The PCI Security Standards Council officially has released the 3.0 version of the PCI DSS standard. Businesses have plenty of time to begin assessing their data security practices against these updated and new rules, but for many, this will require some work.
So how do you get started? Take a deep breath, and consider these tips to help begin the process.
Learn what's changed. First, you need to understand what changed between the old version, PCI DSS 2.0, and the new one, version 3.0. A good place to start is by watching a webinar we produced or checking out this blog post. But if you're short on time, it would be useful to conduct an internal risk assessment or engage a professional to perform a gap assessment. Both can help you set straight a risk strategy that takes the changes into account.
Scope it out. In versions 3.0, the boundaries of what's considered "in scope" during a PCI DSS assessment are stricter, effectively expanding what's considered the cardholder data environment. Review your current PCI DSS scope and network segmentation diagrams and practices. Understand the new rules and how they will affect your approach to scope and segmentation.
Form a relationship with your vendors. If you're not intimately familiar with the security practices of your service providers, it might be time to pick up the phone to learn this information. The new PCI DSS version institutes more rigor in contract language between parties.
Pencil in the pen test. Penetration testing of your environment is a critical step in security and compliance to make sure no stone is unturned. The PCI council has expanded pen testing requirements to include any network segment that is near the cardholder data environment, and it expects expert testing. What does this mean? That it won't fly if you're using a software solution to perform your pen testing in 3.0.
Location. Location. Location (of your data): Do you know a large number of successful attacks take place on merchant environments that are NOT storing cardholder data? The bad guys are stealing valuable data in transit. So what does your business need to do? You should be able to describe how you protect cardholder data, and if you can't, you won't meet the new standard and you'll be exposing your organization.
Version 3.0 is not the silver bullet. And neither is the next version. Or the one after that. Or ever. Remember, the PCI standard is an evolving set of best practices that changes as the industry changes. It's important to understand where PCI falls short because compliance will only get you so far.
For example, a PCI-compliant password is several characters long and is alpha-numeric. Under these guidelines, you can use "Password1" - the most commonly used password in the world - and according to the current rules, still achieve compliance. But a legacy of brute-force password breaches tells us to think otherwise when choosing a secret word or phrase.
As always, Trustwave is here to answer your questions on overcoming PCI DSS version 3.0 challenges. Keep an eye on this blog for more to come.
Greg Rosenberg is a security engineer at Trustwave.