Organizations involved in developing, selling, or managing payment applications must ensure robust protections for payment data at every stage of its lifecycle. The PCI Software Security Framework (SSF) is a set of security standards designed to ensure PCI SSF compliance by protecting payment software throughout its lifecycle. It provides guidelines for the secure development and maintenance of payment applications. A critical aspect of SSF implementation is determining data interactions, which helps shield payment data from unauthorized access and security breaches. Keep reading this blog post to understand where, when, and how data interactions occur and the role PCI SSF plays in safeguarding your payment data.
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Determining Data Interactions for PCI SSF Compliance
In 2021, the Payment Card Industry (PCI) Security Standards Council (SSC) released a new framework to protect payment software. Developers, vendors, and others who had previously needed to abide by the Payment Application Data Security Standard (PA-DSS) now need to implement the Software Security Framework (SSF) to remain fully compliant with the PCI.
Determining data interactions serves as a cornerstone of SSF implementation, ensuring that payment data is protected from unauthorized access and other compromising events. Organizations must assess their entire payment data ecosystem to identify all potential interaction points, ensuring alignment with PCI SSF requirements. SSF data determination comes down to:
- Monitoring intake and input channels for payment data
- Limiting storage of payment data to specific locations
- Documenting all processes enacted on payment data
- Controlling access to systems housing payment data
- Restricting transmissions of or impacting payment data
Working with a dedicated PCI SSF advisory partner is the best way to ensure that all data is accounted for and controls are in place to streamline PCI SSF certification and compliance.
Step 1: Monitor Data Intake and Input Channels
It all starts with intake. If determining data interactions means understanding the who, when, and where of data processing, then input monitoring grants visibility into what data is being interacted with. Organizations must establish transparency across all ports and input channels where payment data enters or interacts with software systems, enabling comprehensive tracking throughout its lifecycle. In practice, you’ll need sensors to identify, tag, and report on data from the moment it becomes present to or within the software.
Data intake is the first interaction that payment data makes with your software. Implementing monitoring tools, such as sensors and automated logging systems, can provide real-time visibility into data intake processes.
The PCI SSF covers protections for software and hardware that comes into contact with payment data, including at the point of interaction (POI) with physical media (i.e., terminals). The framework’s 12 Core Control Objectives apply across all payment software. Furthermore, its Module B Control Objectives apply specifically to terminals and POI systems. If software you develop, sell, or manage includes terminal functionality, its interactions are in scope for PCI SSF.
Step 2: Limit Data Storage to Select Locations
The next consideration is a natural extension of the first. Beyond monitoring and securing payment data when it first enters a system, organizations should also ensure that any data retained is as secure as it can be for the duration it stays wherever it stays. Data in storage might seem like it is “at rest” or not being interacted with, but time spent in storage is actually interactive in and of itself. Data in storage is interacting with storage systems as a process.
The implications for determining data interactions are twofold:
- Payment data in storage needs to be monitored and secured, not forgotten about
- The extent of data storage should be limited to the absolute minimum necessary
Data storage should be treated as an active process requiring robust monitoring and control measures. The second part is actually covered extensively in the SSF’s Control Objective 3.1. This control requires that software only retains sensitive data that is absolutely necessary for the software’s intended functionality, which is a limit on the amount of data that is retained. And Control Objective 3.2 adds a temporal factor, specifying that data should only be kept for a duration that is necessary to perform legitimate business purposes. Organizations should also employ encryption, access control, and automated alerts to secure stored payment data effectively.
Understanding data storage as an interaction helps achieve these aims efficiently.
Step 3: Document All Processes Applied to Data
This is arguably the most obvious of the phases, but it still needs to be taken seriously and conducted with attention to detail. Any process that is applied to data, beyond baseline intake and storage, needs to be documented and secured. This includes but is not limited to the kinds of interactions that make changes to data or metadata, such as movements or changes to the data itself. Instances of data access or reading, even without modifications, are considered interactions under PCI SSF compliance and must be documented.
With respect to PCI SSF requirements, Control Objective 8 requires granular activity tracking such that uses and attempted uses of sensitive data are documented and tracked to specific users. In practice, monitoring for data processes goes hand-in-hand with access control (see below), as you need to account for both actual processes and potential user activities. Automated documentation tools can help track and record these interactions consistently, reducing the risk of oversight.
Control Objective 5 in the Secure Software Lifecycle Framework (Secure SLC) specifically covers secure change management for developers. It ensures that data interactions and processes during the production of payment software are accurately accounted for.
Step 4: Control Access to Data and Connected Systems
Access control is one of the most critical parts of any cyberdefense deployment, and it can be seen as a catchall way to account for any and all kinds of data interactions. With respect to PCI SSF compliance, you can consider any access to (or attempted access to) sensitive payment data as a kind of interaction with it. This means that an interaction in which a user gains access to and then performs another action on data (i.e., read, change, transmit) actually comprises several interactions rather than one continuous one. Each interaction, from access requests to subsequent data manipulations, must be documented and secured at a granular level.
In terms of specific PCI SSF requirements, the most pertinent Control Objectives fall under 5, governing authentication and access control. All access to sensitive payment data needs to be authenticated (5.1) using unique identification (5.2) and sufficiently strong access credentials (5.3). All of these elements should be considered part of the data interaction matrix for a given access request—a user authenticating to access data is itself an interaction that requires a tag. Implementing multifactor authentication (MFA) and role-based access controls (RBAC) enhances the security of data access processes.
Step 5: Restrict Transmissions of Sensitive Data
Finally, you need to account for data interactions that involve transmissions of sensitive payment information both within software systems and without. Any time data is being transmitted, the movement from one location to another or the communication from one party to another is an interaction for the purposes of PCI SSF compliance. It needs to be documented and secured.
There are many PCI SSF requirements that this step relates to. On one level, Control Objective 6.1 specifically requires sensitive data to be secured during transmission. But, on another level, very many objectives and their specifications make mention of transmission-specific rules and considerations. Data transmission is a critical interaction that requires meticulous attention due to its dynamic nature and involvement of multiple parties.
Accounting for all data interactions is easiest when working with a PCI SSF advisory partner.
Optimize Your PCI SSF Compliance Processes
To protect payment data, you must understand all the places and ways it interacts with the software and the broader systems it connects to. For organizations that develop, sell, or manage payment software, determining data interactions efficiently and accurately could spell the difference between compliance and noncompliance.
RSI Security has helped countless organizations achieve and maintain compliance with PCI standards. We know how critical payment data security is, and we’ll help you do that effectively.
To learn more about our PCI SSF compliance services, contact RSI Security today!
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