In December, the Public Company Accounting Oversight Board (PCAOB), which establishes rules for compliance with Sarbanes-Oxley, proposed a new standard for Sarbox section 404, which governs internal controls over financial reporting, including IT controls. Separately, the Payment Card Industry data security standard will require merchants and payment processors to implement stringent IT security procedures, such as additional firewalls and access controls. These laws include both proactive components (having an information security policy, implementing access control technology) and reactive components (disclosure of security breaches).