
Cloud PCI compliance is a must for businesses handling sensitive customer data. The Payment Card Industry Data Security Standard (PCI-DSS) sets the bar for secure cloud storage and processing.
To achieve PCI compliance in the cloud, you must identify and assess all cloud service providers (CSPs) and their services. This includes reviewing their security controls, data storage, and access policies.
Cloud service providers must implement robust security measures to protect customer data. These measures include encryption, firewalls, and access controls.
Compliance with PCI-DSS also requires regular security audits and vulnerability assessments.
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Cloud Service Provider (CSP) Requirements
Cloud Key Management Service (Cloud KMS) is a service that lets you manage encryption keys, including AES-256, RSA 2048, RSA 3072, RSA 4096, EC P256, and EC P384 encryption keys.
Cloud KMS simplifies compliance with sections 2.2.2, 3.6, 3.7, and 8.2 by removing plain-text passwords stored in code or config files.
To meet PCI DSS encryption and key management standards, DuploCloud orchestrates AWS KMS and Azure Key Vault keys per tenant, encrypting various resources like databases and storage services.
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Your CSP Needs Attestation

Your CSP needs attestation of compliance (AOC) to ensure they are PCI DSS compliant. This is especially important if you're storing sensitive data, like credit card numbers, in their cloud server environment.
To get an AOC, you'll need to verify your CSP's compliance on an annual basis. This can be done by requesting a statement from your CSP that acknowledges their responsibility for PCI DSS compliance.
If your CSP is already PCI DSS compliant, they should be providing the AOC to customers anyway. However, it's still important to keep a record of it on file.
Here are some key points to keep in mind:
- Request a statement from your CSP that acknowledges their responsibility for PCI DSS compliance.
- Verify your CSP's compliance on an annual basis.
- Keep a record of the AOC on file.
By following these steps, you can ensure that your CSP is taking the necessary steps to protect your sensitive data and maintain PCI DSS compliance.
Key Management Service (KMS)
Key Management Service (KMS) is a crucial aspect of cloud security, and Cloud Key Management Service (Cloud KMS) is a service that lets you manage encryption keys, generating, using, rotating, and destroying keys like AES-256 and RSA 2048.
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Cloud KMS simplifies compliance with sections 2.2.2, 3.6, 3.7, and 8.2 by removing plain-text passwords stored in code or config files.
To ensure secure key management, keep your data encrypting keys (DEKs) separate from your key encrypting keys (KEKs), and make sure the encryption for your KEKs is at least as strong as, or stronger than that of your DEKs.
NIST SP 800-57 describes equivalence between different cipher types, such as RSA-3072 being equivalent to AES-128.
Set up key rotation policies to provide resiliency to manual rotation, prevent brute force attacks by limiting the number of messages encrypted with the same key, and limit the number of actual messages vulnerable in the event of a compromise.
Key rotation policies can be implemented to:
- Provide resiliency to manual rotation
- Help prevent against brute force attacks by limiting the number of messages encrypted with the same key
- Limit the number of actual messages vulnerable in the event of a compromise
DuploCloud offers a solution for encryption and key management under PCI-DSS by orchestrating AWS KMS and Azure Key Vault keys per tenant for encrypting various resources like databases and storage services.
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Key Roles and Responsibilities
Your cloud service provider (CSP) needs to clearly outline roles, responsibilities, and what will be done with your data. This is a requirement from PCI section 12.
You need to document what they provide and ensure you know what you're supposed to do. This is not only best practice, but also a requirement for PCI compliance.
One major difference between storing credit card information in the cloud is the level of access: you need to track access to sensitive data and verify that it's appropriate.
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Core Roles and Responsibilities
Your cloud service provider (CSP) needs to clearly outline roles, responsibilities, and what will be done with your data. This is not only best practice, but it's also a requirement from PCI section 12.
You need to know each party's roles and responsibilities, so make sure to document what your CSP provides and what you're supposed to do. This will help you understand where your provider's responsibility ends and where yours begins.

Understanding shared responsibility is crucial for achieving compliance in the cloud. The answer isn't always clear-cut, and definitions of the shared responsibility security model can vary between service providers.
To avoid confusion, know the different encryption modules your cloud provider provides, and if they are PCI compliant. This will help you ensure that your data is secure and compliant with regulations.
The PCI DSS has evolved to accommodate the unique security risks posed by cloud environments, including requirements for encryption, access control, vulnerability management, and continuous monitoring.
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Key Management
Key management is a critical aspect of data security. It involves ensuring that your data encrypting keys (DEKs) are separate from your key encrypting keys (KEKs).
The encryption for your KEKs should be at least as strong as, or stronger than that of your DEKs. For reference, NIST SP 800-57 describes equivalence between different cipher types, such as RSA-3072 being equivalent to AES-128.

Setting up key rotation policies provides resiliency to manual rotation, helps prevent against brute force attacks, and limits the number of actual messages vulnerable in the event of a compromise.
Here are the benefits of key rotation policies:
- Provides resiliency to manual rotation.
- Helps prevent against brute force attacks by limiting the number of messages encrypted with the same key.
- Limits the number of actual messages vulnerable in the event of a compromise.
Maintaining compliant data retention periods is another challenge in the cloud.
Regulatory Compliance
Regulatory compliance is crucial for any business handling sensitive data in the cloud. PCI-DSS requires companies to implement a range of security measures to protect customer data.
Companies must have a formal risk assessment process in place to identify potential security threats. This includes identifying vulnerabilities in the cloud environment.
Compliance with PCI-DSS also requires companies to implement strong access controls, including multi-factor authentication and role-based access control.
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HIPAA
HIPAA compliance is crucial for healthcare organizations, where access to Protected Health Information (PHI) is essential for organizational function. In fact, not having access to PHI could cripple a healthcare organization's ability to function.
For HIPAA compliance, access to PHI is a top priority, unlike PCI DSS compliance where limiting access to credit card data is preferable. This is because HIPAA requires sensitive health information to be handled carefully.
Healthcare organizations must carefully manage access to PHI to meet HIPAA requirements. This includes controlling who can view, modify, or delete sensitive health information.
Other Regulatory Requirements
In addition to the requirements mentioned in the article, there are other regulatory requirements that businesses must comply with. These include obtaining necessary permits and licenses, which can vary depending on the type of business and location.
The Federal Trade Commission (FTC) requires businesses to comply with its guidelines on truth-in-advertising, which includes disclosing material facts and avoiding deceptive practices.
A business must also comply with the Americans with Disabilities Act (ADA), which requires accessible websites and physical spaces for people with disabilities.
The Payment Card Industry Data Security Standard (PCI DSS) requires businesses that handle credit card information to implement specific security measures to protect sensitive data.
Some industries, such as healthcare and finance, are subject to additional regulations, such as HIPAA and the Gramm-Leach-Bliley Act, which require specific data handling and storage procedures.
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Definitions and Background

Cloud PCI compliance is a must for any business handling cardholder data.
A cardholder data environment (CDE) refers to any part of your app that holds or transfers any cardholder data. This includes the payment account number or any personally identifiable information related to the card.
If you're not familiar with PCI DSS, it's a set of standards for securing cardholder data. Qualified Security Assessors (QSAs) are qualified by the PCI Security Standards Council (SSC) to perform PCI DSS on-site assessments.
Self-Assessment Questionnaire (SAQ) is a reporting tool used to document self-assessment results from an entity's PCI DSS assessment, but it only applies for entities that are eligible for self-assessment.
Tokenization is a process that replaces the primary account number (PAN) with a surrogate value called a token. This token is then stored in a secure lookup, and de-tokenization is the reverse process of looking up a PAN by its token.
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Security Measures
To secure your network, you need to create Cloud Next Generation Firewall policies or Compute Engine firewall rules, a Cloud VPN tunnel, and an External Application Load Balancer. Cloud NAT is also recommended for an additional layer of network security. Cloud DNS offers private DNS zones, which allow you to securely name hosts within your CDE without leaking sensitive network topology data to the public.
To establish a secure VPN tunnel, you can use Cloud VPN to connect your on-premises environment to your payment-processing environment. This is crucial for protecting sensitive data and ensuring compliance with PCI DSS standards.
To help secure your app, you should evaluate the administrator interface and consider using Cloud Key Management Service. This will provide an additional layer of security and help prevent unauthorized access to your application.
Here are some key security measures to implement:
- Cloud Next Generation Firewall policies or Compute Engine firewall rules
- Cloud VPN tunnel
- External Application Load Balancer
- Cloud NAT
- Cloud Key Management Service
Attestation Process
To verify your cloud service provider's security, you'll need to obtain an attestation of compliance (AOC) from them.
An AOC is a statement that acknowledges the CSP's responsibility for PCI DSS compliance, which is required by the PCI DSS to be done annually. You should have this on file to ensure your CSP is doing their part to protect your sensitive data.
A CSP's business model relies on providing secure data storage, so it's assumed they're invested in providing a secure infrastructure, but it's still important to do your homework.
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Securing Your Network
Securing your network is crucial for a payment-processing app. Cloud Next Generation Firewall policies or Compute Engine firewall rules can be created to secure inbound and outbound traffic.
Cloud VPN tunnels can be established to secure VPN connections between on-premises environments and payment-processing environments. This is especially important for sensitive data and transactions.
A Cloud VPN tunnel can be used to create a secure connection between on-premises and cloud environments. This ensures that sensitive data is protected from unauthorized access.
Cloud NAT can be used to provide an additional layer of network security. This can be especially useful for Compute Engine and GKE instances.
Cloud DNS offers private DNS zones, which can be used to securely name hosts within a CDE without leaking sensitive network topology data to the public.
Here are some key network security measures to consider:
- Cloud Next Generation Firewall policies or Compute Engine firewall rules
- Cloud VPN tunnels
- External Application Load Balancer
- Cloud NAT
- Cloud DNS private zones
These measures can help protect your network and prevent unauthorized access to sensitive data. By implementing these security measures, you can ensure that your payment-processing app is secure and compliant with PCI DSS requirements.
Secure Package Management

Secure Package Management is a must-have in a security-hardened hosting environment. It's a key component that helps prevent supply-side attacks, which are becoming more common.
You likely have a package manager installed, such as RPM, Yum, or Apt, unless you're using Container-Optimized OS from Google. Your app might also use its own programming language-specific package manager, like NPM, PyPi, or Composer.
Treat update sources as a potential security risk, especially if your app can fetch updates from the internet. Imagine the effects of installing an update to SSH that contains malicious code.
Create a safe recipients list for your packages and verify that they match the list. Keep a record of tested and approved version numbers for each package, along with its hash or signature.
Most package management systems allow for private hosting, so consider launching your own private package management server. This way, you can only host tested and approved software, and lock down the package manager to prevent it from reaching out to other servers for updates.
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Ideally, your app build process fetches and validates all packages, then creates a revision of the custom disk image that includes everything the container needs. This reduces the chance of random errors at launch time and allows you to revisit previous versions of your app exactly as they were in production.
Sanitizing Sensitive Data
Sanitizing sensitive data is a crucial step in protecting it. You can use Sensitive Data Protection to sanitize data, which is a requirement for apps that need to access PCI data.
There are many good reasons to sanitize data, such as for analytics or development. You can grant apps access to PCI data only after it has been sanitized.
Sensitive Data Protection is necessary to protect data that's not in scope, but still useful. This helps prevent unauthorized access to sensitive information.
By sanitizing data, you can ensure it's only accessed by apps that need it, and that it's not compromised in any way. This is especially important for PCI data, which requires special protection.
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Encryption and Key Management Solutions
Encryption and key management are crucial security measures that protect your data from unauthorized access. Cloud Key Management Service (Cloud KMS) is a service that lets you manage encryption keys, generating, using, rotating, and destroying keys for various encryption algorithms.
Using Cloud KMS can simplify compliance with certain security standards, such as removing plain-text passwords stored in code or config files. This is especially important for sections 2.2.2, 3.6, 3.7, and 8.2.
To maintain secure key management, it's essential to separate your data encrypting keys (DEKs) from your key encrypting keys (KEKs). This means that the encryption for your KEKs should be at least as strong as, or stronger than, that of your DEKs.
For example, RSA-3072 is equivalent to AES-128, according to NIST SP 800-57. This equivalence helps ensure that your KEKs are adequately protected.
Set up key rotation policies to provide resiliency to manual rotation, prevent brute force attacks, and limit the number of actual messages vulnerable in the event of a compromise. This can be achieved by:
- Providing resiliency to manual rotation
- Helping prevent against brute force attacks by limiting the number of messages encrypted with the same key
- Limits the number of actual messages vulnerable in the event of a compromise
DuploCloud offers a solution for encryption and key management under PCI-DSS by orchestrating AWS KMS and Azure Key Vault keys per tenant. It restricts access to encryption keys, ensuring they are only granted to instance profiles without user accounts, aligning with PCI DSS encryption and key management standards.
Cloud Provider Specifics
Amazon Web Services (AWS) provides a robust framework that aligns well with PCI DSS v4.0 requirements, offering tools and services that facilitate compliance.
AWS offers an extensive array of services that can be configured to meet specific PCI DSS v4.0 requirements, such as Amazon VPC for secure networking or AWS IAM for detailed access control.
AWS Cognito and AWS KMS provide advanced solutions for user authentication and data encryption, essential for protecting sensitive payment information.
Tools like AWS Shield and AWS WAF help manage and mitigate risks in real time, aligning with the continuous risk management approach mandated by PCI DSS v4.0.
AWS Artifact and other compliance documentation tools offer essential resources for understanding and implementing necessary security measures in line with PCI DSS standards.
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Best Practices and Guidance
Ensuring the adequate protection of your data in a cloud environment can be very challenging and quite complex. It requires careful consideration of various factors to maintain PCI DSS compliance.

We cannot forget the people side of compliance, and in some cases, it can be the hardest part! It's not just about implementing technical measures, but also about educating and engaging your team to ensure everyone is on the same page.
Consider five key best practices to help your organization secure its information assets: these are crucial steps to take in order to maintain cloud PCI compliance.
Things to Consider
When you're storing sensitive data in the cloud, you can't just assume it's secure. There are more businesses using the cloud infrastructure than just yours, which is where the big risk lies.
In a shared infrastructure, someone could potentially break out of their environment and get unauthorized access to your data. This is a major concern for businesses that need to maintain PCI compliance.
Encryption is a key tool for addressing this risk, but it's not the only consideration. You also need to think about how you're going to protect your data in the event of a breach or other disaster.
Businesses need to be aware of the risks associated with shared cloud infrastructure and take steps to mitigate them. This includes implementing robust security measures and regularly monitoring your data for any signs of unauthorized access.
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Best Practices

Securing your data in a cloud environment can be challenging and complex, but there are key best practices to follow. Ensuring PCI DSS compliance requires careful consideration of these practices.
One of the hardest parts of compliance is the people side of it. In some cases, it can be the most difficult to manage.
Protecting your data in a cloud environment requires a multi-faceted approach. Consider implementing five key best practices to secure your information assets.
Simplify Your Journey with Duplo
DuploCloud simplifies the process of PCI DSS compliance for businesses handling credit card transactions.
Navigating PCI DSS compliance can be complex, but DuploCloud provides an effective, all-in-one framework solution for seamless compliance.
With DuploCloud, you can reinforce your commitment to secure transactions and enhance trust among your clients.
DuploCloud helps turn compliance into a business advantage, making it a valuable solution for companies in this industry.
Frequently Asked Questions
Is Azure cloud PCI compliant?
Yes, Microsoft Azure is PCI compliant, having achieved Service Provider Level 1 certification and maintaining validation through a qualified security assessor. You can view the publicly available Attestation of Compliance (AOC) for more details.
What are the changes for PCI compliance in 2024?
PCI compliance in 2024 requires implementing Multi-Factor Authentication (MFA) for secure access to Cardholder Data Environments (CDE). This change aims to strengthen payment data protection and meet the new PCI DSS v4.0 standards
Sources
- https://www.securitymetrics.com/blog/PCI-compliance-cloud
- https://cloud.google.com/architecture/pci-dss-compliance-in-gcp
- https://ermprotect.com/blog/how-to-achieve-pci-compliance-in-the-cloud-as-security-controls-evolve/
- https://www.schellman.com/blog/pci-compliance/making-pci-compliance-cloud-native
- https://duplocloud.com/solutions/security-and-compliance/pci-dss/
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