It is well known by now that the major credit card companies have collectively mandated that all members, merchants and service providers storing, processing or transmitting cardholder data must adhere to the Payment Card Industry (PCI)'s "12 commandments" -- the dozen overarching best practices that make up the guideline -- or else risk possible fines and even the termination of credit card processing privileges. In addition, by Sept. 30, 2007, all Level 2 organisations -- merchants processing more than 150,000 Visa or MasterCard transactions each year or merchants that process more than 1 million transactions annually -- must be compliant with these standards. Unfortunately, the path to PCI DSS compliance can be demanding due to the amount of money, time and effort required.
This learning guide will review a few of the more challenging PCI DSS requirements and provide some tips that enterprises can use to achieve PCI DSS compliance.
DSS: Where are organisations struggling?
All of the PCI DSS requirements seem to be fairly well defined, unlike those of the Sarbanes-Oxley Act. SOX does not provide any specific direction on how to secure information assets and has been open to varying interpretations by companies and compliance audit firms. Nevertheless, organisations still find it difficult to become PCI DSS compliant. In an interesting study conducted by VeriSign, researchers found that organisations were most likely to be noncompliant with PCI Requirement 3. Seventy-nine percent of the failed assessments did not meet the requirement to protect stored data. According to VeriSign, the top five PCI assessment failings were:
| Requirement 3: | Protect stored data | 79% |
| Requirement 11: | Regularly test security systems and processes | 74% |
| Requirement 8: | Assign a unique ID to each person with computer access | 71% |
| Requirement 10: | Track/monitor network resources and cardholder data | 71% |
| Requirement 1: | Install and maintain a firewall configuration to protect data | 66% |
The Slaughterhouse-Five: Why are these problem areas?
Regardless of the fact that PCI DSS is definitely comprehensive, the list of requirements allows for 12 potential points of failure; the inability to pass any one means an organisation won't be compliant. Additionally, even with the PCI DSS providing specific requirements, it can be interpreted differently by different types of organisations. Let's review the aforementioned PCI requirement failures, analyse why these might cause trouble for some organisations and discuss what measures can be taken to resolve the dilemma.
A GUIDE TO PASSING PCI'S FIVE TOUGHEST REQUIREMENTS