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10 Best Practices and 3 Core Strategies for Maintaining PCI DSS Compliance

The article outlines that maintaining PCI DSS compliance requires a continuous, integrated security program encompassing comprehensive policies, procedures, and performance metrics, along with designated ownership to coordinate security activities, emphasizing ongoing protection of cardholder data beyond just passing assessments.

Achieving compliance with the Payment Card Industry Data Security Standard (PCI DSS) is challenging and can require significant time and resources. Organizations invest heavily to secure credit card data and maintain the high level of cardholder data protection required for PCI DSS compliance. However, maintaining compliance is an ongoing process that requires continuous attention.

The PCI Security Standards Council (PCI SSC) has outlined 10 essential steps for maintaining PCI compliance:

  1. 1.

    Develop and Maintain a Sustainable Compliance Program

    • Integrate your compliance program with your organization's overall security strategy. Monitor the effectiveness of security controls continuously to maintain compliance between assessments. The primary goal should be the ongoing security of cardholder data, not just achieving a compliant report.
  2. 2.

    Develop a Program, Policy, and Procedures

    • A comprehensive PCI DSS compliance program should include people, processes, technology, and supporting policies and procedures (such as an information security policy). This ensures proper protection of payment card data and repeatable business processes.
      • Program: Includes strategic objectives, roles, responsibilities, and plans to achieve business objectives (e.g., vendor-management program).
      • Policy: States management intent or rules to be followed (e.g., security policy for anti-virus updates, password policy).
      • Process/Procedure: Outlines step-by-step instructions for tasks and policy support (e.g., firewall configuration, security system testing, data encryption procedures).
  3. 3.

    Define Performance Metrics to Measure Success

    • Establish a metrics program to allocate resources, minimize risk, and measure the impact of security events. Define the scope of measurement based on organizational needs, goals, risk priorities, and compliance maturity.
  4. 4.

    Assign Ownership for Coordinating Security Activities

    • Designate a manager responsible for continuous PCI DSS compliance to oversee coordination of resources, monitoring, projects, and costs.
  5. 5.

    Emphasize Security and Risk Management to Attain and Maintain Compliance

    • Focus on building a culture of security and protecting information assets. Compliance should be a result of strong security practices, not the sole objective.
  6. 6.

    Continuously Monitor Controls

    • Regularly monitor, test, and document the implementation and effectiveness of security controls and PCI compliance activities.
  7. 7.

    Detect and Respond to Control Failures

    • Implement processes to promptly recognize and respond to security-control failures. Response should include:
      • Minimizing incident impact
      • Restoring controls
      • Root-cause analysis and remediation
      • Implementing hardening standards
      • Enhancing monitoring
  8. 8.

    Maintain Security Awareness

    • Establish a formal security awareness process to address the latest cybercrime trends and prevent social engineering attacks.
  9. 9.

    Monitor Compliance of Third-Party Service Providers

    • If third parties manage your PCI DSS controls, monitor their compliance and adjust your relationship if their status changes.
  10. 10.

    Evolve the Compliance Program to Address Changes

    • Update controls as new threats emerge and as organizational structures, business initiatives, and technologies change.

Three Core Strategies

These steps fit into three core strategies for PCI DSS compliance:

  1. 1.

    Dedicate Program Resources Perpetually

    • Invest in information security by updating technologies and training personnel to meet PCI DSS requirements.
  2. 2.

    Assess and Test Your Information Security Environment

    • Regularly assess and test your security environment and controls. Methods include:
      • Penetration testing
      • Internal and external vulnerability scanning
      • Security awareness training
      • Compliance review
      • Risk assessment
  3. 3.

    Shore Up Your Vulnerability Management Program

    • Manage vulnerabilities in systems, networks, and data to maintain a secure environment. Key activities include:
      • Patching and patch management
      • Firewall and router configurations
      • Application security
      • Data integrity assessment
      • Reviewing logs, alerts, and access permissions
    • Regular vulnerability scans by an approved scanning vendor (ASV) may be required.

Being PCI compliant means protecting payment card data at every step of payment processing, including sensitive authentication data and both onsite and e-commerce transactions. The requirements your organization must meet depend on its compliance level, which is determined by the number of transactions processed annually and the card brands involved. Each level (1, 2, 3, and 4) has different criteria and requirements.

Lower-level merchants may use Self-Assessment Questionnaires (SAQs) to report compliance, with the specific SAQ depending on the types of transactions processed. Continuous annual requirements, such as quarterly vulnerability scans and annual assessments by a Qualified Security Assessor (QSA), may apply.

Maintaining a compliant cardholder data environment requires ongoing effort. PCI DSS provides best practices and testing procedures to help organizations achieve and maintain compliance.