Can I Do PCI Compliance Myself and Maintain Security

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Trying to handle PCI compliance on your own can be a daunting task, but it's definitely possible with the right guidance. The Payment Card Industry Data Security Standard (PCI-DSS) is a set of rules that must be followed to ensure the security of credit card information.

You'll need to invest time and resources into understanding the 12 requirements of PCI-DSS, which include installing and maintaining firewalls, encrypting sensitive data, and regularly updating software. This requires a good understanding of network security, data encryption, and access controls.

While it's possible to do PCI compliance yourself, it's essential to consider the potential risks and consequences of non-compliance, such as fines and damage to your business reputation.

Understanding PCI Compliance

Becoming PCI compliant can be a complicated process, but understanding what's required of you can help create a game plan and make the process smoother.

The PCI Security Standards Council plays a significant role in shaping the landscape of global payment security standards.

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The Council lays the groundwork for the standards, but compliance lies in different organizations' hands. They provide the necessary resources, such as an SAQ Instruction Guide, and set guidelines for managing third-party service provider relationships.

These standards are designed for all entities that handle payment account data, as well as developers and manufacturers of related products. They ensure the standards stay up-to-date with emerging and established payment technologies and threats.

The PCI SSC assists organizations in completing annual self-assessments.

Identify Level

To determine if you can do PCI compliance yourself, you first need to identify your organization's level of compliance. This will help you understand what's required of you.

The level of compliance you need is determined by the size of your organization, the number of annual credit card transactions, and requirements from your customers or acquiring bank.

Most small businesses fall into the Level 4 category, which requires completing a self-assessment questionnaire (SAQ), having an Approved Scanning Vendor (ASV) conduct quarterly network scans, and completing an Attestation of Compliance (AoC).

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However, if you process more than 6 million transactions, you'll need to complete a PCI-RoC, which is a more in-depth report.

Here are the different levels of compliance and what's required of each:

Your point of sale (POS) reports can show your detailed transaction data, which can help you determine your level of compliance.

Completing a Self-Assessment

To complete a self-assessment, you'll need to identify the correct PCI DSS self-assessment questionnaire (SAQ) for your organization. There are eight types of SAQs, each tailored to address specific compliance requirements based on your payment processing methods and cardholder data handling.

You can determine which SAQ applies to your business by considering factors such as the method you use for transactions, whether you store any cardholder data, and the type of business you are. For example, if you only use imprint machines to process card transactions, you'd fall under SAQ B.

Here are the different types of SAQs:

  • SAQ A
  • SAQ A-EP
  • SAQ B
  • SAQ B-IP
  • SAQ C
  • SAQ C-VT
  • SAQ P2PE
  • SAQ D for Merchants and Service Providers

A self-assessment questionnaire (SAQ) involves a series of yes/no questions and includes two main sections: a basic survey about the company and a second section with questions about each PCI requirement and sub-requirement.

Complete a RoC or SAQ

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If you're a Level 1 Merchant or Service Provider, you're required to complete an annual Report on Compliance (RoC) by a Qualified Security Assessor (QSA). This external audit reviews your policies, processes, controls, and evidence to ensure you meet PCI DSS requirements.

If you're not a Level 1 Merchant or Service Provider, you'll need to fill out a Self-Assessment Questionnaire (SAQ). This questionnaire covers each requirement, expected testing, and asks if the control is in place, in place with a compensating control, not in place, N/A, or not tested.

There are different types of SAQs, ranging from SAQ A to SAQ D, each designed to address specific aspects of PCI DSS. For example, SAQ A is for merchants who only use imprint machines to process card transactions, while SAQ D is for merchants and service providers who need to meet all PCI DSS requirements.

To determine which SAQ is right for you, consider factors like the size of your organization, number of annual credit card transactions, and requirements from your customers or acquiring bank. You can use the following criteria to determine your level of compliance:

If you don't receive a specific request, you can use these questions to determine your level of compliance. If you're unsure, it's always best to consult with a qualified expert or your merchant bank for guidance.

Implement a Management System

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Implementing a management system can be a game-changer for your self-assessment process. It forces you to go through every line item and confirm that you’re in compliance.

A compliance management system has a built-in structure that protects your organization by ensuring you've done your due diligence. This is especially important for PCI requirements, where it's easy to breeze through without much rigor.

Having a compliance management system gives your clients and partners more confidence in the validity of your AOC. It also ensures that you own your own compliance data, which is crucial in case you switch Consultants or Assessors.

You need to own the license for your own compliance management system to avoid losing your compliance history. This is a valuable repository of your approach by requirement, which can quickly enable new partners to get up to speed on your engagement.

Maintaining Compliance

Maintaining compliance is an ongoing process that requires regular effort. To maintain PCI certification, you'll need to complete an RoC or SAQ and AoC annually.

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You'll also need to plan for other periodic tasks throughout the year, such as reviewing logs and alerts daily, running file integrity monitoring scans weekly, and installing security patches monthly. Quarterly tasks include reviewing user access, scanning for unauthorized wireless networks, and verifying data deletion.

Here's a breakdown of the tasks you'll need to perform regularly:

  • Daily: Review logs and alerts
  • Weekly: Run file integrity monitoring scans
  • Monthly: Install security patches
  • Quarterly: Review user access, scan for unauthorized wireless networks, and verify data deletion
  • Biannual: Review firewall and router configurations
  • Annual: Review and re-approve policies, conduct a risk assessment and pen test, and complete secure code training and security awareness training

By following these tasks, you'll be able to maintain compliance and keep your customers' card data safe.

Maintain Certification

Maintaining certification is a crucial part of staying compliant. To keep your certification valid for another year, you'll need to complete a new RoC or SAQ and AoC annually.

Daily review of logs and alerts is essential to catch any anomalies or suspicious activity. This task should be done every day to stay on top of potential security threats.

Weekly file integrity monitoring scans with critical file comparisons must be run at least weekly to ensure the integrity of your system. This task helps identify any unauthorized changes to your files.

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Monthly security patches are a must to keep your system components and software protected from known vulnerabilities. Install these patches as soon as they become available to stay secure.

Quarterly tasks include reviewing user access, scanning for unauthorized wireless networks, verifying data deletion, and conducting vulnerability scans with an ASV. These tasks help identify potential security risks and vulnerabilities.

Biannual review of firewall and router configurations is necessary to ensure they're set up correctly and securely. This task should be done every six months to stay on top of any changes or updates.

Annual tasks include reviewing and re-approving policies, requiring employees to acknowledge the Information Security Policy, conducting a risk assessment and pen test, and completing secure code training for developers and security awareness training for employees. These tasks help ensure your organization is secure and compliant.

Foster Trust Through Thoropass

PCI DSS Self Assessment is a critical process for any business that accepts card payments. By understanding the PCI DSS requirements, businesses can demonstrate their commitment to protecting cardholder data.

Credit: youtube.com, Thoropass Co-Founders talk about how their compliance solution helps customers reach their goals

PCI Data Security Standards (PCI DSS) is required for any businesses that process, store, or transmit credit cards and is enforced by the Card Brands and Acquiring Banks.

Thoropass streamlines and accelerates your certification by combining automation with self-assessment support and expert insights. This makes it easier to get certified PCI compliant faster with less work and headaches.

Becoming Compliant for Small Businesses

Becoming PCI compliant as a small business can be a daunting task, but it's not impossible. To start, you'll need to complete 12 steps, which can be broken down into six goals. The first goal is to ensure access to your systems is protected, which means having a regularly tested firewall policy in place.

You should also change vendor-supplied passwords for any hardware or software to unique and secure passwords. And don't forget to update your passwords every 90 days. This will help prevent unauthorized access to your systems.

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If your business actively stores cardholder data, it's not recommended that you store any card data. This includes never keeping data such as PIN numbers or card validation codes. Instead, combine virtual and physical safety measures, like authentication procedures and locked cabinets, to limit access to the server.

Encryption is also key when transmitting data, so make sure to encrypt the transmission of all data to ensure that only those with the correct cipher can read it.

A robust anti-virus system is also crucial for secure card payments. This means scanning your software for malicious viruses, updating your anti-virus software to stop newer viruses, and checking your card provider's updates to stop any security exploits.

Only those who have a definite need to access cardholder data should be able to access it. This means providing staff with unique IDs for computer access and following best practices like authorization and frequent password resets.

You should also limit access to cardholder data held offsite, as this doesn't mean your provider can provide a lower level of security. The third-party provider still needs to ensure sufficient security every step of the way.

To track who accesses the data and when, you should implement accurate logging systems. This will help your provider find the root cause and fix it as soon as possible in case of a security breach.

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Finally, your information security policy should be a comprehensive overview of every aspect of your data security procedures in your business. This includes what your data security procedures are, who executes them, and how compliance will be achieved.

Here's a quick summary of the steps to become PCI compliant:

  • Complete a self-assessment questionnaire (SAQ)
  • Have an Approved Scanning Vendor (ASV) conduct quarterly network scans
  • Complete an Attestation of Compliance (AoC)

As a small business, you're considered a Level 4 merchant, which means you don't need an annual Report on Compliance (ROC) by a Qualified Service Assessor (QSA). But don't get too comfortable – you still need to stay on top of your security measures to ensure compliance.

Choosing a Provider

To ensure PCI compliance, selecting the right third-party provider is crucial. Selecting the right third-party provider to support PCI compliance efforts requires comprehensive due diligence.

You'll need to ensure their PCI DSS compliance is current, check their Attestation of Compliance, and review them on the payment card brands' registry list of compliant service providers.

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Their qualifications and history, including their experience with data breaches, should be thoroughly reviewed. Their incident response plan, employee background checks, and overall reputation and reliability, as indicated by client testimonials, are also essential considerations.

Clarifying which PCI DSS requirements are managed by the provider is vital. This will aid in delineating the division of responsibilities and ensuring the proper selection of the right third-party provider.

Here are some key things to check when selecting a provider:

  • Ensure third-party service providers’ PCI DSS compliance is current
  • Check their Attestation of Compliance
  • Review providers on the payment card brands’ registry list of compliant service providers
  • Their qualifications and history, including their experience with data breaches
  • Their incident response plan
  • Employee background checks
  • Their overall reputation and reliability, as indicated by client testimonials

Adrian Fritsch-Johns

Senior Assigning Editor

Adrian Fritsch-Johns is a seasoned Assigning Editor with a keen eye for compelling content. With a strong background in editorial management, Adrian has a proven track record of identifying and developing high-quality article ideas. In his current role, Adrian has successfully assigned and edited articles on a wide range of topics, including personal finance and customer service.

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