Compliance with PCI regulations is not a one-time job that you can complete, and then check off your list. According to Verizon, who publish their regular Payment Security Report, “80% of companies that passed their annual assessment failed a subsequent interim assessment, which indicates that they’ve failed to sustain the security controls they put in place.”
Any business that works with payment data recognizes the challenges involved with maintaining a PCI compliant data center. IT environments are becoming increasingly complex, with diverse and dynamic technologies that are constantly changing to best support customer needs and to provide competitive differentiation. Even small companies with relatively simple company structures still may have on-premise data centers, virtual backups, SaaS applications or IaaS in both the public and private Cloud, and payment information on physical machines or devices internally. Many of these go through regular application or organizational changes that disrupt your ability to be compliant, as they shift data and workloads to meet demand.
Additionally, PCI regulations are not static, they change as the industry learns more about security and as wider threats evolve. This obviously has an influence on the security tools your business needs. With all this to consider, how can you bring your organization on board for sustainable compliance?
Streamline a Rolling PCI Compliance Process and Creating a PCI Compliant Data Center With these 4 Phases
- Reduce the scope and include fewer elements in your annual assessment
- Outsource your PCI strategy, or some specific components of it
- Select a comprehensive platform approach
- Make PCI compliance an integral part of your company culture, remaining vigilant to keep abreast of changes in regulations to continue prioritization of sustained PCI compliance
Reduce the Scope
According to the PCI Security Standards Council (SSC), the cardholder data environment (CDE) and all connected systems are all considered to be ‘in-scope.’ In fact, a system component can only be ‘out of scope’ if it is unable to communicate with any other component within the compliance environment, and therefore cannot compromise the CDE security. It’s worth remembering that even isolated networks need to be documented in your compliance report. This definition makes reducing scope, and thereby reducing the elements you need to include in your annual assessment difficult.
- Tokenization: One way to go about the task of reducing scope is to reduce the data itself. Think about truncating or masking PAN (primary account number) data, which is rarely required in full, or consolidating the systems that store cardholder data, whether that’s hardware or software. Some companies replace PAN data with fixed-length message digest or use Tokenization which allows this data to then be removed from scope. Point to Point Encryption is becoming more popular in order to remove the whole of Merchant Services from scope altogether.
- Segmentation & Micro-segmentation: Another tactic is reducing scope using architecture. Traditionally, firewalls were used to create partitions and enforce network zones, while segmentation gateways were shown to improve access control both internally and externally. Virtual LANs with strong ACLs were shown to have the same effect. Everything changed with the advent of Cloud-based and hybrid solutions, and today – there is no such thing as a simple IT environment. While segregation can help reduce scope using a combination of methods such as IP address restriction, communication protocol restriction, port restriction and application level restriction, microsegmentation is garnering the most attention.
Micro-segmentation supports your staff to work at a process or identity level, setting the rules you need to keep your network secure. As you control the flow of data from process to process, the idea of a breach is no longer catastrophic, as even in the worst-case scenario it is automatically isolated and easily resolved.The benefits are clear. As well as gaining deep visibility and wide coverage of your architecture, microsegmentation limits its complexity, making continued compliance that much easier.
Outsourcing for Compliance
Most enterprises have identified that while their environments continue to grow in complexity, their staffing size and skill sets remain somewhat static. There is a growing demand for qualified IT staff, and the growth in the workforce hasn’t kept up with the pace. Executives continue to complain about a shortage of skilled employees. In fact, a January 2018 research study by ESG showed 51 percent of respondents claimed their organization had a problematic shortage of cybersecurity skills.
Many enterprises have found that outsourcing specific components of their PCI strategy to Managed Security Services Providers is the right solution. In the right situations, outsourcing might help you reduce scope, or add tools that help maintain a compliant data center.
- Security Outsourcing to MSSPs: PCI regulations include ensuring you have an up-to-date Antivirus solution, Think about SIEM/logging capabilities, File Integrity Monitoring, vulnerability and patch management solutions. These are great examples of things that can be outsourced to competent MSSPs, effectively outsourcing compliance, in an affordable and smart way of taking advantage of third-party expertise. Of course, Antivirus solutions are not all created equal. Some options will provide an added layer of vulnerability management, helping you achieve compliance without you lifting a finger on your side. Look for MSSPs who have solutions that check as many of the boxes as possible for you when it comes to technical requirements.
- Other options for outsourcing include Storage, Processing and Handling, all of which can partially or completely remove cardholder data from your CDE, supporting your company in reducing scope.
Selecting Comprehensive Platform Solution over Multiple Point Products
Comprehensive Platform Approach: Since multiple tool sets often lend themselves to confusion and complexity, we’ve seen a shift from enterprises selecting multiple point solutions to unifying, comprehensive platforms. A solution may provide adequate threat detection for example, but do they have a distributed firewall, or response to breaches from the same platform? Dynamic environments need a lot of attention, so using one platform/solution instead of multiple to manage a whole area of compliance is invaluable when it comes to policy management and proof process.
Continued Compliance Enhances Enterprise Security as a Whole
It’s important to facilitate an environment where compliance isn’t viewed as a hassle or even a hindrance but instead a part of having a healthy, vibrant, safe and secure enterprise. While it’s true that PCI compliance is not a be-all and end-all, these continued compliance checks when done correctly lend themselves to the improvement of the organization as a whole. Here are some examples where continued PCI compliance lends itself to overall enterprise comprehensive health:
- Flow Visualization: If you can access a visual map of all application workloads in granular detail, you can use working towards PCI compliance to uncover underlying security issues. Proper visualization could catch ineffective oversight mechanisms, organizational silos, wasted resources, or poor architecture design. Lack of data compromises security integrity. In addition to sustaining compliance, maintaining process-level visibility keeps an accurate tab on the state of your overall security.
- Set Policies and Rules for Cardholder Data: Intelligent rule design can protect you in case of a breach, but also helps you refine and strengthen your compliance policies. Setting and enforcing strict compliance rules using a flexible policy engine is essential. These can be higher-level best practices for security when considering larger segments, and then more specific rules for micro-segments. Of course, these need to work across your entire Network, including in hybrid environments.
- Reduce Complexity and Maintain Control: Simplify your IT architecture with business process corrections and investment in new hardware or software, reducing costs for the business. Using a single platform for visualization, microsegmentation, and breach detection means you don’t have to fear becoming more vulnerable to attacks or less compliant to regulations.
- Detailed Forensics: The immediate benefits of compliance may not always be clear. Continuous monitoring and sharing of detailed actionable analytics of breach detection or resolution can improve security posture and increase awareness and appreciation of these efforts among your staff. This creates an environment where data protection and compliance are shown to have true value.
Sustainable Compliance Needs Dedication
Ensuring that your security supports continued compliance doesn’t happen without work. All areas of the business need to be on board, from business strategists to customer call representatives. Simplifying your business process through reducing scope, outsourcing, selecting comprehensive platforms over multiple point solutions and understanding how continuous PCI compliance positively affects the health of your enterprise security overall will help make it an integral part of your company culture.