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Date: Tue, 27 Apr 2010 16:19:55 -0400
From: Valdis.Kletnieks@...edu
To: Michael Holstein <michael.holstein@...ohio.edu>
Cc: full-disclosure@...ts.grok.org.uk
Subject: Re: Compliance Is Wasted Money, Study Finds

On Tue, 27 Apr 2010 13:48:11 EDT, Michael Holstein said:

> You've already stated in a prior email that you have no involvement with
> PCI implementation on either side of the fence ("hell no", was your
> answer, I believe) .. so I don't see where you're really qualified to
> make a categorical statement that PCI compliance lends nothing to security.

To be fair - the claim has mutated a bit along the way.

What it *started* as was more like: "Once you've spent money actually securing
the enterprise, then the time and money spent on actually getting the audit done
is "wasted" from a security viewpoint, as that time/money isn't actually getting
spent on something that affects security."

Your site runs a relatively tight ship already. You read the PSI specs, and you
spend $10K and 2 man-months getting compliant because your ship isn't totally
tight, and there's a few things you should have done. That's not wasted
security-wise.

You then pay $10K and 4 man-weeks to actually get the audit done.

What actual *security* benefit do you get from that $10K and 4 man-weeks?
Pretty much zero, unless you stretch it to the risk-management side and
have to declare "risk of not getting PCI compliance impacting our revenue
stream" on an SEC filing.  But that's one heck of a stretch.



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