I was recently sent a whitepaper by a colleague of mine which covered the subject of tokenization. It took a belligerent tone regarding the PCI DSS and the PCI Security Councils views of Tokenization, which is understandable in context - the vendors involved with the whitepaper are fighting their corner and believe passionately that tokenization is a great solution to the problem of how best to protect cardholder data.
To summarize the message of the whitepaper, the authors were attacking the PCI Security Standards Council because the Council's 'Information Supplement covering PCI DSS Tokenization Guidelines' document was specifically positioned as 'for guidance only' and explicitly stated that it did not 'replace or supersede requirements in the PCI DSS'.
The whitepaper also quoted a PCI Security Standards Council Press Release on the subject of Tokenization where Bob Russo, the General Manager of the PCI SSC had stated that tokenization should be implemented as an additional PCI DSS 'layer'. The tokenization whitepaper took issue with this, the argument being that tokenization should be sanctioned as an alternative to encryption rather than yet another layer of protection that a Merchant could optionally implement.
The unfortunate reality is that Bob Russo runs the PCI Standards Security Council and it is they who define the PCI DSS, not any vendors of specific security point-products. Also, where I would say the statement above is completely wrong is where they say 'It's not about layering' because the PCI DSS - and best practise in security in general - is absolutely all about layering!
The reason why the PCI DSS is often seen as overly prescriptive and over-bearing in its demands for so much security process is that card data theft still happens on a daily basis. What's more pertinent is that whilst card date theft can be the result of clever hackers, or polymorphous malware, or cross-site scripting or even card skimming using fake PEDs.
The number one Card data theft threat remains consistent - complacency about security.
In other words, corners are being cut in security - a lack of vigilance and more often than not, silly, basic mistakes being made in security procedures.
So what is the solution? Tokenization won't help if it gets switched off, or if it has a conflict with a windows patch or if it gets targeted by malware, or simply bypassed by a card skimming Trojan - also it won't protect against a malicious or unintentional internal breach. Tokenization also won't help protect cardholder data if the Card Swipe or PED (PIN Entry Device in Europe) gets hacked, or if a card number gets written down or recorded at a call centre.
In summary - Tokenization is undeniably a good security measure for protecting cardholder data, but it doesn't remove the need to implement all PCI DSS measures. 'There has never been and there still is NO SILVER BULLET when it comes to security.
In fact the only sensible solution to card data theft is layered security, operated with stringent checks and balances at all times. What PCI Merchants need now and will continue to need in the future is quality, proven PCI solutions from a specialist with a long track record in practising the Art of Layered Security, combining multiple security disciplines to protect from external and internal threats, combining such things as good change management, file integrity monitoring with SIEM for example to provide the necessary vigilance essential for tight data protection security.