The Payment Card Industry Data Security Standard (PCI DSS) is a set of security standards designed to ensure that all companies that accept, process, store or transmit credit card information maintain a secure environment. If you accept credit card payments or process data related to them, you likely need to be PCI compliant. Preparing for and achieving certification comes down to monitoring for scope, control implementation, and assessment readiness, ideally through a continuous compliance solution.
Is your organization prepared for PCI DSS compliance? Schedule a consultation to find out.
How to Stay on Top of PCI DSS Compliance
Organizations that process cardholder data (CHD) need to abide by the PCI DSS standards. Doing so can be challenging, especially for organizations newer to compliance as a whole. Failing to comply can lead to significant fines and even the loss of the ability to process credit card transactions.
Achieving and maintaining PCI DSS certification seamlessly comes down to:
- Understanding the extent or scope of certification needed
- Installing and monitoring controls to ensure audit readiness
- Implementing a comprehensive PCI management solution
Working with a quality PCI DSS advisor organization further optimizes the process, making scoping, implementation, assessment, and overall management significantly easier at scale.
Keep Track of Applicability and Scope
The PCI Security Standards Council (SSC) oversees compliance, and its individual members (i.e., Visa, Mastercard, Discover, JCB, and AmEx) enforce it. Staying ahead of compliance and non-compliance starts with understanding whether and to what extent you’ll need to certify.
The level of PCI DSS compliance required varies depending on your organization’s classification as a merchant or service provider, as well as the volume and nature of transactions processed.
For example, consider Mastercard’s levels for merchant PCI compliance:
- Level 1 Merchants – Merchants who process over six million annual transactions, must submit a PCI Report on Compliance (ROC) annually, underscoring the critical need for rigorous adherence to PCI DSS standards.
- Level 2 Merchants – Merchants with more than one million transactions but fewer than six million overall must complete a Self-Assessment Questionnaire (SAQ) annually.
- Level 3 Merchants – Merchants with over 20,000 transactions need an annual SAQ.
- Level 4 Merchants – All other merchants must also submit an annual SAQ.
While levels 2, 3, and 4 all have the same documentation requirement, the scrutiny applied and the potential for discretionary placement at Level 1 increases alongside transaction volume.
Mastercard also specifies separate levels for service provider PCI compliance:
- Level 1 Service Providers – The following service providers need an annual SAQ:
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- Third-Party Processors (TPPs)
- Staged Digital Wallet Operators (SDWOs)
- Token Service Providers (TSPs)
- 3-D Secure Service Providers (3-DSSPs)
- Installment Service Providers (ISPs)
- Merchant Payment Gateways (MPGs)
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- Anti-Money Laundering (AML) and Sanctions Providers, Data Storage Entities (DSEs), and Payment Facilitators (PFs) with 300,000+ annual transactions
- Level 2 Service Providers – All Terminal Servicers (TSs) and AML and Sanctions providers, DSEs, and PFs with fewer than 300,000 annual transactions need an SAQ.
Every organization has the same general controls to apply, but the assessment needed for each can differ significantly. See below for more information on how to prepare for each kind of audit.
Monitor Controls and Audit Readiness
For many organizations, the biggest hurdle to PCI DSS compliance is the implementation and ongoing management of all required controls. Similar to other regulatory frameworks, protections need to be installed to fully protect CHD across all organizational systems.
As an overview, the core requirements of the PCI DSS framework break down as follows:
- Building Secure Network Systems
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- Requirement 1: Install Network Security Controls
- Requirement 2: Apply Secure Configurations
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- Protecting Account Data
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- Requirement 3: Protect Account Data in Storage
- Requirement 4: Encrypt CHD for Secure Transmission
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- Managing Vulnerabilities
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- Requirement 5: Protect Against Malicious Software
- Requirement 6: Maintain Secure Systems and Software
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- Implementing Access Control
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- Requirement 7: Restrict Access by Business Need to Know
- Requirement 8: Identify and Authenticate Access to Systems
- Requirement 9: Restrict Physical Access to CHD Environments
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- Monitoring and Testing Networks
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- Requirement 10: Log and Monitor Access to Systems and CHD
- Requirement 11: Test System and Network Security Regularly
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- Maintaining a Security Policy
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- Requirement 12: Support Security with Policies and Programs
Each Requirement includes multiple controls and specifications, with testing metrics that vary based on your organization’s classification.
Once controls are installed, they need to be maintained for regular (re)assessment.
Practice Continuous Compliance Assessments
Compliance is not just about installing controls up to PCI DSS standards and forgetting about them. Organizations also need to maintain those controls over time, making adjustments and updates as necessary, and conducting annual assessments to verify that controls are functional.
One of the best ways to stay ready for compliance year-round is to implement a continuous compliance assessment (CCA) program with regular (i.e., monthly) readiness assessments.
As mentioned above, there are two main kinds of official assessments to account for:
- Self-Assessment Questionnaire (SAQ) – Eligible organizations self-assess their control deployment up to standards specified in the PCI-provided documentation.
- Report on Compliance (ROC) – Qualified Security Assessors (QSAs), vetted by the SSC, conduct elaborate testing and submit detailed reports on all required controls.
CCA helps organizations know if they’re ready for an upcoming SAQ or ROC ahead of time.
There are many variations of the SAQ for different kinds of service providers and merchants, loosely aligned with the breakdown of levels detailed above. There are minimal differences between them, but organizations need to be certain they’re filling out the correct document.
Whichever report is completed, it must be submitted alongside an Attestation of Compliance (AOC) signed by the organization for an SAQ or the third-party provider for an ROC. The AOC summarizes and affirms the contents of the reports to be accurate and assures accountability.
Implement PCI as a Service (PCIaaS)
One of the best ways to ensure long-term PCI DSS certification, across compliance periods, is to implement a streamlined PCI as a service (PCIaaS) solution. PCIaaS providers combine all elements of achieving and maintaining PCI compliance into a single, easy-to-manage package.
For organizations new to PCI DSS compliance, PCIaaS providers may begin with a readiness or gap assessment to identify any potential issues. This is followed by a targeted control installation or remediation to ensure all required protections are in place and ready for an official SAQ or ROC.
For organizations targeting recertification, PCIaaS eliminates costly crunch cycles by maintaining continuous compliance, thereby reducing the intensive preparation required before annual audits. Rather than cramming any necessary updates or other maintenance into a tight window, experts spread it out over a manageable timeline.
Another major benefit of PCIaaS is the way it can streamline compliance across the board.
For many organizations, PCI DSS is just one of multiple frameworks they need to manage simultaneously. PCIaaS includes mapping and overall scope reduction to minimize costly overlap, navigate seeming contradictions or conflicts of interest, and streamline processes.
PCIaaS makes PCI compliance easy to achieve, short-term, and manage, long-term.
Streamline Your PCI DSS Compliance Today
PCI compliance is absolutely essential for any organization that wants to process payments securely and provide assurance to its clientele, personnel, and partners. Staying on top of compliance procedures means constant scoping and monitoring, assessing your readiness regularly, and, ideally, implementing a comprehensive PCI DSS management solution.
RSI Security has helped countless organizations achieve and maintain PCI compliance. We’re recognized by the PCI SSC as a QSA and Approved Scanning Vendor (ASV) who can assist with both individual scanning requirements and overall SAQ/AOC/ROC preparation. And we’re committed to a human-first, disciplined approach, unlocking greater freedom down the road.
To learn more about our PCI DSS services, including PCIaaS, contact RSI Security today!
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