PCI DSS compliance policy and template
PCI-DSS (Payment Card Industry Data Security Standard) is a privately managed set of data security regulations for the credit card processing sector. PCI-DSS aims to safeguard cardholder data during and after transactions. And the regulations set down a strict set of compliance criteria to achieve this goal.
PCI-DSS compliance is crucial for online businesses that handle or store credit card data. Compliance prevents regulatory penalties. But it has other benefits as well. For instance, PCI compliance protects against data breaches and fraud.
This article will explain how to use PCI-DSS templates to create an effective compliance policy. Intelligent use of templates reduces errors and enhances data security. Read on to learn how templates can streamline and simplify the compliance process.
Why do you need a PCI policy?
- The scope of the Cardholder Data Environment (CDE)
- Access controls to guard the CDE
- Data protection tools such as encryption and threat management systems
- Incident response plans to safeguard data and restore functionality
- Auditing procedures to ensure data security
- Testing systems used to investigate and fix security issues
A PCI-DSS policy aims to inform key stakeholders. The policy should inform network users of their security responsibilities. It supplements employee or third-party training, providing a baseline to assess user activity.
A good PCI policy also feeds into strong data security practices. The policy helps define security objectives and identifies critical assets. Companies can identify areas of improvement, such as protocols and access controls. Meeting PCI security standards will lead to improved data protection, fewer data breaches, and lower financial losses.
Moreover, PCI policy documents provide clarity for regulators, customers, and auditors. It builds confidence in a company's commitment to security. Outsiders can easily assess security controls and the organization's overall security posture.
This matters because security is a core part of how companies are assessed. Organizations with poor security and compliance records will lose out to competitors with robust compliance processes.
What should a PCI policy include?
IT teams should take care to include all relevant parts of a PCI-DSS policy. This template structure includes the most important elements:
Scope
This section defines areas covered by the policy. This includes critical systems, processes, and network users covered by PCI-DSS compliance.
Roles and responsibilities
Describes the role played by individuals and teams in protecting cardholder data. This is a general statement that network users must follow the compliance policy and meet their responsibilities. Specific roles and responsibilities are listed in the security controls section below.
Security objectives
Outlines the overall security aims of the organization. This brief statement of objectives should focus on securing the cardholder data environment in line with PCI-DSS compliance.
Security controls
This in-depth section of the policy details the security controls required to protect customer data. Each control should include three sections:
- Purpose – Why the security control is a critical PCI-DSS requirement
- Audience – Who the security control applies to
- Policy – How the information security control meets a specific PCI-DSS requirement
Relevant security controls include:
Access management
Access controls determine who has access to the CDE, when they have access and the actions they can take. This applies to anyone who can access cardholder data. It also includes rules for device usage, both on-site and remotely. Document any authorization systems in use, including attribute or role-based access controls.
Account management
Details how user accounts are created, managed, and deleted. This includes a mandatory agreement to comply with security policies. Accounts should have unique IDs. Account sharing should be prohibited. This section may include details about multi-factor authentication (MFA) or 2FA systems. It may also deal with third-party or vendor accounts if applicable.
Data encryption
Defines the encryption standards used to protect customer data, as well as how to store encryption keys and sensitive authentication data.
Data protection and retention
Includes guidelines for the retention and secure deletion of cardholder data. This should include controls to protect payment card data such as Primary Account Numbers (PANs), as well as encryption of all other credit card data.
Firewalls
How firewalls are configured, and how firewall protection guards secure zones within the CDE. Includes firewall requirements for remote devices. May also feature details about segmentation to create DMZs for the most sensitive data.
Device management
Details how the organization manages digital and physical assets to guard data. Includes devices to take payments and communicate cardholder data. Also includes the need to inventory all devices and log device maintenance activity. Backup security is also part of this section.
Network management
Deals with network infrastructure within the scope of the CDE. Standard security configurations should enforce device patching and changing vendor defaults. Companies should create data flow diagrams to track cardholder data throughout the network. Every device should be covered by anti-virus software. Encryption should protect wireless networks, with specific controls for wireless access points.
Activity logging
Demonstrates that the organization keeps audit trails for all devices and users. Mandates the use of timestamps for all access requests and actions. Audit trails should be secured from tampering. And logs must be reviewed to detect security issues.
Incident response
How the organization responds during security incidents. Under PCI-DSS rules, the organization requires a response plan that is tested annually. Security teams should be available to respond to security alerts at all times.
Physical access
Any devices within the scope of the CDE require access controls. Companies should also closely monitor physical access via cameras and sensors. Physical access should be determined by role, with time-limited access to devices hosting cardholder data. Visitor management should identify and authorize all external visitors.
Remote access
There should be separate controls for remote access to the CDE. This includes MFA and the use of data tracking to prevent the movement of sensitive data. The organization should approve all remote devices. It should include rules about storing sensitive authentication data and avoiding insecure public networks.
Software development
Includes rules about the creation and maintenance of CDEs. This section mainly deals with the responsibilities of developers. All personal cardholder data should be removed during testing processes. App developers should follow secure coding practices. And there must be specific controls to protect public-facing web applications.
Vulnerability management
This section defines procedures to detect security vulnerabilities. It can be included as a sub-section under security controls or added as a separate section. In either case, this section should cover PCI-DSS requirements such as:
Network scanning
Network scans should be carried out quarterly. Organizations should enlist Approved Scanning Vendors (ASVs) to execute network scans. The scan should assess vulnerabilities according to severity. Re-scanning may be needed until all vulnerabilities have been fixed.
Regular patch management
IT teams should update all software within the CDE as soon as new security patches are available. Network scans should establish the need for software updates if patches are not already in place.
Penetration testing
The policy may require annual penetration testing by an ASV. This simulates common network attacks and suggests areas of improvement.
Intrusion detection/prevention systems (IDPS) should detect incoming threats and apply controls to neutralize attacks.
Training
Explains training and employee awareness programs in place to meet every PCI-DSS requirement. Training should revolve around data security responsibilities, and programs should cover all users with CDE components.
Monitoring
The policy should define processes to monitor PCI compliance. This includes regular audits in line with the organization's PCI level. It also includes threat assessments and incident reporting.
Enforcement
A brief section that establishes penalties for not following the PCI policy. Violations may include internal disciplinary action, termination, or even criminal penalties. This section should also include penalties for vendors, including termination of agreements and prosecution.
Policy reviews
Establishes a schedule for reviewing PCI-DSS policies. This should take into account new regulations, changes to the organization's operational structure, and technological developments.
PCI-DSS templates should include all of these elements to comprehensively meet regulatory goals. Click here to download a sample PCI policy template featuring the necessary elements.
How to create PCI policy templates
Following PCI templates is advisable. Templates include all relevant areas and also focus the attention of IT teams to meet PCI-DSS goals. They eliminate less important data security measures, shifting the focus to issues that fall under PCI rules.
Organizations can download pre-prepared templates or follow the structure above. Templates enable administrators to customize the structure and content of their PCI compliance policy. If you choose to create your own template, follow the advice below to create a watertight compliance document.
1. Understand PCI-DSS requirements
Before writing anything, policy writers must be familiar with PCI regulations. IT teams should establish the PCI level of their organization. And they should define which credit card companies are relevant to their compliance challenge.
Compliance requirements vary slightly between companies. For instance, American Express has different requirements than Mastercard when securing cardholder data. Policies need to meet business needs. Writers must know exactly what they are protecting, and what regulators expect from them.
2. Customize your template to meet organizational needs
Every PCI-DSS-compliant organization is different. CDEs vary between organizations. Each company has a unique set of operations, systems, and processes. Its PCI compliance policy must reflect that diversity.
Take into account your industry sector and the size of the company. And factor in specific security needs. Some companies have large physical data centers that process cardholder data. In that case, video storage could be a core PCI-DSS requirement. Others manage multi-cloud payment environments. Micro-segmentation and encryption could be all-important for these organizations.
PCI compliance is not a one-size-fits-all task. Carry out a full risk assessment of your systems to establish how cardholder data is stored and transmitted. And use that assessment to put in place tailored policies that protect sensitive data.
3. Write clear and concise templates
The language used in PCI templates should be clear and easy to understand. It should not include technical jargon that only IT staff understand. The policy aims to inform and assist readers. Writers must avoid confusion at all costs.
Link security controls to PCI requirements. Show how controls protect cardholder data, and include clear information about auditing and assessments. Outline the steps that employees must take when using security systems. And be very clear about employee responsibilities.
Double-check every section for clarity. Seek feedback from other business departments to ensure the language is clear and comprehensible.
4. Provide regular training
A PCI compliance policy is not a static document to be stored and forgotten. Organizations should train network users to understand the policy. And employees should be invited to consult policy documents if required.
Schedule training events to introduce the PCI compliance policy. This should include an introduction to staff responsibilities and an explanation of data security controls. Follow this up with regular sessions to refresh user knowledge.
Remember that PCI is a moving target. Training should accompany changes to compliance policies. That way employees will always be aware of their obligations.
5. Establish processes to review and update policies
A PCI compliance policy should change over time. PCI-DSS regulations change regularly. Security technology advances all the time and new threats to cardholder data constantly emerge.
Create a mechanism to regularly review and update your PCI policies and procedures. IT teams should assign an officer to stay informed about PCI developments. This officer should check for regulatory updates and make any relevant recommendations to change existing policies.
6. Consult outside expertise if needed
Complying with PCI-DSS regulations can be challenging. Even well-resourced corporations sometimes require external input to fine-tune their PCI compliance policy.
If you are unsure about PCI requirements, help is available. Don't be afraid to bring in security assessors to check your systems. The eyes of an outsider can often detect problems that insiders miss.
Create PCI templates to meet compliance goals
PCI compliance is an essential task for digital businesses. Companies should meet their compliance goals by creating a clear and comprehensive PCI compliance policy. This article has explained the core areas to cover. Follow our PCI template and customize the format to reflect your business requirements. The result will be stronger protection for cardholder data.