How to Prepare for a PCI SSF Assessment

As the Payment Card Industry (PCI) Software Security Framework (SSF) becomes the standard for securing payment applications, understanding its scope and compliance requirements is essential for organizations in the payment software space. The SSF was created to replace the outdated Payment Application Data Security Standard (PA-DSS) and introduces two key components in the framework: the Secure Software Standard and the Secure Software Lifecycle (Secure SLC) Standard. With a focus on securing both the software itself and the development processes, the SSF provides a comprehensive framework for ensuring the safety and privacy of payment systems. In this blog post, we’ll walk you through the key steps to prepare for a PCI SSF assessment, ensuring your organization is fully compliant with these important standards.

 

Understand the Scope of the SSF

The Payment Card Industry (PCI) Software Security Framework (SSF) is a modern standard that replaces the now-retired Payment Application Data Security Standard (PA-DSS). Overseen by the PCI Security Standards Council (SSC), the SSF ensures the security and privacy of payment applications by safeguarding both the software and its development processes.

The SSF consists of two key components: the Secure Software Standard and the Secure Software Lifecycle (Secure SLC or SSLC) Standard.

• Secure Software Standard: Focuses on securing payment software, including default settings and configurations that protect sensitive payment data.
• Secure Software Lifecycle Standard: Ensures security within the development environment, establishing protections for how payment software is created and maintained.

Your organization’s role in payment software determines which part—or both—of the SSF applies. Compliance may require implementing separate sets of controls and undergoing distinct assessments for each standard. Additionally, other PCI frameworks, such as the Data Security Standard (DSS), may also be relevant.

 

Meet PCI Secure Software Standard Requirements

If your organization is subject to the Secure Software Standard, it’s essential to implement its control objectives. Even if it doesn’t currently apply, understanding its scope is beneficial for future considerations.

The Secure Software Standard outlines 12 Control Objectives, organized into four categories:

1. Requirements for Minimizing the Attack Surface:

• Control Objective 1: Identify critical assets.
• Control Objective 2: Implement secure defaults.
• Control Objective 3: Retain sensitive data securely.

2. Required Software Protection Mechanisms:

• Control Objective 4: Protect defined critical assets.
• Control Objective 5: Control authentication and access.
• Control Objective 6: Protect retained sensitive data.
• Control Objective 7: Utilize strong cryptography.

3. Requirements for Secure Software Operations:

• Control Objective 8: Track activity.
• Control Objective 9: Detect attacks.

4. Requirements for Secure Software Lifecycle Management:

• Control Objective 10: Manage threats and vulnerabilities.
• Control Objective 11: Ensure security updates are installed.
• Control Objective 12: Provide vendor implementation guidance.

In addition to these foundational controls, the Standard includes specific modules with additional controls tailored to particular types of software and the organizations that develop, vend, or manage them. Depending on your organization’s software, one or more of these Modules may apply, leading to variations in implementation and assessment processes.

It’s important to note that the PCI Security Standards Council periodically updates these standards to address emerging security challenges. For instance, version 1.2 of the Secure Software Standard introduced the Web Software Module to address common security issues related to internet-accessible payment technologies. 

 

 

Implement PCI Secure SLC Controls

If your organization falls under the scope of the Secure Software Lifecycle (Secure SLC) Standard, it’s essential to implement its control objectives. Even if it doesn’t currently apply, familiarizing yourself with its scope can be beneficial for future considerations.

The Secure SLC Standard comprises 10 Control Objectives, organized into four categories:

1. Requirements for Software Security Governance:

• Control Objective 1: Designate security responsibilities and resources.
• Control Objective 2: Disseminate software security policies and strategies.

2. Requirements for Secure Software Engineering:

• Control Objective 3: Implement threat identification and mitigation.
• Control Objective 4: Implement vulnerability detection and mitigation.

3. Requirements for Secure Software and Data Management:

• Control Objective 5: Monitor and manage changes across systems.
• Control Objective 6: Implement protections for software integrity.
• Control Objective 7: Implement protections for sensitive data.

4. Requirements for Security Communications:

• Control Objective 8: Provide implementation guidance for vendors.
• Control Objective 9: Ensure stakeholder communication infrastructure.
• Control Objective 10: Ensure timely communication regarding updates.

Unlike the Secure Software Standard, the Secure SLC Standard does not include additional modules specific to certain organizational settings. All applicable organizations are required to implement and assess the same set of control objectives.

 

Conducting a PCI SSF Assessment

To ensure compliance with the PCI Software Security Framework (SSF), organizations must undergo assessments conducted by PCI-qualified SSF Assessor Companies. These assessments evaluate adherence to the Secure Software Standard and/or the Secure Software Lifecycle (Secure SLC) Standard. A list of qualified assessor companies is available on the PCI Security Standards Council (PCI SSC) website.

The assessment process involves a thorough evaluation of all systems related to the development and maintenance of payment software. Upon successful assessment, the assessor will generate a Report on Validation (ROV) confirming that all applicable control objectives have been met. Additionally, the organization must complete an Attestation of Validation (AOV) to affirm their compliance status.

Prior to the official certification audit, organizations may opt to engage in gap and readiness assessments with their assessor or compliance advisor. These preliminary evaluations help identify areas needing improvement, providing greater assurance of successful verification during the formal assessment.

It’s also beneficial to align SSF compliance efforts with other PCI standards, such as the Data Security Standard (DSS). Although the SSF and DSS are distinct frameworks, they share foundational security principles. As your organization prepares for DSS v4.0.1 compliance, consider leveraging existing controls and collaborating with assessors to streamline compliance across both standards.

 

 

How to Prepare for a PCI SSF Assessment

Now that you understand the context of PCI SSF, here’s how to prepare for the assessment:

1. Understand the Scope of Compliance:
   Start by understanding which parts of the SSF apply to your organization—either the Secure Software Standard, the Secure Software Lifecycle Standard, or both. Evaluate whether additional PCI frameworks, such as the Data Security Standard (DSS), may also be relevant to your compliance efforts.
2. Review Control Objectives:
   Familiarize yourself with the control objectives for both the Secure Software Standard and the Secure SLC Standard. Identify where your current processes and security measures align with the required objectives and where gaps may exist.
   • For the Secure Software Standard, ensure that your organization is meeting objectives like securing sensitive data and using strong cryptography.
   • For the Secure SLC Standard, focus on governance, secure engineering practices, and communication of security updates.
3. Conduct Gap and Readiness Assessments:
   Before undergoing the formal assessment, consider working with a PCI-listed assessor or compliance advisor to conduct a gap assessment. These assessments identify areas where your organization may fall short and provide recommendations for achieving compliance. Readiness assessments also ensure that you are fully prepared for the official audit, reducing the risk of surprises.
4. Implement Corrective Actions:
   If gaps are identified during your readiness assessment, prioritize implementing corrective actions. This might include enhancing your software development lifecycle security, revising data protection practices, or updating cryptographic measures.
5. Establish Documentation and Reporting:
   Proper documentation is essential for a successful assessment. Ensure that all relevant processes, controls, and evidence of compliance are well-documented and readily available for your PCI assessor. Your assessor will use this information to generate the Report on Validation (ROV) and the Attestation of Validation (AOV).
6. Align SSF Compliance with Other PCI Standards:
   If your organization is also preparing for compliance with PCI DSS, align your SSF controls with DSS controls where possible. Many of the security principles overlap between the two standards, and aligning them can streamline your overall compliance efforts, making the process more efficient and less resource-intensive.
7. Ongoing Monitoring and Updates:
   After completing the assessment, it’s important to maintain continuous monitoring and improvement. The PCI SSC regularly updates its standards to reflect emerging threats, so staying current with the latest security updates and maintaining ongoing compliance is crucial for long-term security.

By following these steps, you’ll be well-prepared for a successful PCI SSF assessment and ensure that your organization is compliant with the latest security standards for payment software.

 

Streamline Your SSF Compliance Today

Preparing for SSF compliance involves understanding the scope of both standards, implementing the required controls, and selecting an assessment partner to validate your compliance. RSI Security has extensive experience helping organizations navigate PCI regulations, including the DSS and PA-DSS. Now, we’re here to assist you in preparing for the future of SSF compliance. We are committed to ensuring the right solutions are in place to safeguard your data. 

To learn more about the PCI Secure Software compliance requirements and how partnering with a qualified advisor or assessor can streamline your process, contact us today!

 

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