they’ve<br />

been really trying and worrying about how they’re going<br />

to get at the small business merchants. So, encouraged by<br />

Jeremy, they have started to put together an education<br />

package particularly focused at level 4 merchants around the<br />

e-commerce environment. That was sustained and upheld<br />

by the PCI council in the autumn. When the council asked for<br />

suggestions of what they should focus on in a 12 month period<br />

they got 31 suggestions, that was whittled down to 13. These<br />

were voted on by the participating organisations, of which there<br />

are over 600 across the world. The vote came out in favour of<br />

e-commerce solutions and education for smaller merchants but<br />

they broadened that and said e-commerce education. Here in<br />

the UK we’re focused on smaller merchants, looking at risk and<br />

looking at cloud. And in the UK the card acquirers have come<br />

together and they’ve written some guidance which has been fed<br />

into the special interest group, which will hopefully be published<br />

before September/October.<br />

AH: Say a retailer already knows what they’re meant to<br />

be doing. I meant in the process of monitoring someone’s<br />

compliance maintenance, there is the ability to just indicate<br />

that you have an implementation plan in place. Even if that plan<br />

is that you’re waiting for your payment supplier to provide a<br />

solution – that is also accepted. But this could roll over into a<br />

number of years and in my opinion it’s not a realistic review of<br />

that retailer’s compliance.<br />

CP: Waiting for your supplier is another area that is being<br />

addressed. The challenges for merchants has been that some<br />

of the suppliers are saying: ‘Well there’s nobody chasing me<br />

to do it. You’re going to pay for it Mr merchant.’ The merchant<br />

says: ‘No I’m not.’ So that’s also been addressed now. Visa<br />

particularly have launched a program to get the service<br />

providers to register online to indicate they are compliant or<br />

that their solution means card data is not in the merchant’s

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