The current version of the Payment Card Industry Data Security Standard (PCI DSS) has been in place since April 2016. However, there are a number of requirements within this version 3.2 that up until this year have not been mandatory.
Instead the PCI Security Standards Council (SSC) had marked these particular points as “best practice” to allow organisations time and space to implement them.
There is a danger however that these “best practice” requirements may have been over looked by some company’s so that when they come to do their 2018 attestation of compliance, they may suddenly be faced with significant areas of non-compliance. As you will see below, this especially applies to service providers (but Merchants shouldn’t rest on their laurels either).
Let’s discuss these “best practice” points in turn and highlight what needs to be in place from end January 2018, to maintain compliance.
Requirement 3.5.1: Maintain a documented description of the cryptographic architecture.
This is an additional requirement for service providers (SPs) only. It mandates that SPs must document in detail key aspects of their cryptographic implementation, including algorithms, protocols, and keys in use. Interestingly, other than some fleeting references in guidance columns, this is the only place in the whole of the standard that uses the term “architecture” directly as a requirement.
Requirement 6.4.6: Upon completion of a significant change, all relevant PCI DSS requirements must be implemented on all new or changed systems, and documentation updated.
This a now a mandatory requirement for both SPs and Merchants. It requires that organisations must have an additional process in place to carry out a “PCI DSS-relevant review” of changes and ensure that the cardholder data environment (CDE) is kept up to date. For example, maybe an asset inventory needs to be updated; or a network diagram amended; or a new system needs to be included in the vulnerability scanning schedule.
Requirement 8.3.1: Incorporate multi-factor authentication (MFA) for all non-console systems admin access into the CDE.
For both SPs and merchants, this potentially represents a significant change in working methods for system administrators. All admin access which is not in front of an actual console must use an MFA option when accessing the CDE, either at the network or system / application level (not both). This is to reduce the risk of powerful admin level access being compromised due to just a password being sniffed either on an internal or external network.
Requirement 10.8 and 10.8.1: Implement a process for the timely detection, response and reporting of failures of critical security control systems.
This is another set of requirements just for SPs. It means that an additional safe-guard measure must be in place to alert if a control such as an IDS/IPS, firewall, anti-virus, or access control mechanism stops working correctly. So, for example, its not just a requirement to have an IDS/IPS in place, but SPs must also check that the solution is doing its job properly and actually detecting intrusion attempts. The new alerting and response process must be documented.
Requirement 22.214.171.124: Penetration testing to be carried out on at least a 6-monthly basis, if segmentation is used.
Yet another uplift for SPs. Where segmentation controls are used to limit the scope of compliance, the organisation must validate that these controls are working effectively at least every six months and after any changes to segmentation methods.
Requirement 12.4.1: Executive management must establish responsibility for the PCI DSS compliance program.
Again, one for SPs. The organisation must define a charter which describes how the compliance program is organised, and that top management have assigned overall accountability and applicable roles.
Requirement 12.11 and 12.11.1: Perform reviews at least quarterly to confirm personnel are following security policies and procedures.
This is now a mandatory requirement for both SPs and merchants A process for confirming that other critical procedures such as change management, firewall policy reviews, log reviews and so on, are actually taking place effectively. Documentation, for example a completed checklist, clearly showing the results and sign-off, needs to be included.
Requirement A2.2: Migration projects to move from SSL / early TLS to be completed.
For all entities, the risk mitigation and migration plan for moving to secure TLS protocols must be completed no later than end June 2018.
So, this year is a significant one in terms of ratcheting up compliance levels; and with the likely announcement of an updated version 3.3 of the standard, all entities should play close attention to ongoing PCI DSS requirements.
PGI can provide assistance to your company’s PCI DSS compliance needs. This can either be as a QSA to assess your levels of compliance, or as expert security practitioners to put in place new documentation or processes tailored to your organisation.
PGI believes that cyber security doesn’t need to be overly complicated, incomprehensible or vastly expensive. We specialise in delivering cyber security services and protection, and offer a range of training courses to upskill your staff to tackle cyber threats in-house.
Want to know more about our PCI Compliance Advice, PCI Gap Analysis, Testing and Monitoring or Audit and Compliance Reporting? Please get in contact via our online form, directly through our email at email@example.com or call us on 0207 887 2699.
Your free global geopolitical
PGI’s Risk Portal tool provides daily intelligence feeds, country threat assessments and analytical insights, enabling clients to track, understand and navigate geopolitical threats.
The Risk Portal gives users up-to-date information and analysis on global affairs.
The Risk Portal allows users to visualise information in a unique and instantly understandable way. Mapping filters enable the visualisation of incidents by threat category, time period, perpetrator and target type.
Risk Portal users can upgrade their accounts to include the Report Builder and Country Profile Generator features. The Report Builder allows users to select information, data and images from the Risk Portal and create bespoke reports and emails.
Subscribers to PGI’s Bespoke services receive tailored analysis on specific sectors and geographies of interest, delivered at a frequency they determine.
Making ongoing compliance easier for you and your business
GDPR is now in force. Make sure your business meets the necessary requirements, providing assurance for all of your customers and employees.
A full audit of your business to assess the level of your compliance against GDPR requirements.
Become GDPR compliant with minimal work. We will conduct an analysis, review, report and implement any necessary changes to your business.
We will conduct simple security assessments to help you understand and mitigate the potential risks to your business.
Get your business ready to face the cyber challenge.
We provide a full range of accredited, certified and bespoke services that assess the resilience of your cyber security posture.
PGI’s Qualified Security Assessors (QSA) will help you meet Payment Card Industry Data Security Standards (PCI DSS).
Find out more on PCI DSS
Demonstrate your commitment to cyber security by achieving and maintaining accreditation for the globally-recognised information security standard.
Find out more on ISO 27001
Understand the threats of phishing and malware to avoid being targeted.
Undertake our phishing vulnerability assessment to reduce your organisation’s risk of attack, by measuring the cyber awareness of your workforce.
PGI will conduct a tailored phishing campaign, using multiple methods, to identify realism and train employees where necessary to mitigate future attacks.
PGI monitor multiple metrics to identify the types of phishing, generate in-depth analytical reports and provide an informed decision to help improve your organisation’s level of security and awareness.
Prevent attacks, respond to breaches and protect your business.
Our bespoke range of cyber security services not only protect your critical assets but provide the education you need to keep your operations and data safe.
Implement this cost-effective cyber security measure launched by the government to prevent cyber-attacks, demonstrate information security commitment to your clients, and attract new business by being recognised as a secure organisation.
Find out more on Cyber Essentials Accreditation
The most effective way to identify how attackers target your organisation’s weaknesses is by evaluating your system, your network security, and reporting on any vulnerabilities that could have an impact on your business.
Find out more on Penetration Testing
If your business has experienced breaches, network compromises or operational disruption, our team of cyber security specialists can deploy quickly, and will begin the process of detecting and eliminating the threat efficiently.
Find out more on Data Breach Response & Recovery
Data Breach Response & Recovery
We prevent attacks, respond to security breaches, and protect your business
Our team of specialists can deploy quickly and efficiently to begin the process of detecting, eliminating and preventing future threats of a breach.
A vital part of the response process is making a copy of your data for safe forensic analysis. We will work with you to preserve and use this evidence to discover the extent of an intrusion.
Find out more on Digital Forensics
We will identify and minimise the risks, as well as the possibility of future risks to your business.
Consistent interaction with your management team and recommendations on how to approach all outcomes that need attention.
Subscribe to our Cyber Bytes Newsletter
Keep yourself in the loop with PGI by signing up to our Monthly Cyber Bytes email. You will receive updates, tips and narrative around what has been happening in the world of information security.