The PCI Security Standards Council recently unveiled the long-awaited version 3.0 of the Payment Card Industry Data Security Standard (PCI DSS). Retailers, service providers and other organizations involved in credit card processing have until January 2015 to comply with the new standard. There’s a lot to do.
How should an organization get started? The best approach is to prioritize the changes based on the date they become effective for your credit card processing activities.
The good news is that, although PCI DSS 3.0 went into effect on January 1, 2014, merchants have a one-year grace period to adapt to the new standard. In the interim, they may choose to recertify under either the PCI DSS 2.0 or 3.0 standard. In addition, implementation deadlines for a handful of requirements are further delayed until July 1, 2015.
Step 1: Thoroughly Review the Standard
As the first step in preparing to comply with PCI DSS 3.0, thoroughly read the new standard. The PCI DSS 3.0 Summary of Changes prepared by the PCI Security Standards Council can help guide your review. While the summary of changes runs 12 pages, you’ll be relieved to find that the vast majority of those changes are classified as “Clarification” or “Additional Guidance” updates that simply correct ambiguous wording. Review each of these changes, but chances are they will not significantly impact your PCI DSS compliance program.
The significant items to watch out for are those labeled “Evolving Requirement.” In these cases, the PCI SSC has made significant changes to the standard. Think of it as a euphemism for “new work.” Work your way through each of the changes identified in the document and determine what actions, if any, will be required to bring your cardholder data environment into compliance with the new standard.
Step 2: Implement the First Wave of Changes
Once you’ve reviewed the standard and outlined your work plan, start implementing any required changes. The good news is that you have until the end of 2014 to implement these changes, so an early start will give you plenty of time to evolve gradually. Some of what you must cover in this first wave include:
- Developing a diagram of all cardholder data flows and updating your network diagram to meet the requirements of sections 1.1.2 and 1.1.3.
- Creating an inventory of in-scope system components, as required by the new section 2.4.
- Ensuring that antivirus software can’t be disabled by end users, as required by the new section 5.3.
- Conducting risk assessments for platforms not commonly affected by malware, in compliance with section 5.1.2.
- Ensuring that your password requirements meet the revised complexity standards of section 8.2.3.
- Updating the use of non-password authentication mechanisms to ensure they are linked to individual accounts, in compliance with section 8.6.
- Evaluating whether physical security access procedures comply with section 9.3.
- Ensuring that audit trails capture changes to identification and authentication mechanisms, modifications to administrative accounts, and starting or stopping the audit log, in compliance with the updates to section 10.2.
- Maintain an inventory of wireless access points and ensure that incident response procedures are triggered when unauthorized APs are detected, per section 11.1.
Tailor your organization’s 2014 action plan to meet the specific operational needs of your credit card processing environment.
Step 3: Prepare for 2015
Once you’ve tackled the first wave of changes, turn your attention to the four requirements that have the deferred implementation deadline of July 1, 2015. These four requirements include:
- Section 6.5.11 requires updating software development practices to protect against broken authentication and session management.
- Section 8.5.1 mandates that service providers working with multiple merchants have unique access credentials for each customer.
- Section 9.9 institutes new control requirements around physical access to point of sale terminals.
- Section 11.3 hardens requirements for penetration tests, mandating the use of a comprehensive methodology that meets detailed PCI DSS requirements.
While any major update to a compliance standard can be a disruptive event for an organization, there’s no need to panic with the release of PCI DSS 3.0. The majority of the changes in this version simply clarify existing requirements.
For those requirements likely to require change, the standard provides plenty of time, with the first deadline at the end of this year and the second even farther out in July 2015. If you start now, you should have enough time to ensure continued compliance.