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Payment Card Industry Data Security Standard 3.0 (PCI DSS) changes became effective on Jan. 1, and many businesses will be working to ensure they are meeting new and updated requirements throughout 2014.
Last month, Layered Tech become one of the first managed hosting service providers to become certified under PCI DSS 3.0 standards. Since we handle the majority of IT controls for many of our clients, it was an easy decision for us to seek certification as early as possible to help them address potential gaps in security and reporting requirements between now and the end of the year. In 2015, all hosting providers must be in full compliance with the new PCI 3.0 standards.
The PCI DSS Lifecycle
PCI DSS (and its counterpart PA DSS) rules live on a three-year lifecycle, and PCI 3.0 began its life when announced in October 2013. Since the new standards became available in January, most cloud solutions providers (CSPs) will spend 2014 implementing the changes pushed by PCI 3.0.
Old PCI 2.0 rules are grandfathered in for 14 months (through Dec. 2014), but merchants and vendors alike will be working diligently to complete their transitions as soon as possible. Here are some of the most noteworthy changes under the new requirements that you should be aware of:
Requirements in PCI DSS 3.0 Go Beyond Compliance
The major changes in PCI 3.0 focus on raising user awareness of potential security and compliance concerns, beefing up security standards, and making user-controls more flexible. At its core, PCI focuses on securing cardholder data, so the new standards put a lot of emphasis on securing internal infrastructure, managing third-party access and authenticating systems with access to data.
- Establish a culture of security through education. One of the largest themes of PCI DSS 3.0 is to maintain and drive accountability at every level of client organization by educating employees on security.
- More rigorous requirements for penetration testing. Earlier standards required some testing, but 3.0 requires more strenuous testing on both application-layer and network-layer levels, and QSAs will have to put more emphasis on penetration testing. Tests must cover the entire cardholder data environment and use an accepted testing model, like NIST. Unlike most of the PCI DSS 3.0 changes, however, organizations have until July 15, 2015 to fully comply with rules regarding penetration testing. Despite the longer deadline, we expect that penetration testing methodologies will come under increased scrutiny in years to come, so having a rigid testing method in place will be crucial.
- Organizations must have written security agreements with service providers to define security obligations. PCI 3.0 requires that any business, third-party vendor or organization that accepts card payments is fully aware of their responsibilities in data security. The new standards provide an extra level of guidance to both CSPs and merchants to ensure that responsibility is shared, not outsourced.
- Enhanced service provider scrutiny. CSPs must now use unique credentials for each of their clients (spurred by a data breach caused by a vendor using a single password across each environment), and must give customers documentation confirming their responsibility for data in their possession and maintaining compliance in the data environment.
- Merchants and vendors must maintain a complete inventory of the cardholder data environment (CDE). This includes documenting each component of the environment, along with its function and purpose.
It shouldn’t be a big surprise that so many of the changes encourage CSPs and third-party vendors to share responsibility for maintaining security. So as more businesses seek help with their IT operations, third-party providers will have a more prominent role in guaranteeing compliance. At Layered Tech, we manage all the IT controls through internal staff, without third-party support, helping clients limit scope, risk and costs.
The Value of Early Adoption
Since all organizations – vendors, assessors and CSPs alike — must adhere to the new standard by the end of 2014, Layered Tech felt it was important to achieve early certification. As our clients begin to recertify for their own business, we can now safely manage their controls and leave no gaps between their compliance efforts and our own. Layered Tech has always been on the leading edge of PCI DSS certification, and we continue to support the needs of our clients by staying ahead of the curve.
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About the Author: Dennis Pickard holds CIA & CISA certifications and is the IT Audit Lead in the Compliance and Security Group of Layered Tech. He has more than 20 years of experience in compliance and technology audits, primarily in the Financial Services industry. Throughout his professional career, he has directed and performed numerous HIPAA security and privacy analysis activities.
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