Preparing for a Payment Card Industry (PCI) compliance assessment is a major task for any size organization.
The complexity derives from PCI's Data Security Standards (DSS), which include up to 13 requirements that specify the framework for a secure payment environment for companies that that store, process, or transmit credit card transactions.
There are several steps to follow that can make a PCI DSS assessment easier.
In order for an organization to effectively manage its own risk, it must complete a detailed risk analysis on its own environment. The goal for the risk analysis is for the organization to determine the threats and vulnerabilities to services performed and assets. As part of a risk assessment the organization should define its critical assets including hardware, software, and sensitive informationand then determine risk levels for those components. This in turn allows the organization to determine priorities for reducing risk. It is important to note that risks should be prioritized for systems that will be in-scope for PCI DSS and then other company systems and networks.
Once the risk assessment has been completed the organization should have a much clearer view of its security threats and risks and can begin determining the security posture of the organization. Policies and procedures form the foundation of any security program and comprise a large percentage of the PCI DSS requirements. Business leaders and department heads should be armed with the PCI DSS requirements and the results of the risk analysis to establish detailed security policies and procedures that address the requirements but are tailored to business processes and security controls within the organization.
Building upon the foundation of security policies, the committee of business leaders and department heads should now review the PCI DSS requirements in detail and discuss any potential compliance gaps and establish a remediation plan for closing those gaps. This is where it is important to have the full support of business leaders who can authorize necessary funds and manpower to implement any remediation activities.
This is also the time to schedule the required annual penetration testing. These are typically performed by third parties, but is not required to be performed by third parties, and can take some time to schedule, perform, and remediate (if necessary). The results of a PCI DSS assessment will be delayed until the penetration test is completed so now is the time to schedule the test.
The next step is training and educating employees. Technical employees should obtain any certifications or training classes necessary so that they can operate and monitor the security control set in place. Non-technical employees must be trained on general security awareness practices such as password protection, spotting phishing attacks, recognizing social engineering, etc. All the security controls and policies in the world will provide no protection if employees do not know how to operate the tools in a secure manner. Likewise, the strongest 42-character password with special characters, numbers, mixed case, etc. is utterly broken if an employee writes it on a sticky note attached to their monitor.
At this point the organization is ready for a full-scale PCI DSS assessment and can now enter a maintenance mode where periodic internal audits occur and regular committee meetings are held to perform risk assessments and update policies, procedures, and security controls as necessary to respond to an ever changing threat landscape. PCI DSS must become integrated into the everyday operation of the organization so that the organization remains secure and to ease the burden of the annual assessments.
Phil Dorczuk is a Senior Associate with BrightLine, where he specializes in PCI DSS assessments and gap assessments