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Why Change Your QSA Now If You Have Been Compliant in the Past?

July 21, 2023 | Richard Haag

As a business owner, you understand the importance of maintaining compliance with the Payment Card Industry Data Security Standard (PCI DSS) to protect your customers' sensitive payment information. 

Whether you perform your own assessment or work with a Qualified Security Assessor (QSA), you are responsible for an annual assessment of your organization's security posture to ensure that you meet PCI DSS requirements. 

So why would you change your QSA if you’ve always passed your PCI assessment? 

What benefits come from a continuous PCI assessment approach rather than a short-term review?

In this article, we expand on the role of QSAs, the risks of an under-qualified QSA, and why a passing grade is not the only indicator of high-quality QSA services. 

The Role of a QSA

A Qualified Security Assessor (QSA) is an individual certified by the Payment Card Industry Security Standards Council to conduct assessments of an organization's compliance with the Payment Card Industry Data Security Standards (PCI DSS). 

QSAs provide expert guidance and assistance to businesses to ensure they meet PCI DSS requirements and maintain secure payment card data.

Learn more about when and why you should use a QSA for PCI compliance here.

QSAs Vary in Expertise and Experience

When selecting a QSA for your business, it is important to remember that not all QSAs are created equal. 

While all QSAs have met the PCI Security Standards Council's qualification requirements, some may have more experience than others in specific industries or types of assessments. 

To ensure compliance and reduce risk, it is best to choose a QSA with the right combination of technical expertise, knowledge of your industry, and communication skills to ensure that you receive the best possible guidance. 

A top QSA should:

  • Provide insights and feedback. A skilled QSA not only assesses you against the PCI standard but also provides valuable insight on how to improve your organization's security posture and navigate the complexities of PCI DSS.
  • Understand the intent of standards. An experienced QSA understands the unique nuances of specific requirements and how to correctly interpret how they are written, the intent of the requirement, and how they should be interpreted. It’s not all black and white, and a good QSA knows how to expertly manage the grey area. 

A great example of these qualities can be seen when a QSA initiates the process. Some QSAs just request evidence from you demonstrating compliance. In contrast, Intersec’s QSAs ask your system administrators to perform live tests using random samples throughout the environment to verify compliance requirements are truly met. This approach may take more time, but it can uncover lapses in compliance that pre-prepared evidence may not. With our more thorough approach, the security posture of your organization will be more robust and better prepared to prevent a breach than the alternative “check the box” approach. 

Should You Change Your QSA, Even If You Passed Your PCI Assessment?

Many organizations keep the same QSA for years because they know they will pass the annual PCI assessment requirements. 

But this doesn’t come without risk—

  • Is your organization as secure as it could be or is data comprise eminent? 
  • Are you really PCI compliant against all new or changing standards? 
  • Has the environment been scoped accurately? 
  • Are new changes in your organization and/or industry being reflected in the assessment?
  • Are standards being overcomplicated leading to excess, unnecessary work?

Passing your annual PCI assessment is a significant achievement that reflects your organization's commitment to securing payment card data. But passing isn’t always the only important consideration.

As new PCI DSS 4.0 standards come into law next year, understanding what you need to change to be compliant in the future is more critical than ever. 

A new QSA can bring fresh insights and perspectives on how to improve your organization's security posture and ensure that you remain compliant with the new PCI 4.0 standard. 

Choose a QSA who has experience and expertise in your industry, understands your unique business needs, and has a track record of providing practical, actionable recommendations to strengthen your overall security defenses. 

Having you started your PCI 4.0 transition? Follow our step-by-step process. 

Does Your QSA Offer A Broad Range of Services?

Remaining PCI compliant is more than just passing an annual assessment. Ideally, your QSA should be working with you throughout the year, offering additional services, including:

  • GAP Analysis – A gap analysis is a key component of high-quality PCI compliance services as it provides a complete assessment of your organization’s readiness for your annual onsite assessment. Assessors should analyze and report on all system areas that pertain to PCI compliance and provide a comprehensive set of deliverables that verifies the current status of PCI requirements.
  • Remediation – Not only do the top QSAs review your PCI compliance standards in detail, but they also refer to independent partners with remediation strategies to reach full compliance. Intersec has established engineering teams competent in PCI but separate from our compliance teams to ensure independence.
  • Compliance Monitoring – You know you’re getting the top QSA services available when your QSA firm also offers monitoring services to help you remain compliant. 

Does Your QSA Sign Your Assessment?

Completing a PCI assessment does not come without risks for QSAs, but many QSAs (maybe even your own), may not actually sign the assessment to take responsibility for its contents.

Intersec Worldwide signs every assessment because we are confident that our review of the standard and your overall compliance is accurate—we stand by the quality of our work. It also provides our clients with peace of mind, knowing they can trust our services. 

The Benefits of Continuous PCI Compliance Review 

Intersec has completed hundreds of PCI assessments over the years, and the one consistent piece of feedback our QSAs hear is that a 120-day assessment and implementing changes within 30 days is stressful, time-consuming, and frustrating.

This is why we’ve developed a better system. 

A continuous PCI compliance review is a unique approach Intersec Worldwide uses with many organizations to prioritize compliance. With a subscription-based model, organizations receive ongoing PCI compliance support and continuous assessments throughout the year. This reduces stress, provides more turnaround time to address required changes, and ensures that businesses are always compliant. Using a continuous PCI compliance review approach, you’ll have peace of mind that we’ll find any problems and resolve them before they become a security or compliance issue.

Getting ahead of PCI 4.0 is a great example of how you can work on compliance objectives in advance, reducing stress when the standard changes in 2024. 

Finding the Right Complimentary Services

If you find a QSA that does hit all the right points for your organization, there are other complimentary services Intersec Worldwide can provide that can of great value to shore up your cyber defenses. 

  • Managed incident response services - Restore business operations to normalcy faster with managed incident response services designed to pinpoint the source of issues and enact resolutions.
  • Certified PFI - Certified as independent experts in incident response, PCI Forensic Investigators (PFIs) are qualified to handle data breaches within the payment card industry.

Learn more about our innovative approach to cybersecurity now

A Qualified QSA is Time and Money Well Spent

Data breaches, being fined for losses, or lawsuits are some of the many risks associated with a lack of prioritization of PCI compliance. Time and money spent finding the right QSA and determining the right level of service your business needs to remain compliant is time and money well spent.

Intersec Worldwide stands out as one of only a handful of PCI compliance consulting firms that possess extensive expertise in digital forensics, incident response, and tailored remediation services. 

To discover more about our services as a QSA company or to explore ways we can assist your organization, contact our team directly.

Read more of our PCI resources: