Preparing for PCI DSS compliance

Recently I have taken over some of the security aspects within the organization, specifically our PCI DSS compliant.  I am going to try to create a series of posts where I will be going over each of the requirements with some commentary on how to meet them.

As a merchant, we are required to protect the customers payment card information from those who wish to defraud our customers.Payment Card Industry Data Security Standard (PCI DSS) is a set of requirements that helps us merchants protect the consumer from bad people.  The PCI DSS requirements are broken into 12 high level sets.  The 12 sets of requirements are again grouped into 6 groups*.

  • Build and Maintain a Secure Network and Systems
    • Install and maintain a firewall configuration to protect cardholder data
    • Do not use vendor-supplied defaults for system passwords and other security parameters
  • Protect Cardholder Data
    • Protect stored cardholder data
    • Encrypt transmission of cardholder data across open, public networks
  • Maintain a Vulnerability Management Program
    • Protect all systems against malware and regularly update anti-virus software or programs
    • . Develop and maintain secure systems and applications
  • Implement Strong Access Control Measures
    • Restrict access to cardholder data by business need to know
    • Identify and authenticate access to system components
    • Restrict physical access to cardholder data
  • Regularly Monitor and Test Networks
    • Track and monitor all access to network resources and cardholder data
    • Regularly test security systems and processes
  • Maintain an Information Security Policy
    • Maintain a policy that addresses information security for all personnel

One of the topics that I have found to be most contentious is around what constitutes cardholder data and cardholder data.  The PCI gives the following definition for both cardholder and cardholder data:

Cardholder: Non-consumer or consumer customer to whom a payment card is issued to or any individual authorized to use the payment card.

Cardholder Data: At a minimum, cardholder data consists of the full Primary Account Number (PAN). Cardholder data may also appear in the form of the full PAN plus any of the following: cardholder name, expiration date and/or service code

Since implementing the Utopian security policies is not a reality, these definitions are contorted almost to the breaking point.  Another good neighbor guidance is the protection of the Personally identifiable information (PII).  PII guides us to make sure that malicious individuals cannot gain access to your personal information, such that it can be used,again, to defraud the customer.  If you focus your eyes on both PCI and PII, then the meaning of cardholder data becomes much less subjective.

Next time, I will start in on Building and Maintain a Secure Network and Systems (requirements 1 & 2).

* Requirements and Security Assessment Procedures. N.p.: PCI Security Standards Council, LLC., Apr. 2015. PDF.

** Glossary of Terms, Abbreviations, and Acronyms. N.p.: PCI Security Standards Council, LLC., Apr. 2015. PDF.

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