Compliance with PCI DSS is not as simple as implementing a few technical security controls, but requires a holistic approach to security that runs throughout the entire organization. PCI compliance should be a “business as usual” activity, woven into the day-to-day activities of personnel in all aspects of the business. To achieve and maintain compliance with PCI DSS 4.0, organizations need to move far beyond the “check-the-box” mindset and adopt a comprehensive strategy that aligns with their specific industry and environment. The holistic approach emphasizes the implementation of appropriate security controls as well as monitoring the effectiveness of those controls and making ongoing adjustments to the organization’s security program.
Implementing the Appropriate Security Controls
Effective security controls are the basis of a holistic approach to PCI compliance. Rather than implementing the controls blindly, organizations must conduct a thorough inventory of not only their cardholder data environment (CDE), but the “connected to” systems and environments supporting the security of the CDE. This critical component inventory should include infrastructure, software applications, payment applications, third party vendors, electronic cardholder data and physical locations. With this information, organizations can appropriately design their security controls to protect their entire PCI footprint.
“Set it and forget it” certainly does not apply when it comes to PCI compliance and good security practices; regular checkpoints to assess the effectiveness of the security controls are required. These checkpoints occur in various forms, such as internal audits and monitoring controls, regularly updating risk assessments, performing periodic vulnerability and penetration tests and undergoing third party compliance and security assessments. The perspective gained from these assessments provides valuable feedback to the organization as to what is working well and what needs adjustment.
Staying Vigilant Through Training and Collaboration
A holistic approach to security also requires regular employee security training as well as knowledge sharing with key outside entities. Regular training sessions on security topics such as phishing education and recognition and incident response protocols empower employees to be become an effective line of defense against internal and external threats to the organization and its cardholder data.
Knowledge sharing beyond the walls of the organization can occur through relationships with industry peers, attending conferences and forums and participating in special interest groups. Staying informed about emerging threats better enables organizations to adapt their security measures, ensuring new risks are addressed timely and effectively.
Implementing and maintaining a compliance program for PCI DSS 4.0 requires a holistic approach to security that extends beyond the checklist approach. The steps outlined above are just some of the areas to consider when designing a holistic security approach and can set an organization on the path to achieving PCI DSS v4.0 compliance.