Learn about the essential steps for maintaining PCI compliance between audits. Proactive PCI compliance validation ensures audit readiness, fortifies security, builds trust, and minimizes financial risks.
When it comes to credit card payments, there’s a lot at stake for consumers and businesses, and the Payment Card Industry Data Security Standard (PCI DSS) has taken steps to reduce much of the risk. One key step is PCI compliance validation checks by auditors, which check whether organizations use the proper security controls and tools to protect sensitive data.
Naturally, an organization wants to avoid the fines and operational disruptions that could result from a failed audit. But by making sure you’re ready for your next audit, you also reduce the risk to your company and consumers.
To help you prepare, here’s a straightforward breakdown of some of the most common reasons businesses fail PCI audits and how to ensure you’re in compliance.
Common Reasons Businesses Fail PCI Audits
Even thoughtful, careful teams can miss one or two crucial details that can result in a failed audit. Here are some of the pitfalls that often catch teams unaware.
Unsecured Payment Data Storage
Unsecured payment data storage tops the list because it’s a serious violation and a surprisingly easy oversight. First of all, any database or storage system has to encrypt cardholder data. This may not be news, but here are some ways organizations can fall out of compliance:
- They encrypt cardholder data in their database, but their monitoring and logging system copies and stores it without encryption.
- A business, such as a restaurant, keeps physical copies of customer credit card authorization forms in an unlocked drawer or gives multiple employees access to it.
- An online store uses an e-commerce solution that processes payments but doesn’t encrypt payment details. The business doesn’t even know this info is unprotected in its database.
Weak Access Controls
Weak access controls continue to plague businesses, often because it’s easier for people to log in and do their work if they don’t have to go through detailed verification steps. However, what may feel like a boost in efficiency can be a thorn in the side during an audit. Common missteps include:
- A system that only requires a username and password instead of multifactor authentication (MFA)
- Employees sharing administrative login credentials
- Weak login credentials, such as usernames or passwords containing simplistic words like “admin” or “1234567!”
- Former employees still have valid access credentials despite no longer working there for several months or longer
Incomplete Network Segmentation
You need to isolate cardholder data from the general internet and those who have no need to ever see it. Often, the best way to do this is to put whatever server holds cardholder data on a different network than one used for other purposes.
Here are some common ways organizations fail to do this:
- Putting a point-of-sale (POS) system on the same network guests can access. A skilled attacker could connect as a guest and then navigate to where the organization stores payment data.
- Storing customer payment information on its own server but connecting that server to the same network the rest of the office uses. A malware infection from an employee clicking on a malicious link could impact customer payment data and intentionally send it to an attacker’s server.
- Neglecting to use strong firewall controls in front of the customer data segment of the network. This results in data flowing freely in and out of that network segment, which increases the risk of an exfiltration attack.
Failure to Conduct Regular Security Testing
Sometimes, because everything seems to be going very well, an organization may fail to test its security on a regular basis. But this could be a dangerous presumption, especially because attack methods evolve. Therefore, a measure that’s effective today may fall short tomorrow.
In some situations, regular testing may be in place, but the organization fails to follow through. For example, a company may perform vulnerability scans but fail to follow up on the issues it discovers.
Or an organization may perform penetration tests only for its web application. In reality, penetration testers should target all digital infrastructure, especially POS and payment systems. We’ve seen companies check all the boxes on their internal testing yet fail to adequately review their vendors’ compliance policies. This misstep can result in major fines and degrade customer trust, especially in critical infrastructures like finance and banking.
At the same time, it’s important not to overlook the threat of attacks on your physical environment. This is where weaving physical penetration testing into your security testing schedule can make a big difference.
For instance, suppose a company’s entryway security is less than tight. Perhaps a guard occasionally nods off on the job. Maybe you have people who leave as soon as their shift has finished — whether or not their replacement has shown up. Or perhaps your security staff lets people borrow other employees’ access cards. These and similar weaknesses can result in serious vulnerabilities.
Similarly, some of your staff may have a habit of leaving their computers open and unlocked when they take a break or go to the bathroom. Or maybe file cabinets containing sensitive or proprietary information aren’t properly locked. Oversights like these are common and can make it easy for a bad actor to enter sensitive systems and obtain physical copies of confidential information.
But by conducting regular security testing, you can catch and address a variety of vulnerabilities before they result in a breach.
Inconsistent Logging and Monitoring
Logs and alerts generated by monitoring systems are invaluable golden nuggets of security data, especially when it comes to payment processing. But it’s easy to slip into the habit of inadequately analyzing and following up on log data and the results of scans and monitoring systems.
For instance, an organization might:
- Review logs only occasionally, such as every month. This makes it difficult to pinpoint the causes of issues or ascertain the architecture of an attack.
- Collect logs but not check them for suspicious activity. Deciphering log information may require a trained professional, and some organizations may not have someone with the necessary skills.
- Fail to back up log data. If an outage or a successful attack brings down your system, you could lose the log data you need to perform a thorough forensic examination.
While the above pitfalls are common, you can take steps to avoid them before your next audit.
How to Validate PCI Compliance Before Your Next Audit: 7 Steps
Validating your PCI compliance in time for your next audit can be relatively straightforward, especially if you use experienced professionals who understand how to execute the following steps.
1. Confirm the Level of Compliance You Need to Adhere To
Figure out your PCI DSS validation level based on the number of transactions you perform. Then, identify the systems that handle card data.
2. Review Your Cardholder Data Security Policies
You should never store cardholder data, such as CVV codes and card numbers, unnecessarily. You should always use at least TLS 1.2 cryptography to secure payment details.
3. Strengthen Your Access and Authentication Controls
Use principles of least privilege and MFA for admin accounts and check that each admin uses unique credentials to log in. Regularly review the list of those who have access and always double-check that former employees can’t access your system.
4. Test Your Network Security and Segmentation
Your cardholder data environment (CDE) should be segmented and secured with strong firewall rules. If possible, it should live on its own well-secured network.
5. Perform Regular Security Assessments
You can catch potentially problematic vulnerabilities by conducting vulnerability scans and penetration tests at least once a quarter. By simulating real-world attacks, you can also discover gaps in employee cyber hygiene and unseen vulnerabilities like open ports or data entry fields without adequate validation.
6. Implement Continuous Logging and Monitoring
Use a security information and event management (SIEM) solution or a log management tool to detect unauthorized access to your CDE. Be sure to keep your logs for a year — at least — and review them regularly.
7. Conduct Employee Training and Policy Reviews
Employees should know how to handle payment data in the context of PCI compliance. If PCI DSS requirements change, you should immediately inform all employees and provide training.
The Outcome of Proactive PCI Compliance Validation
PCI compliance validation checks several important boxes with one stroke. For one, you avoid a PCI noncompliance fee, which is a penalty for falling short of PCI DSS standards. However, from a regulatory standpoint, you also increase the chances of passing an audit and filling compliance gaps that could otherwise result in a failed audit.
You also reduce the chances of a breach or financial loss as a result of stolen payment information. At the same time, you shrink the chances of suffering legal penalties as a result of a breach.
When you improve your monitoring and logging systems, you simultaneously strengthen your ability to detect and respond to incidents. Instead of guessing what happened or using trial and error, you have a concrete data trail to follow.
The effect these practices have on customer and payment processor confidence also can’t be overstated. For this reason, it helps to document the steps you take. If someone with the right to know asks, you can show them what you do, at least at a high level. And the lack of security incidents gradually bolsters customers’ and payment partners’ confidence in your organization.
Last but certainly not least, you save money. Over the long term, smooth, uninterrupted operations free of breaches and security issues will strengthen your financial posture. You don’t have to deal with fines, lawsuits or regulatory penalties. And you don’t have customers coming after you to settle outside of court in the wake of a data breach.
Be Audit-Ready With Continuous PCI Compliance
PCI compliance is an ongoing process. By embracing it as a regular facet of your security infrastructure, you may drastically reduce your cyber risk. Perform your own internal audits year-round and immediately address any issues that arise.
User access management isn’t a one-and-done step within your organization. We look at the dangers of user access complacency and how you can combat it.
Schedule a PCI assessment today using our compliance and validation services to identify and fix gaps before your next audit. Contact us
