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Guide to PCI compliance cost
When you think about the pros and cons of PCI compliance, you think about the worst case scenario: how terrible it would be to be affected by a data breach. It can devastate your reputation and lose the trust of your customers.
At the end of the day, though, everything comes down to dollars and cents when you’re running a business. So it’s important to know what you’re getting into before your PCI compliance process. Learn about the cost of a Report on Compliance (ROC), various documentation factors, and the potential large-scale needs associated with compliance. Let's take a deep dive into what you can expect from your PCI DSS costs.
How much does it cost to become PCI compliant?
It should come as no surprise that there isn’t a singular average cost of PCI compliance for all businesses. Costs vary considerably from one business to another based on many factors, such as:
- The number of transactions you process annually
- The size of your network
- Your organization and its current security readiness
- The size of your organization
Those are only a few factors that impact your initial on ongoing costs.
It’s important to note that there are two types of costs that you could incur: costs to implement the PCI DSS standards and costs to certify or document your compliance. Your costs to implement the PCI standards will vary considerably based on the size of your network and how secure it already is.
The cost for documenting your PCI compliance depends on the size of your business. Businesses who process under six million credit card transactions per year will have minimal costs, often just a few hundred dollars per year or less. Businesses that process over six million annual transactions must pay for an onsite audit, which costs thousands each year.
To help you budget for your PCI compliance, let’s break down the typical expenses you can expect for both documentation and implementation.
Costs involved in PCI documentation
PCI documentation can be time consuming without an automated system. The job of figuring out PCI compliance and then following through with documentation usually falls to the hand’s of the company’s head of engineering. This person will then have to spend several hours, weeks, or even months researching, documenting, and then solving the PCI compliance issues that arise. That is a lot of time spent on PCI documentation that could have been spent on building products. It might cost your organization a lot of money spending more time on PCI compliance than on product growth.
The costs listed above will bring your business security up to speed so that you’re adhering to all the PCI DSS standards. However, there’s one more step involved. There are processes you need to follow to officially document your PCI compliance.
This PCI certification cost varies considerably depending on how PCI DSS classifies your business. If you’re a level two, three, or four merchant or a level two service provider, you only need to complete a self-assessment questionnaire, purchase a vulnerability scan, and sign an attestation of compliance form. If you’re a level one merchant or level one service provider, you have the added PCI assessment cost of an onsite audit.
Vulnerability scanning involves paying an approved scanning vendor, or ASV, to scan your system and check for security vulnerabilities. These scans are only available from providers that the PCI Security Standards Council has already reviewed and approved. The scans typically cost around $200 and up. Merchants and service providers at all levels need to receive these scans.
Onsite PCI audit
For level one merchants and level one service providers (that is, merchants who process over six million transactions per year or service providers who process over 300,000 transactions per year), an audit is a necessary yet costly part of the PCI compliance process.
You’ll need to hire a qualified security assessor or QSA to conduct an onsite audit of your system and your security practices. This audit report is known as a ROC. You’ll have to choose an assessor that appears on PCI SSC’s approved vendor list. Prices are typically quoted from $30k to $200k annually to complete a ROC. Shopping for a QSA can be an opaque and confusing process. A PCI compliance platform can help identify appropriate assessors and ease the stress associated with PCI compliance costs.
Costs involved in becoming PCI compliant
When we ask, “How much does it cost to become PCI DSS compliant?,” there’s not a simple number we can average out for all businesses. While the PCI standards are the same for all businesses, larger organizations usually pay more to secure their networks because of their large-scale needs. In any case, there are several costs you can expect to pay.
PCI DSS requires that you have a firewall to protect your customers’ data. For most businesses, this involves paying an ongoing monthly or annual fee for a pre-developed firewall and paying your developers to update it as needed.
Another requirement of PCI DSS is that you encrypt any payment data as it is transmitted. Typically, this is a process that your internal or outsourced developers will put in place, so you will incur the cost of your developers’ time.
PCI DSS requires that anyone accepting or processing payments maintains an antivirus software to block viruses from invading their networks and accessing customer data. This is typically an ongoing subscription fee that you will pay.
Identity verification and access control
To be PCI compliant, you need to limit which employees have access to sensitive data within your network. To do this, you need an identity verification system to make sure that those who are accessing the data are truly those who are authorized to access it.
While some organizations choose to have their internal developers create an access control system, most businesses opt to purchase it instead. This is typically a continuous licensing fee that you will pay annually or monthly.
Your company’s network needs to be set up in a secure way and continuously monitored to make sure it lives up to the latest security standards. While this isn’t a product or service you can purchase like a firewall and antivirus software, it does cost you in the form of your developers’ time.
Training and policy development
PCI DSS doesn’t only outline specifications for your technical system. It also requires certain policies your staff needs to develop and maintain. The process of creating appropriate policies, designing ways to implement and enforce them, and training employees on the new policies can add up in the form of labor costs.
Learn more about PCI DSS
Determine whether the GDPR applies to you and if so, if you are a processor or controller (or both)
Do you sell goods or service in the EU or UK?
Do you sell goods or services to EU businesses, consumers, or both?
Do you have employees in the EU or UK?
Do persons from the EU or UK visit your website?
Do you monitor the behavior of persons within the EU?
Create a Data Map by taking the following actions
Identify and document every system (i.e. database, application, or vendor) which stores or processes EU or UK based personally identifiable information (PII)
Document the retention periods for PII in each system
Determine whether you collect, store, or process “special categories” of data
Determine whether your Data Map meets the requirements for Records of Processing Activities (Art. 30)
Determine whether your Data Map includes the following information about processing activities carried out by vendors on your behalf
Determine your grounds for processing data
For each category of data and system/application have you determined the lawful basis for processing based on one of the following conditions?
Take inventory of current customer and vendor contracts to confirm new GDPR-required flow-down provisions are included
Review all customer contracts to determine that they have appropriate contract language (i.e. Data Protection Addendums with Standard Contractual Clauses)
Review all in-scope vendor contracts to determine that they have appropriate contract language (i.e. Data Protection Addendums with Standard Contractual Clauses)
Have you performed a risk assessment on vendors who are processing your PII?
Determine if you need to do a Data Protection Impact Assessment
Is your data processing taking into account the nature, scope, context, and purposes of the processing, likely to result in a high risk to the rights and freedoms of natural persons?
Review product and service design (including your website or app) to ensure privacy notice links, marketing consents, and other requirements are integrated
Does the notice to the data subject include the following items?
Does the notice also include the following items?
Do you have a mechanism for persons to change or withdraw consent?
Update internal privacy policies to comply with notification obligations
Update internal privacy notices for EU employees
Determine if you need to appoint a Data Protection Officer, and appoint one if needed
Have you determined whether or not you must designate a Data Protection Officer (DPO) based on one of the following conditions (Art. 37)?
If you export data from the EU, consider if you need a compliance mechanism to cover the data transfer, such as model clauses
If you transfer, store, or process data outside the EU or UK, have you identified your legal basis for the data transfer (note: most likely covered by the Standard Contractual Clauses)
Have you performed and documented a Transfer Impact Assessment (TIA)?
Confirm you are complying with other data subject rights (i.e. aside from notification)
Do you have a defined process for timely response to Data Subject Access Requests (DSAR) (i.e. requests for information, modification or deletion of PII)?
Are you able to provide the subject information in a concise, transparent, intelligible and easily accessible form, using clear and plain language?
Do you have a process for correcting or deleting data when requested?
Do you have an internal policy regarding a Compelled Disclosure from Law Enforcement?
Determine if you need to appoint an EU-based representative, and appoint one if needed
Have you appointed an EU Representative or determined that an EU Representative is not needed based on one of the following conditions?
If operating in more than one EU state, identify a lead Data Protection Authority (DPA)
Do you operate in more than one EU state?
If so, have you designated the Supervisory Authority of the main establishment to act as your Lead Supervisory Authority?
Implement Employee Trainings to Demonstrate Compliance with GDPR Principles and Data Subject Rights
Have you provided appropriate Security Awareness and Privacy training to your staff?
Update internal procedures and policies to ensure you can comply with data breach response requirements
Have you created and implemented an Incident Response Plan which included procedures for reporting a breach to EU and UK Data Subjects as well as appropriate Data Authorities?
Do breach reporting policies comply with all prescribed timelines and include all recipients i.e. authorities, controllers, and data subjects?
Implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk
Have you implemented encryption of PII at rest and in transit?
Have you implemented pseudonymization?
Have you implemented appropriate physical security controls?
Have you implemented information security policies and procedures?
Can you access EU or UK PII data in the clear?
Do your technical and organizational measure ensure that, by default, only personal data which are necessary for each specific purpose of the processing are processed?
Develop a roadmap for successful implementation of an ISMS and ISO 27001 certification
Implement Plan, Do, Check, Act (PDCA) process to recognize challenges and identify gaps for remediation
Consider ISO 27001 certification costs relative to org size and number of employees
Clearly define scope of work to plan certification time to completion
Select an ISO 27001 auditor
Set the scope of your organization’s ISMS
Decide which business areas are covered by the ISMS and which are out of scope
Consider additional security controls for business processes that are required to pass ISMS-protected information across the trust boundary
Inform stakeholders regarding scope of the ISMS
Establish an ISMS governing body
Build a governance team with management oversight
Incorporate key members of top management, e.g. senior leadership and executive management with responsibility for strategy and resource allocation
Conduct an inventory of information assets
Consider all assets where information is stored, processed, and accessible
- Record information assets: data and people
- Record physical assets: laptops, servers, and physical building locations
- Record intangible assets: intellectual property, brand, and reputation
Assign to each asset a classification and owner responsible for ensuring the asset is appropriately inventoried, classified, protected, and handled
Execute a risk assessment
Establish and document a risk-management framework to ensure consistency
Identify scenarios in which information, systems, or services could be compromised
Determine likelihood or frequency with which these scenarios could occur
Evaluate potential impact of each scenario on confidentiality, integrity, or availability of information, systems, and services
Rank risk scenarios based on overall risk to the organization’s objectives
Develop a risk register
Record and manage your organization’s risks
Summarize each identified risk
Indicate the impact and likelihood of each risk
Document a risk treatment plan
Design a response for each risk (Risk Treatment)
Assign an accountable owner to each identified risk
Assign risk mitigation activity owners
Establish target dates for completion of risk treatment activities
Complete the Statement of Applicability worksheet
Review 114 controls of Annex A of ISO 27001 standard
Select controls to address identified risks
Complete the Statement of Applicability listing all Annex A controls, justifying inclusion or exclusion of each control in the ISMS implementation
Continuously assess and manage risk
Build a framework for establishing, implementing, maintaining, and continually improving the ISMS
Include information or references to supporting documentation regarding:
- Information Security Objectives
- Leadership and Commitment
- Roles, Responsibilities, and Authorities
- Approach to Assessing and Treating Risk
- Control of Documented Information
- Internal Audit
- Management Review
- Corrective Action and Continual Improvement
- Policy Violations
Assemble required documents and records
Review ISO 27001 Required Documents and Records list
Customize policy templates with organization-specific policies, process, and language
Establish employee training and awareness programs
Conduct regular trainings to ensure awareness of new policies and procedures
Define expectations for personnel regarding their role in ISMS maintenance
Train personnel on common threats facing your organization and how to respond
Establish disciplinary or sanctions policies or processes for personnel found out of compliance with information security requirements
Perform an internal audit
Allocate internal resources with necessary competencies who are independent of ISMS development and maintenance, or engage an independent third party
Verify conformance with requirements from Annex A deemed applicable in your ISMS's Statement of Applicability
Share internal audit results, including nonconformities, with the ISMS governing body and senior management
Address identified issues before proceeding with the external audit
Undergo external audit of ISMS to obtain ISO 27001 certification
Engage an independent ISO 27001 auditor
Conduct Stage 1 Audit consisting of an extensive documentation review; obtain feedback regarding readiness to move to Stage 2 Audit
Conduct Stage 2 Audit consisting of tests performed on the ISMS to ensure proper design, implementation, and ongoing functionality; evaluate fairness, suitability, and effective implementation and operation of controls
Address any nonconformities
Ensure that all requirements of the ISO 27001 standard are being addressed
Ensure org is following processes that it has specified and documented
Ensure org is upholding contractual requirements with third parties
Address specific nonconformities identified by the ISO 27001 auditor
Receive auditor’s formal validation following resolution of nonconformities
Conduct regular management reviews
Plan reviews at least once per year; consider a quarterly review cycle
Ensure the ISMS and its objectives continue to remain appropriate and effective
Ensure that senior management remains informed
Ensure adjustments to address risks or deficiencies can be promptly implemented
Calendar ISO 27001 audit schedule and surveillance audit schedules
Perform a full ISO 27001 audit once every three years
Prepare to perform surveillance audits in the second and third years of the Certification Cycle
Consider streamlining ISO 27001 certification with automation
Transform manual data collection and observation processes into automated and continuous system monitoring
Identify and close any gaps in ISMS implementation in a timely manner
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Determine which annual audits and assessments are required for your company
Perform a readiness assessment and evaluate your security against HIPAA requirements
Review the U.S. Dept of Health and Human Services Office for Civil Rights Audit Protocol
Conduct required HIPAA compliance audits and assessments
Perform and document ongoing technical and non-technical evaluations, internally or in partnership with a third-party security and compliance team like Vanta
Document your plans and put them into action
Document every step of building, implementing, and assessing your compliance program
Vanta’s automated compliance reporting can streamline planning and documentation
Appoint a security and compliance point person in your company
Designate an employee as your HIPAA Compliance Officer
Schedule annual HIPAA training for all employees
Distribute HIPAA policies and procedures and ensure staff read and attest to their review
Document employee trainings and other compliance activities
Thoroughly document employee training processes, activities, and attestations
Establish and communicate clear breach report processes
to all employees
Ensure that staff understand what constitutes a HIPAA breach, and how to report a breach
Implement systems to track security incidents, and to document and report all breaches
Institute an annual review process
Annually assess compliance activities against theHIPAA Rules and updates to HIPAA
Continuously assess and manage risk
Build a year-round risk management program and integrate continuous monitoring
Understand the ins and outs of HIPAA compliance— and the costs of noncompliance
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