Avoiding conflicts of interest in PCI security assessments

Network security audits should not be performed by the same individual who later patches the network security holes found by that network security audit.

I recently became a qualified assessor. Previously, I conducted scans for my customers and fixed vulnerabilities that would prevent them from passing a QSA-conducted scan. Is it acceptable for me to fix the problems I find in the scans I find as their QSA? I'm thinking it might be better to have a separation of duties here.

Section 2.2 of the PCI Validation Requirements for Qualified Security Assessors (QSA) v. 1.1 calls for "auditor independence" within the QSA program precisely to avoid the type of conflict of interest that you are worried about. In discussing this issues with others in the industry, it is generally accepted that policies be put into place that mandate a separation of duties between QSA Auditors and QSAs, or other individuals within a QSA certified company who provide remediation support.

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