I just read Bill Brenner's interview with Heartland Payment Systems' CEO Bob Carr [ Heartland CEO on Data breach: QSAs Let Us Down] and truthfully, my blood is boiling.
Basically, he's throwing his QSA under the bus for the massive data breach that happened under his watch.
Basically, because the QSA didn't find anything, therefore he should be off the hook.
I say that's a load of crap. It's about time organizations suffering from a data breach owned up to the fact that they made a mistake. You see, the fine folks at Johnson and Johnson didn't throw the pharmacy under the bus when Tylenol got poisoned in 1982, did they? NO! They accepted responsibility (even though it wasn't their fault) and re-established trust with their customers.
This kind of response from Mr. Carr basically proves that organization has learned NOTHING from the data breach, which means inevitably it will happen again.
To be clear, you cannot outsource thinking. You cannot outsource security. An auditor or assessor is only there to substantiate the technical controls implemented to meet a regulation. They are not there to tell an organization whether they are secure or not. They are not there to provide an itemized list of every possible attack vector that could compromise data.
That, my friends, is the responsibility of the internal security team. That's what they do, and that's what they get paid for. And in Heartland's case, that's what they clearly failed to execute. His security team should have known about the malware used on "300 other companies." Why is it the auditors responsibility to inform him of that? The auditors are there to determine whether they have met the spirit of the regulation.
He makes the statement that "PCI compliance doesn't mean secure." Uh, is that news to him? If so, then he's more out of touch than I had feared. Anyone in this business knows that any regulation is on the beginning of a comprehensive security program, and PCI is no exception. And moreover, even if you are compliant, you are not done. When it comes to security, you are never done. Not as long as there are bad guys (and gals) trying to compromise your systems.
But you have to hand it to Mr. Carr. He is proving to be a master at misdirection. First it was the fairly ridiculous push for end to end encryption. As if that would have solved the problem at a reasonable cost. Now he's trying to point the finger at the auditors. I'm sure when this goes over like a lead balloon, he'll be looking for some other scapegoat. Next time, he'll be more than happy to throw Vontu and Voltage under the bus, since he mentions them specifically as the "answer" to ensure this doesn't happen again.
Sorry, I don't buy it. Widgets do not equal security. Blaming others does not make you secure either. I suggest you look in the mirror Mr. Carr. That's where you'll see where the blame ultimately lies. Any attempts to blame others are hollow and disingenuous.