The Dangerous Out-Of-Scope PCI Charade

Dominating many discussions over the last few weeks in payment security circles has been speculation over what the PCI Council, Visa and others will decide about declaring some types of data out-of-scope for PCI purposes. Getting much less attention is what IT execs should do with data that is declared out-of-scope and how dangerous a game out-of-scope is.
At its simplest, out-of-scope means beyond jurisdiction; it means that whatever is being discussed no longer falls under the rules and requirements of PCI. One critical problem is that the brands and the PCI Council giveth and they can taketh away. In other words, if you’ve started sharing some, for example, tokenized data with marketing because a temporary out-of-scope ruling makes you comfortable doing so, you may find it almost impossible to undo should that ruling be reversed. Put more philosophically, you won’t likely be able to get the clear-text toothpaste back into the “they’re going to fine me from here to Shanghai, aren’t they?” tube.
The safest route is to somehow identify things that are declared temporarily out-of-scope from those that are permanently out-of-scope. But nothing would likely ever be declared temporary, so that’s rather useless advice. The only wise route is to simply assume that everything declared out-of-scope could later be declared back in-scope.
Standards change, and nothing changes faster than security standards. “We all thought WEP was (continue reading...)