Charting a course for successful PCI DSS compliance

With PCI DSS 4.0 in place, companies must focus on compliance

Jul 18, 2023
Cybersecurity consulting Cybersecurity Regulatory compliance

Achieving Payment Card Industry Data Security Standard (DSS) compliance can be a complex and time-consuming process, but it is required for any organization that stores, processes, or transmits payment card account data or provides services that can affect the security of payment card account data.

With PCI DSS version 4.0 now in place, your organization must concentrate more energy on remaining compliant.

Below are several steps that can help you begin your journey to PCI DSS compliance:

1. Determine applicability

First, your organization should identify your business' role in handling payment card data—whether you are a merchant, service provider, or both. Determine if and how your business stores, processes, or transmits account data and understand whether you provide services to other entities involving account data.

With that established, you should determine the level of compliance validation required. Identify the specific criteria that determine your compliance level as defined by the payment card brands (e.g., annual transaction volume).

  • As a merchant: Level 1, Level 2, Level 3 or Level 4
  • As a service provider: Level 1 or Level 2

2. Understand PCI DSS requirements

To reach compliance, you must first familiarize yourself with the current version of the PCI DSS. You can obtain a copy of the PCI DSS documentation from the official PCI Security Standards Council (PCI SSC) website and review the 12 principal requirements and their associated sub-requirements to understand the expectations for compliance.

3. Establish responsibility

Designate an individual or team with the necessary experience, authority, and resources to manage PCI compliance efforts. Report your compliance efforts to top-level management. In many cases, you may often need third parties to augment your internal bandwidth and experience.

4. Determine the scope of the cardholder data environment (CDE)

You must identify all personnel, systems, and processes that store, process, or transmit account data (e.g., point-of-sale systems, e-commerce websites, payment gateways, etc.). Determine the network segmentation and boundaries of the CDE to ensure that you include only necessary systems and processes. In addition, you should document the scope of the CDE in a formal document and keep it updated.

5. Conduct a gap assessment

An effective gap assessment identifies areas where your security controls may lack or not meet the PCI DSS requirements. This process should document all PCI-required security controls in place and their effectiveness.

6. Remediate gaps

With a new perspective on your environment, you should develop a prioritized plan to address all gaps based on the risk-to-account data. Assign responsibility for implementing the remediation plan, set a timeline for completion, and test and validate the effectiveness of the remediated controls.

7. Conduct regular vulnerability scans and penetration tests

You and your team should conduct quarterly internal vulnerability scans of all systems and processes that store, process or transmit account data. In addition, you must conduct quarterly external vulnerability scans using a PCI Approved Scanning Vendor (ASV), as well as annual penetration tests of the CDE. Address any vulnerabilities or weaknesses identified during the scans and tests.

8. Maintain and update security policies and procedures

Develop and maintain policies and procedures that address security and data protection and regularly review and update policies and procedures as needed.

9. Train employees on security awareness and their role in protecting account data

To promote ongoing compliance, conduct regular security awareness training for all employees with access to account data. This training should ensure that employees are aware of their responsibilities and obligations for protecting account data.

10. Document and retain evidence

You should maintain documentation demonstrating compliance efforts, including all policies, procedures, and security controls implemented to meet PCI DSS requirements. Keep records of system configurations, network diagrams, and other relevant documentation.

In addition, retain evidence of security controls, policies, training, and audit, including records of employee training and awareness programs, audit logs, vulnerability scan reports, and penetration test results. Retain the completion of policy and procedure reviews even when no update is needed.

11. Complete PCI DSS validation documentation

You must complete the appropriate Self-assessment Questionnaire (SAQ) or, when required, engage a Qualified Security Assessor (QSA) for a Report on Compliance (ROC) assessment. Provide accurate and comprehensive information about your security measures, including validating PCI DSS controls and completing the SAQ or provide the necessary documentation to the QSA for the ROC assessment. You should also provide and retain evidence and documentation to support your compliance with each PCI DSS requirement.

12. Submit compliance reports

After compiling your documentation, submit the SAQ or ROC and corresponding Attestation of Compliance to your acquirer or payment brand by the required deadline. Respond promptly to any requests for additional information or clarification.

13. Maintain ongoing compliance

To help ensure your organization remains in compliance, you should regularly review and update security measures. Stay informed about the latest security threats and vulnerabilities and continuously assess and enhance your security controls to address emerging risks. Include the PCI lead or team in evaluating new projects to determine how they may affect current PCI DSS compliance.

In addition, you should conduct periodic assessments to ensure ongoing compliance, with regular self-assessments to identify any new gaps or vulnerabilities. Engage a QSA for annual ROC assessments as required by the payment card brands.

The takeaway

It is important to remember, while you report PCI DSS compliance annually, it is an ongoing process that requires regular monitoring, updates, and adjustments to maintain a secure environment for payment account data. It's crucial to stay informed about changes in the PCI standards and work with reputable security professionals to ensure the highest level of compliance and security.

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