How to get PCI compliant
Your business is uniquely yours, but every business owner has the same general goal: to have a stable and successful business that is beloved by loyal customers. It can take time to earn consumers’ trust, but if you aren’t maintaining the security you should, a data breach can torch that trust instantly.
That’s why PCI compliance is so critical: it’s a way to ensure that you’re taking the strongest reasonable precautions to protect your customers’ vital payment data. It’s also a way to avoid potential fines and complications from banks.
If you’re not sure how to become PCI compliant, this is a helpful place to start. Follow these PCI compliance steps to keep your customers and your business secure.
Step 1: Determine your PCI level
The PCI Security Standards Council or PCI SSC divides businesses into several levels depending on the way they use cardholder data and the number of ways that data transactions can impact people and businesses. For merchants, or businesses that accept card payments for goods or services, there are four levels. Level 1 merchants, for example, the highest level, include businesses that process six million or more credit card transactions per year.
There are also levels for service providers: Businesses that don’t take card payments directly, but come into contact with cardholder data in other ways, like storing, transmitting, or processing payments. A level 1 service provider deals with 300,000 or more credit card transactions annually.
Your level will determine the steps you need to take to achieve PCI compliance. Specifically, level 1 service providers and level 1 merchants need to have a third-party auditor complete an on-site audit for their compliance. Those at levels 2-4 self-assess their compliance with a questionnaire instead.
Step 2: Understand the PCI standards
The PCI Data Security Standard, or PCI DSS, is a set of standards your business needs to follow for PCI compliance. PCI DSS compliance involves twelve key steps, though there are smaller and more detailed criteria within the steps as well.
These are the PCI compliance 12 steps to know:
- Use and maintain a firewall to protect cardholders’ information.
- Ensure all passwords have been changed from the vendor-supplied default passwords.
- Protect stored data about cardholders.
- Encrypt any cardholder data that is transmitted over open or public networks.
- Use up-to-date antivirus software.
- Maintain secure systems and applications.
- Limit access to cardholder data to those in the company who need to access it.
- Set up a security ID system that assigns a unique ID code to each person in the company who uses a computer.
- Restrict access to any physically stored cardholder data.
- Monitor all digital activity that accesses network resources and cardholder data.
- Test security systems and processes frequently.
- Establish and maintain a security policy for employees and contractors.
Step 3: Determine where you stand
You know you need to satisfy all 12 PCI standards to be compliant, so the next step is to find out how many of them you already meet. This can be a time-consuming challenge to do manually.
Step 4: Tackle any remaining items on your to-do list
Now that you have a checklist of the PCI standards you don’t yet meet, you can use this as a to-do list. If you’ve been wondering, “How long does it take to become PCI compliant?” This step will largely answer that question for you. If you already meet most of the criteria, it could be a quick process. If not, your PCI compliance can take weeks or months to reach.
One step that any business will need to complete is to get a vulnerability scan. The PCI SSC requires a third-party scan from one of their approved scanning vendors or ASVs each quarter. This scan looks for potential security risks in your system so you can correct them, and it’s one of the requirements of standard 11.
Step 5a: For Level 1 merchants and Level 1 service providers: Complete a Report on Compliance
If you are a level 2-4 merchant or a level 2 service provider, your process for how to be PCI compliant is simpler so you can skip this step. If you’re a level 1 merchant or level 1 service provider, though, this is a pricy stage: hiring a Qualified Security Assessor (QSA) to complete a Report of Compliance (ROC). The QSA is like having a third-party auditor who will complete an on-site audit, the ROC, of your security systems to determine if you meet all the compliance criteria.
Step 5b: For non Level 1 merchants or service providers:
Merchants considered level 2-4 and service providers at level 2 will need to complete a Self-Assessment Questionnaire (SAQ). There are 8 different types of SAQs, and the first step is determining which Self-Assessment Questionnaire applies to your business. Then the SAQ must be completed, which can take anywhere from a couple days to a few weeks. The final step is completing an Attestation of Compliance (AOC), which is a signed document confirming your PCI compliance and your SAQ’s accuracy. This whole process must be done annually, unless you use an automated compliance platform which can alleviate the annual manual labor.
Step 6: Complete and submit your paperwork
Congratulations - the hard part is over! You’ve ensured that you’ve met all the criteria to get PCI certification, so the last step is to complete and submit your paperwork.
If you are a level 1 service provider or level 1 merchant, this includes completing an AOC and submitting it along with your auditor’s compliance report and your ASV scan. For all other levels, your paperwork includes a SAQ, and an AOC.
Making your PCI compliance smoother
PCI compliance requires in-depth security measures and it can be a long and challenging endeavor. If you’re still in the process of learning how to do PCI compliance (or even if you’re a pro), the right tools can make a world of difference.
Get PCI compliant
Vanta’s automated PCI DSS compliance tool
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?
Consider streamlining GDPR compliance with automation
Transform manual data collection and observation processes into continuous monitoring
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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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