Questions have been asked at various Community Meetings over the years regarding reliance on internal and external audits, but none of us discussing this question could remember anyone asking the Council about ISAs. The reason this issue repeatedly comes up is due to organizational audit fatigue.
With standards such as PCI, NIST, ISO and the like, some organizations can be under constant and never-ending audits. To add to this audit onslaught, the personnel involved are, in a lot of cases, covering the same topics over and over and over. For the people involved, these endless audits become very annoying as these people are interrogated over the same topics time and again.
For the record, when the Council has been asked about internal and external auditor results, the answer has always been an emphatic “No”. That answer has, of course, been met with groans and complaints from the audiences that the Council is arrogant and unrealistic in how they approach assessments. While some of these complaints are on point for policies, access controls and physical controls, there are some PCI requirements such as those in sections 1, 2, 10 and 11 that are unique in the level of detail explored and are not covered in that same level of detail in other standards’ work programs. Both the Council and the people making complaints have their points.
So, we come back to the original question about ISAs. In theory, ISAs are provided the same training as a QSA by the PCI SSC. The only difference between a QSA and an ISA is that an ISA is employed by the organization being assessed. As a result, you would assume that all things being equal, a QSA should be able to rely on an ISA’s assessment work after a review of that work.
Nope!
According to the response we got back from the Council, a QSA must first ask the entity receiving the assessment if they can rely on an ISA’s assessment work.
QSAs are told not to question the work of other QSAs. But we need to ask permission to trust the work of an ISA? You are required to trust one, but cannot trust the other? What kind of nonsense is this?
With answers like this, you start to wonder what the purpose of the PCI SSC is in the scheme of PCI.
And we all though the discussion about “Not Tested” was ridiculous.