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RS<br />

38 RS June - July 2012<br />

roundtable<br />

AJ: In the education process is that listed as one of the areas<br />

retailers should look at?<br />

CP: Yes, but perhaps there hasn’t been enough emphasis on it.<br />

When you look at the guidelines for PCI on the council website<br />

it goes through the details, but I think it’s probably one of the<br />

details that hasn’t been brought up sufficiently. If you’re talking<br />

to a supplier who’s perhaps doing something internationally,<br />

their data centre in Phoenix, Arizona, is compliant, but they<br />

may have a data centre here in the UK that hasn’t gone through<br />

compliance. So as a merchant you need to know which data<br />

centre your data will be going to and whether or not it has been<br />

assessed. That’s the beauty of the attestation. If you look at<br />

Phoenix Networks and Semafone and the detail in which they’ve<br />

been assessed, that’s how you know they’re the right partner<br />

for you as a merchant.<br />

CN: It’s probably worth saying that the level one, level two<br />

service provider – level two is only processing up to 300,000<br />

transactions a year. So do you really want to be putting your<br />

business in the hands of a company that’s only dealing with<br />

300,000 transactions a year? And they are the ones who are<br />

allowed to self assess. You want to be dealing with level one<br />

service providers; level two is just too much of a risk because<br />

you’re just back to ticking boxes again.<br />

AY: Fraudsters are very clever aren’t they? They know that<br />

level one and level two have probably got it sorted and so they’ll<br />

go for the weakest link. Recently Alan and I spoke to various<br />

trade bodies, the retail motoring industry, the association of<br />

convenience stores and several others. We found that now is the<br />

time to get that message out there to the wider audience about<br />

outsourcing and the importance of PCI, because that’s where<br />

the breaches are going to take place.<br />

MG: But only if we do it using language that they will<br />

understand.<br />

GT: And they probably need to understand what outsourcing<br />

is because outsourcing isn’t like, take a call centre and give it<br />

to somebody else. It’s like using a service that ensures you can<br />

continue to use your own contact centre except you’re not<br />

bringing any card data into your organisation. So we even need<br />

to be clear about what we mean by outsourcing because it could<br />

be totally misunderstood. Merchants might think they have to<br />

outsource all their IT to a separate business because that’s how<br />

they use the term within their own environments.<br />

CP: I think that’s a very key point because when you look at solu-<br />

tions that are available, a number of them bring the card data<br />

into the environment; therefore you’re left with the expense<br />

and worry of having to protect all that data. Whereas there are<br />

other solutions where the data never comes into the environment.<br />

And that’s key because if you’re looking at the cost of<br />

compliance, especially as you go down the food chain, you have<br />

to be conscious of the ongoing costs because it isn’t a one off<br />

solution. Especially in the level one group that I chair, we talk<br />

about the importance of establishing what level everyone is at.<br />

Of the 35 merchants in my group there are five who have been<br />

compliant since 2010/11 but at the meeting on 6 March almost<br />

all of the rest of the group said they would be compliant by the<br />

end of this year.<br />

A SB: There is a perception out there that PCI compliance is a<br />

very hard thing to achieve.<br />

CP: And there’s a perception that it’s simply a one off job. But<br />

it’s not, it’s continuous. That’s why outsourcing is so important;<br />

it means retailers only have a limited amount to do. You never<br />

get rid of the SAQ, there’s always an SAQ of some sort which<br />

obliges you to be secure in the important areas.<br />

GT: It’s very interesting looking at North America now because<br />

the merchants started this journey so much earlier than us.<br />

Most of them have already reached compliance and now they<br />

have seen the business as usual costs they are much more keen<br />

on the de-scoping issue. So it’s very easy for them to justify<br />

taking that card data and removing it from their environment.<br />

The challenge in this market is that PCI kicks off a whole load of<br />

other projects, it kicks off a network project, a desktop project,<br />

a CRM project, a telephony project. And everybody gets their<br />

budget and goe on their journey without looking at the holistic<br />

card journey. The problem with that is all those departments<br />

have been wanting to buy a whole series of tools forever and<br />

then PCI comes around and they think: ‘Hey, I’ve got a budget to<br />

buy exactly what I wanted to. We should have invested in that<br />

years ago, that’s good information security.’ And so everybody<br />

goes and spends their budget on that instead of questioning<br />

whether they really want card data in their environment.<br />

CP: One of the key things to take away from this is that you<br />

can manage without data. My experience with the Post Office<br />

proves that. <strong>Retail</strong>ers should be limiting the scope by keeping<br />

card data and personal data in one particular area so it can<br />

be easily protected. This is not about abdicating responsibility.<br />

You can’t build a business case on protecting card data but we<br />

should all be responsible for protecting personal data for our<br />

customers. Anyone who has data has a responsibility.

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