How To Minimize The Scope of Your PCI DSS AuditPublished July 8, 2019 by Alan Gouveia • 4 min read
Compliance with the Payment Card Industry Data Security Standard (PCI DSS) and its 281 directives can be a time-consuming hassle.
Fortunately, there are ways to minimize your PCI DSS scope, saving time and resources for your organization and auditor, and ratcheting down your stress levels.
Larger organizations—those processing more than 1 million credit-card transactions annually—may need two years to reach initial PCI DSS compliance. Then, to stay compliant, they often must expend ample resources monitoring their systems and security and keeping it all up to date. For those who fail, the penalties can be crippling.
Even smaller merchants and internet service providers (ISP) may require a year’s work to reach PCI compliance. That’s because this data security framework, mandatory for all who accept credit-card payments, contains 281 directives in 12 categories. Just keeping track of all the PCI DSS requirements can boggle the mind—and your organization’s budget.
But with a few simple steps, you can ease the way to meeting the security standards applicable to your organization, and become fully PCI compliant.
PCI Compliance: One Size Does Not Fit All
The PCI Security Standards Council (PCI SSC) established PCI DSS in 2004. The council comprises members from financial institutions, merchants, processor companies, software developers, and point-of-sale vendors. The impetus: an explosion in credit card fraud due to the introduction of the internet and the growing popularity of e-commerce.
Compliance with the framework, an industry mandate for all payment card processors, is designed to protect credit card and cardholder data from unauthorized access at every point in the cardholder environment. But as cybercriminals develop more ways to breach systems and networks, the list of requirements has also grown. How can your organization, especially if it is smaller, comply with them all?
The good news is, you may not need to. PCI DSS is a flexible framework with different requirements for different types and sizes of business.
Which PCI DSS Compliance Level are you?
Level 1, the most stringent of the four PCI DSS compliance tiers, includes merchants that process 1 to 6 million or more credit card transactions yearly—the number depends on the card or cards you accept—and payment service providers processing 300,000 or more transactions. Level 1 compliance requires, among other things, passing an onsite audit conducted yearly by a Qualified Security Assessor (QSA) or Internal Security Assessor.
Levels 2, 3 and 4 have fewer requirements for PCI DSS compliance. Merchants and service providers in these levels do not need an audit, but can instead submit and complete a Self-Assessment Questionnaire supplied by the Security Standards Council.
Still, either scenario involves checking off hundreds of directives covering every aspect of payment card security from point-of-sale devices to remote-access connections, and beyond. To make the process easier and more cost-efficient for the auditor and your organization, you will want to find ways to reduce the assessment’s scope.
The Worry-Free Path to Scope Reduction
Before you can minimize the scope of your PCI DSS compliance audit or assessment, you’ll need to determine exactly what that scope is. To do so, sit down with the framework and consider which of the 281 directives apply to your enterprise, perhaps with your audit office’s help. You may find yourself with a shorter list after this step.
Next, examine your CDE. Are there ways you can limit the scope for a more efficient audit? Possibilities to consider include:
- Put up firewalls. PCI DSS Requirement 1.2.1 advises, “Restrict inbound and outbound traffic to that which is necessary for the cardholder data environment, and specifically deny all other traffic.” Firewalls are one way to block access, keeping external users from entering your networks and internal users from accessing information they do not need.
- Use point-to-point encryption. Encrypting all payment-card and cardholder data from the point of sale all the way through payment processing will reduce your PCI audit scope and cost.
- Use approved devices. Make sure your point-of-sale devices, software, and point-to-point encryption devices are on the list of those approved by the PCI Council.
- Analyze third-party vendors. Do you outsource payment processing or other tasks associated with payment data collection, storage, or transmittal? Make sure your service providers are also PCI DSS compliant.
- Examine your payment applications. These must meet PCI compliance, too—and making sure they’re patched and up to date is your responsibility.
- Segment your networks. Network segmentation is one of the best actions you can take for scope reduction. If you place firewalls around your Cardholder Data Environment (CDE), separating it from the rest of your network, your PCI DSS auditor will scrutinize only the CDE.
- Dispose of cardholder data promptly and effectively. Keep it for only as long as you need it, and destroy it using a method approved by the PCI Security Council.
Another idea: Ditch your Spreadsheets
Complying with PCI DSS is no simple feat, no matter what you do. But taking these steps ahead of your audit or self-assessment means you’ll be more likely to pass the test with relative ease.
Unless, of course, you’re using spreadsheets to track and monitor your PCI compliance efforts. Outdated and confusing, spreadsheets tend to add to a compliance officer’s problems rather than resolve them.
A quality governance, risk, and compliance solution does everything spreadsheets can do, and much more. ZenGRC’s features include at-a-glance compliance dashboards, vendor management capabilities, and continuous monitoring to ensure that your organization will stay in compliance with PCI DSS all the time. Why not contact one of our GRC experts today, and minimize the scope of your PCI audit and your worries?