Legal Services

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: 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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PCI DSS Requirement 6.2 Risk Ranking Vulnerabilities – Is your organization ready?

The Payment Card Industry Data Security Standards (“PCI DSS”) version 2.0 dated October 2010 became effective on January 1, 2011. There were many subtle and not so subtle changes from the previous version of the standard. The majority of the change became effective January 1, 2011, when requirement 6.2 was only considered a “best practice” by the PCI DSS. As of June 30, 2012, requirement 6.2 will become a requirement. With June 30 just a few days away, if your report on compliance is not in the final stages of report issuance, you need to be prepared to comply with requirement 6.2.

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PCI DSS Requirement 6.2 Risk Ranking Vulnerabilities – Is your organization ready?

The Payment Card Industry Data Security Standards (“PCI DSS”) version 2.0 dated October 2010 became effective on January 1, 2011.  There were many subtle and not so subtle changes from the previous version of the standard.  The majority of the change became effective January 1, 2011, when requirement 6.2 was only considered a “best practice” by the PCI DSS. As of June 30, 2012, requirement 6.2 will become a requirement.  With June 30 just a few days away, if your report on compliance is not in the final stages of report issuance, you need to be prepared to comply with requirement 6.2.

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Integrated Audit of Financial Statements – Relevance of an SSAE 16 Report

  Over the many years, while I have been working with companies as their Independent Service Auditor to help issue their SAS 70s / SSAE 16 reports, I have also been on the other side of the fence wherein I was part of the team responsible for the Audit of the Financial Statements of a company that used the SAS 70 / SSAE 16 report.  I thought it may be useful to individuals reading this blog to get an understanding of how the SSAE 16 report links to an audit of financial statements more specifically under Sarbanes Oxley.  Since SAS 70 as a standard is no longer in existence, I will refer to only SSAE through the rest of this blog.

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Too many SSAE 16 audit detours?

  Does your Auditor offer: fixed fees? NO out-of-pocket expenses? a declining fee structure? over 250 SOC Audits of experience? the draft report within 10 days of completion? responds to your calls and emails on the same day?   If your current CPA firm is not meeting these standards,…

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Why do my clients ask me for a SOC 1/SSAE 16 Report?

Let’s spend a few minutes getting back to basics. Why do your clients ask for a SOC 1/SSAE 16 report to be provided?  Your clients ask because their auditors probably asked for it.  So why do your auditors ask for this report?  The roots for SSAE 16 can be traced back to SAS 70 and even further to SAS 55.  The understanding of internal controls is a fundamental component of performing a financial audit.  I spent time early in my career in the financial audit department which helps me explain to companies why a SOC 1/SSAE 16 report would be applicable or not to the company.  In performing a financial audit, the auditor makes inquires of the company regarding their internal controls. Having an understanding of the internal control over financial reporting is a required component for the auditor to perform.  If a service has been outsourced to another company, the auditor is required to understand the internal controls. This is so that they can understand the internal controls and assess control risk accordingly.

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