Pci Cover

Title: SAS 70 Type I and Type II Audits & PCI DSS Compliance Assessments

As an auditor for many years, I’ve been approached by many clients desperately wanting to know if efficiencies can be obtained within the audit and assessment process for companies undergoing both a SAS 70 audit and a PCI DSS assessment. There’s no simple yes or no, black or white answer to this, as many variables come into play when conducting a SAS 70 audit or a PCI DSS assessment.

What I can tell you though is that there are common themes and drivers seen in both a SAS 70 audit and a PCI DSS assessment. In short, both a SAS 70 audit and a PCI DSS assessment rely heavily on the existence of documented policies & procedures. Furthermore, both of these examinations also examine various aspects of physical security, network security, logical security, change management, to name a few. Quickly, you can see some overlapping themes in both a SAS 70 audit and a PCI DSS assessment. So, that’s the YES answer to “audit efficiencies can be obtained” when a company has to undertake a SAS 70 audit and a PCI DSS assessment. So, what’s the NO or the gray area? Keep in mind that the PCI DSS assessment is a very technical examination, much more so than a SAS 70 audit. At the same time, a SAS 70 audit also covers comprehensive business process controls applicable to that specific entity being examined for a SAS 70. A PCI DSS assessment does generally not cover or assess these specific business processes that a SAS 70 would. Thus, you can see the gaps between these two examinations.

In short, you can create synergies and efficiencies between SAS 70 audits & PCI by focusing on the areas where overlapping exist, such as in the development of policies/procedures and other areas mentions.

About the Author

Charles Denyer has extensvie expertise in the following areas: SAS 70 audits, Payment Card Industry (PCI) compliance, Regulation AB Item 1122/1123 compliance, Sarbanes-Oxley compliance.

Additionally, Mr. Denyer has a keen understanding and sound interpretation of all compliance rulings/regulations and associated standards/frameworks/methodologies used for auditing and risk assurance compliance

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