Pushing The Limits

Here are some situations that QSAs encounter way too often.

  • Organizations that conduct their annual penetration test 30 days before the deadline to file their self-assessment questionnaire (SAQ) or Report On Compliance (ROC).
  • Organizations that conduct their final quarter vulnerability scan 30 days before the deadline to file their SAQ or ROC.
  • Organizations that decide to implement a compensating control worksheet (CCW) within 30 days before the deadline to file their SAQ or ROC.

Why are these situations a problem?

For the first two conditions, it is because if any of these results in a remediation effort, you either (a) have to remediate the findings and retest before filing your SAQ/ROC or (b) you have to put compensating controls in place and test those to ensure you are mitigating the risk of not remediating. Both of these situations can easily result in missing an organization’s compliance filing date.

For any CCW, it is a problem because you need to test all of the controls you are using to compensate for not being able to comply with a requirement and prove they are functioning as designed. In a lot of cases, those controls are going to be new controls and will take time to implement and then test.

While this “fire drill” is going on, your QSA sits and waits for you to complete remediation or implement your compensating controls so that they can test things and ensure that you are in compliance. Unfortunately, while your QSA waits, the stress of getting things done accumulates and people lash out at the QSA for their organization’s poor planning with the expectation that the QSA will just look the other way.

As a QSA, I would really like to help you. But as the old adage goes, poor planning on your part does not create an emergency on my part. Unfortunately, clients never see it that way when they are trying to hit a deadline, but it is still true.

So the way to minimize these situations is to plan ahead. Make sure that your annual penetration test is conducted no later than the start of the fourth quarter of your reporting period. This will give you around 90 days to address any issues and retest. For vulnerability scanning, I would also highly recommend doing your final quarterly vulnerability scan no later than the start of the fourth quarter of your reporting period as well for the same reason. These both are particularly true if your organization has a history of not getting passing results.

For CCWs, you want your QSA to identify those as soon as possible so that you can work on getting the controls in place and functioning. As a result, you should schedule your assessment to start no later than the third quarter of your reporting period and as early in that quarter as possible. If your organization is large, you may even want to start in the second quarter of your reporting period.

If you have CCWs in place and you will keep them in place for your coming assessment, you should be conduct your own testing prior to your QSA arriving to make sure you can fix any out of compliance situations.

So before you chew off the head of your QSA for some self-inflicted wound, think about how you got into this predicament. Next year plan better and your assessment will likely go better.


2 Responses to “Pushing The Limits”

  1. 2 Me
    August 6, 2015 at 8:48 AM

    Risk assessments (e.g., 12.2) are often left to the last minute too. Depending on the size of the environment these can be large undertakings a company doesn’t want to have to do in the last 30 days or during the assessment – especially with the risk of doing them wrong. Organizations also often ignore the “significant change” requirement and some don’t realize they have been analyzing risk all along. I’d bet service provider responsibility matrix will fall into the “last minute” situation as well. If organizations implement continuous control monitoring and capture evidence along the way their assessment won’t only be smoother, but likely cheaper and with less unhappy employees and QSAs.

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August 2015

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