"Not all [auditors] are the same and not all of their responses will fit your situations," he said. "And so we have to manage them against each other and get what we need from them. They don't always understand the specific security needs of the business."

For example, he said, a department can catch flak for not having a firewall installed on certain systems, even though the more appropriate course for the business unit may be to segment parts of the network from other areas.

Merchants who take the time to truly understand the mechanics of PCI are therefore in a position to debate the auditor's findings and avoid wasteful technological investments that are sometimes made for the sake of a passing grade.

Communication = a better experience
Kintigh has had more positive dealings with the auditors. One thing in his favor is that his company's footprint is tiny compared to Time Inc. Overhead is low and the company has no more than 20 employees. The systems an auditor must examine are a lot simpler.

"We've had fairly decent interactions with our auditors," Kintigh said. "They've been willing to talk over issues with us before giving us the big red X. We are a small company and their processes are built for rather large companies."

Since there are only a small number of people signing off on different software changes and the like, auditors seem to have an easier time pinpointing strengths and weaknesses in the companies PCI security program. In this case, they recommended a more formalized software update process.

"They wanted to see tighter control over our procedures for software tracking, patch management and change management," he said. "We had a system in place but not under a formalized process. They wanted more documented, formal procedures and they wanted us to be more consistent about it."

At the beginning of the auditing process, they also examined the company's firewall rules and suggested changes. "We had various firewalls on different machines and the auditors suggested they wanted to see more of a commercial box for that," he said.

Each year, he said, the auditing process gets easier because the company gains a better understanding of what auditors tend to look at.

One auditor's advice
During the CSOonline PCI security event, Atlanta-based auditor James DeLuccia sat on the panel alongside Duran. He acknowledged that a lot of companies run into the difficulties Duran described. Among other things, he agreed there are probably auditors out there who go too far in pushing certain vendors on merchants as a condition for a passing grade.