Accounts Receivable Management & Collections

PCI Data Security Standard Version 3.0 – Breakdown of Changes to Anticipate

By: Gene Geiger, Partner of A-LIGN Following the 36 month lifecycle the PCI Security Standards Council (“Council”) has established for the published standards, Version 3.0 of the PCI Data Security Standard is in the final stages before it will be released on November 7, 2013. Through several webinars and documents provided to stakeholders, the Council has provided information on the final draft in order to receive feedback at the 2013 Community that will be held in Las Vegas September 24 – 26. The core twelve requirements remain the same, but after a review of the changes and guidance provided by the Council, the change to Version 3.0 is more comprehensive than we experienced with previous version changes. However, due to the impact of these changes and the time it may take to fully comply with the requirements of Version 3.0, Version 2.0 may be used for assessment until December 31, 2014. Nonetheless, the Council encourages adoption of Version 3.0 as soon as practical.

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Ask A-LIGN: When receiving our first SSAE 16 audit, if the auditors find minor mistakes, will we have the opportunity to correct them?

By: Scott Price, Managing Partner of A-LIGN Answer: I hear this question often and, my answer is, “it depends.” I realize this is not the response most of you were hoping for, but I will elaborate. If your audit is a Type 1 SSAE 16, you can elect to have the review date of the report dated for when the service organization has remediated all deficiencies found in the controls. This is one of the main reasons why service organizations like to start with a Type 1 audit. However, in the same breath, the user community sees the limitations of a Type 1 since it only gives assurance at a specific point in time. It is a snapshot.

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New HIPAA Rules: Impact on Business Associates

As I read the “Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules under the Health Information Technology for Economic and Clinical Health Act and the Genetic Information Nondiscrimination Act; Other Modifications to the HIPAA Rules” recently released by the Department of Health and Human Services, I struggled to think how to summarize the 563 page PDF document into a meaningful summary for A-LIGN’s clients.  The title alone is a paragraph long.  A large part of the document is minutia that is not relevant for the everyday conversation on how to protect electronic protected health information (“ePHI”) but there are some key points and clarifications that are made which I believe should be understood by our clients.  As a provider of audit, compliance and security services primarily to companies defined as service organizations or service providers, I will focus on two key points that impact service organizations that handle ePHI, applicability and liability.

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PCI Security Standards Council Releases New Information Supplement on Cloud Computing

In February the PCI Security Standards Council (the “Council”) released a new information supplement related to the application of the Payment Card Industry Data Security Standards (“PCI DSS”) requirements in the Cloud. The goal of the information supplement is to assist Merchants and Cloud Service Providers (“CSP”) maintain PCI DSS compliant environments and also to guide the Qualified Security Assessors (“QSA”) that are tasked with performing the validation assessments.

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PCI Security Standards Council Releases New Information Supplement on Cloud Computing

  By: Gene Geiger, Partner of A-lign Security and Compliance Services In February the PCI Security Standards Council (the “Council”) released a new information supplement related to the application of the Payment Card Industry Data Security Standards (“PCI DSS”) requirements in the Cloud. The goal of the information supplement is to assist Merchants and Cloud Service Providers (“CSP”) maintain PCI DSS compliant environments and also to guide the Qualified Security Assessors (“QSA”) that are tasked with performing the validation assessments.

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Ask A-LIGN: What is the difference between a SOC logo and a SOC seal?

By: Scott Price, Managing Partner of A-LIGN  Answer: Misuse of Service Organization Control (SOC) terminology is a common mishap in the marketplace. When it comes to the use of the SOC logo or seal, many tend to assume the terms mean the same thing (six of one, half a dozen of the other), but in reality they are classified as entirely different entities. Let me explain…

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Ask A-LIGN: What is the difference between a Penetration Test and a Vulnerability Assessment?

A square is a rectangle but a rectangle is not a square. That saying always confused me in school and reminds me of the confusion in the market place between vulnerability assessments and penetration tests. A penetration test is a vulnerability assessment but a vulnerability assessment is not a penetration test. As I speak to organizations that want to test the security of their technology infrastructure I ask “Do you want a vulnerability assessment or a penetration test?” I receive responses ranging from “aren’t they the same” to “I don’t know you tell me”. There are key differences between the two depending upon the purpose of the project.  I would like to outline the purpose of the two projects and when you would select each.

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Ask A-LIGN: What is the difference between a Penetration Test and a Vulnerability Assessment?

By: Gene Geiger, Partner of A-LIGN Security and Compliance Services  A square is a rectangle but a rectangle is not a square. That saying always confused me in school and reminds me of the confusion in the market place between vulnerability assessments and penetration tests. A penetration test is a vulnerability assessment but a vulnerability assessment is not a penetration test. As I speak to organizations that want to test the security of their technology infrastructure I ask “Do you want a vulnerability assessment or a penetration test?” I receive responses ranging from “aren’t they the same” to “I don’t know you tell me”. There are key differences between the two depending upon the purpose of the project. I would like to outline the purpose of the two projects and when you would select each.

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Ask A-LIGN: Is SSAE 16 a Certification?

Answer: No, SSAE 16 is not a certification. Here’s why: It is incorrect to say that you are SSAE 16 certified, because there is not a certification awarded to you after the engagement. The appropriate wording would be to state, “we have received an unqualified (Type 1 or Type 2) SSAE 16 report as a result of a service auditor performing an audit in accordance with SSAE 16 on the services within the scope of our review.” Once we have issued a final report to our clients, we will then issue the AICPA SOC Logo Guidelines form. The guidelines will explain exactly who can use the logo, how to use it appropriately, and when you must end the use or display of the logo.

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Ask A-LIGN: Is my Organization Required to Obtain a Type 2 SSAE 16 Examination Annually?

Answer: This is a question we are asked frequently by our clients and prospective clients, and the answer is: It Depends. Here’s why: The SSAE 16 guidance states that the period of review, or time frame that the report covers, should be at least six (6) months in the case of a Type 2 SSAE 16 examination.  While this standard sets a minimum period of review, it can be set to cover any period of time over 6 months – i.e., six months, nine months or one year.

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