How Privileged Access Management Can Aid in Achieving PCI DSS Compliance
Payment Card Industry Data Security Standard (PCI DSS) is a global standard that provides a baseline of technical and operational requirements designated to protect payment data. It is designed to ensure that all companies that accept, process, store, or transmit credit card information maintain a secure environment. The PCI DSS is mandated by the major credit card brands and administered by the Payment Card Industry Security Standards Council (PCI SSC), an independent body created by these brands.
Note: The latest version of the PCI DSS is version 4.0, which was released by the PCI Security Standards Council on March 31, 2022. It will officially replace the previous version, PCI DSS 3.2.1, on March 31, 2024.
Who Needs the PCI DSS Compliance?
Compliance with the Payment Card Industry Data Security Standard (PCI DSS) is required for any organization or business that handles cardholder data, irrespective of their size or transaction volume. This can include:
- Merchants: Any business that accepts credit or debit cards as a form of payment, either online or in a physical store. This applies to all merchants, regardless of their size or the number of transactions they process.
- Payment Processors: Companies that process credit or debit card transactions on behalf of merchants.
- Service Providers: Any third-party service provider that handles, processes, stores, or transmits credit card data on behalf of another entity. This includes companies offering services like hosting, payment gateways, data storage, and managed security.
- Financial Institutions: Banks, credit unions, and other financial institutions that issue debit and credit cards or are involved in processing card payments.
- Payment Networks and Card Brands: The major credit card brands (Visa, MasterCard, American Express, Discover, and JCB) that are part of the PCI Security Standards Council also adhere to these standards.
Scope of PCI DSS Requirements
The scope of PCI DSS is both specific and comprehensive, covering a wide range of entities and systems within an organization. Central to this scope is the cardholder data environment (CDE), which encompasses all the system components, personnel, and processes that store, process, or transmit cardholder and sensitive authentication data. More than just these direct interactions, the scope also extends to any system components with unrestricted access to the CDE, regardless of whether they directly handle cardholder data. This includes a variety of network devices, servers, and computing devices, as well as virtual and cloud components, each playing a role in the overall security of the data. Additionally, the PCI DSS applies to any component or individual that could potentially impact the CDE’s security. The expansive nature of this scope underlines the PCI DSS’s holistic approach, ensuring that every aspect related to cardholder data is secure and compliant.
It is worth mentioning that the scope of a PCI DSS assessment can be reduced with the use of segmentation, which can be achieved by creating a dedicated and isolated network zone specifically for cardholder data. This targeted approach not only simplifies compliance efforts but also offers cost benefits by reducing both the assessment expenses and the complexity involved in enforcing PCI DSS measures. A crucial point to note is that any system component deemed outside the PCI DSS scope must be rigorously segregated from the cardholder data environment (CDE). This ensures that even if a breach occurs in these out-of-scope areas, the security of the CDE remains uncompromised.
The 12 Requirements of PCI DSS
The requirements of the PCI DSS are specific guidelines and security measures that organizations must follow to protect cardholder data. These requirements include maintaining a secure network, protecting account data, maintaining a vulnerability management program, implementing strong access control measures, regularly monitoring and testing networks, and establishing an information security policy. There are 12 technical and operational requirements, organized under six primary goals:
Build and Maintain a Secure Network and Systems
Requirement 1: Install and Maintain Network Security Controls.
Requirement 2: Apply Secure Configurations to All System Components.
Protect Account Data
Requirement 3: Protect Stored Account Data.
Requirement 4: Protect Cardholder Data with Strong Cryptography During Transmission Over Open, Public Networks.
Maintain a Vulnerability Management Program
Requirement 5: Protect All Systems and Networks from Malicious Software.
Requirement 6: Develop and Maintain Secure Systems and Software.
Implement Strong Access Control Measures
Requirement 7: Restrict Access to System Components and Cardholder Data by Business Need to Know.
Requirement 8: Identify Users and Authenticate Access to System Components.
Requirement 9: Restrict Physical Access to Cardholder Data.
Regularly Monitor and Test Networks
Requirement 10: Log and Monitor All Access to System Components and Cardholder Data.
Requirement 11: Test Security of Systems and Networks Regularly.
Maintain an Information Security Policy
Requirement 12: Support Information Security with Organizational Policies and Programs.
This foundational set of requirements for securing account data can be supplemented with extra controls and practices for added risk mitigation, including adherence to local, regional, and sector-specific laws and regulations. Furthermore, certain legal or regulatory mandates may necessitate specific safeguards for personal information or other types of data, such as the cardholder’s name.
Approaches for Implementing and Validating PCI DSS
In implementing and validating PCI DSS, there are primarily two approaches:
- Standardized Approach: This method involves following the specific requirements of PCI DSS as they are written. It’s straightforward and commonly used, especially by organizations that prefer a clear, guideline-based strategy to ensure compliance.
- Customized Approach: This approach is more flexible and allows organizations to tailor their security controls to their unique environments but also requires significant initial planning and detailed documentation. It is best suited for organizations with mature risk management processes, demonstrating high levels of security and risk management capabilities. Such entities are equipped to effectively create, document, test, and sustain comprehensive security controls that align with the intended objectives. This approach is not a one-size-fits-all solution but is tailored to organizations that already have strong security foundations and can develop and manage advanced security measures
The choice between these approaches depends on the organization’s specific needs, capabilities, and the complexity of their payment processing environments. The Standardized Approach offers a more direct path to compliance, while the Customized Approach allows for more tailored security measures, provided the organization has the necessary expertise and resources.
How Privileged Access Management Can Aid in Achieving PCI DSS Compliance
Now it’s time to analyze the areas where Privileged Access Management solutions can typically help in achieving PCI DSS compliance. Below, you will find the main requirements that PAM can impact and a brief description of how it can help:
Goal: Implement Strong Access Control Measures
- Requirement 7: Restrict access to cardholder data by business need-to-know
How PAM helps: PAM ensures that access to critical data is granted strictly based on the principle of least privilege, allowing only necessary personnel to access sensitive data based on their roles.
- Requirement 8: Identify users and authenticate access to system components
How PAM helps: PAM solutions manage and monitor user access through unique identification and strong authentication mechanisms, including multi-factor authentication. This ensures that only authorized users can access system components and all actions taken on critical data and systems can be traced, reducing the risk of unauthorized access.
Goal: Regularly Monitor and Test Networks
- Requirement 10: Log and monitor all access to system components and cardholder data
How PAM helps: PAM solutions are excellent for logging and monitoring all user activities, especially for privileged accounts. They excel in tracking and auditing access to network resources and sensitive data. It logs and monitors all privileged user activities, which is essential for anomaly detection, security investigations, and ensuring that access policies are being followed.
- Requirement 11: Test security of systems and networks regularly
How PAM helps: PAM solutions can also indirectly help achieve compliance with this requirement, as it can be used to detect and respond to network intrusions. PAM can play a role in regular security audits and tests to ensure effectiveness.
Goal: Maintain an Information Security Policy
- Requirement 12: Support information security with organizational policies and programs
How PAM helps: PAM can help implement and enforce security policies regarding who can access what data and under what conditions. By managing and controlling privileged accounts, PAM ensures that only authorized personnel have access to sensitive systems and data, in line with the organization’s access control policies.
The comprehensive PCI DSS specification covers a wide array of payment card security aspects, extending beyond the capabilities of Privileged Access Management (PAM) alone. However, a well-implemented PAM solution plays a crucial role in meeting many of the critical requirements set by PCI DSS. Therefore, the true value of PAM lies not just in facilitating compliance but also in creating a secure, alert, and flexible business environment. It’s important to remember that adhering to the Payment Card Industry Data Security Standard (PCI DSS) is not a mere one-off task but a continuous process dedicated to upholding and ensuring the security of cardholder data.