PCI DSS Audit

How to Prepare for a PCI DSS Audit

April 16, 2020

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Regardless of your previous knowledge, your next PCI DSS audit will evaluate whether your organization is compliant and has vulnerabilities.

A PCI DSS compliance audit examines the security measures you have implemented to see if you comply with the latest data security requirements. Compliance with PCI means cardholder data remains secure.

You may incur different penalties if you do not comply with the PCI DSS requirements. You may even lose the ability to accept or store payment card data. Problems that may arise may compromise your ability to gain customers and keep your business, or perhaps wholly weaken your profitability as a business.

If you are going through your first audit, your performance will depend on how well you are prepared. Preparing for the PCI DSS compliance audit will help you maintain compliance and ensure your customers are confident of their data.

Compliance with PCI DSS is not a one-time event, but a continuous improvement process to introduce specific protections whenever possible.

To clarify the current status of the PCI DSS Program, companies should conduct a periodic PCI audit. Often companies are reluctant to do this type of work, unless they request a third party, due to the extra workload that can occur with the PCI DSS audit.

However, with the right planning, it will reduce your chances of failing the PCI compliance audit, and therefore the audit process will become even less stressful.

Do Not Assume You Are PCI DSS Compliant Before Auditing

PCI DSS is an evolving standard. It aims to ensure that businesses that process, store, or transmit payment card data implement security measures to prevent cardholder data theft.

Over the years, technology and industry have changed tremendously, and PCI DSS has had to adapt to the changes to solve security problems. Merchants and service providers shall comply with the latest version of PCI DSS 3.2.1 requirements and shall continue to operate by those standards.

For this reason, your company needs to pay attention to the scope of PCI DSS. Misidentification of PCI scope is a standard compliance issue. PCI DSS defines your scope as all device components used within or related to the Cardholder Data Environment (CDE). A review of your coverage is necessary to know if business policies and procedures need to change.

When you change the way you handle cards or plan to make changes to your cardholder environment, you can consult your QSA to see its impact on PCI DSS compliance.

Perform PCI DSS Gap Analysis to Determine Your Situation

Do not assume that you will be compatible automatically this year because you were compatible last year. Organizations can work with a QSA early without adequate preparation to ensure that they are fully compliant with PCI DSS.

The PCI DSS compliance onsite audit process can take a long time when you are not ready. To be a better and more cost-effective solution, a QSA can pre-audit your company to evaluate what you are doing against the specific needs of PCI DSS and perform a PCI DSS gap analysis as a starting point.

In this way, you can identify your deficiencies before the audit, take quick actions, and enter the PCI DSS onsite audit-ready.

Prepare Your Documents and Records

Document all safety activities and precautions so that auditors can quickly find potential problems. The more detailed your records are, the faster and smoother the audit process will be.

In some companies, documentation can be seen as a chore and demanding work. However, proper documentation protects the organization, especially by clearly stating security processes. If you have also verified that the documents are updated regularly, it would be best.

The documentation should contain complete information about encryption protocols, key management processes, and procedures to secure stored card data. Such records show that the company meets the appropriate compliance requirements and provides a registered and controllable way to continue to meet the needs by reviewing the clauses.

Remember that when changes occur in your business policies or card data environment, you must document them. These changes may change your PCI compliant environment and applications.

Create Your Card Data Flowcharts and CDE Network Topology

Creating visual representations of your processes helps explain the movement of your sensitive personal data inside and outside your company. This also provides a simple way to identify weaknesses and shortcomings in current operations.

Your relevant employees will come up with an appropriate solution to potentially identified problems before the auditors arrive. But make sure these flowcharts are updated frequently, along with the rest of your documentation.

Network diagrams are vital as they show how systems communicate with card data. Systems that store, process, or transmit card data in your network must be properly isolated and secured from other systems in your network.

Most companies have an extensive flat network with a firewall at the end. Inside the network, everything is interconnected. Flat networks put the entire network in PCI DSS scope, making it incredibly difficult to secure card data.

To avoid network-related issues, you can create a diagram showing how cardholder data enters your network and the systems it affects as it is transmitted across your network. Some companies have only one stream, but if you are processing card data over different channels, you need to create a card data flow diagram for each.

Network and card data flow diagrams are intended to help you understand which systems store, process, or transmit cardholder data. You can analyze your network and determine if it fits your card flow diagram by asking yourself the following questions.

How was your network designed?
Is there an edge firewall in your card processing environment?
Is your network segmented?
Do you have a multi-interface firewall in your environment?
Are you using more than one firewall?

After answering the above questions, you can make the necessary changes in your network to set up correctly.

Develop Risk Assessments Periodically and in Changes

Risk assessments are a critical factor in defining and implementing emerging technologies. Your change management team should analyze an already new system and its potential impact on existing infrastructure.

Therefore, to determine the impact of changes in compliance with PCI DSS, you can analyze the same due diligence.

Risk Analysis and assessments allow you to assess and test the impact of system changes on a smaller scale than PCI audits.

Test Your Infrastructure Regularly

Proactively control your Cardholder Data Environment (CDE). Cybersecurity auditors, qualified security assessors (QSA), and information security consultants will help you assess your PCI DSS compliance as well as your security protection.

Perform the following tests and take the necessary measures based on the results:

Web application testing: The web application testing required annually is to meet the testing and reporting requirements in PCI DSS Requirement 6.6.
Local network vulnerability scanning: Local network vulnerability scanning allows you to identify vulnerabilities in your local network. You should perform local network vulnerability scans every three months throughout the year.
Vulnerability scanning: Vulnerability scan (ASV) that tests your external network systems by an authorized scanning provider to meet PCI DSS Requirement 11.2. You should perform ASV scans every three months throughout the year.
Penetration testing: You must perform an annual penetration test to meet PCI DSS Requirement 11.3.

Keep in Touch with Your Assessor (QSA) Throughout the Year

PCI QSA auditors are often willing to share their compliance-related information. They love to see IT or compliance managers doing their best to keep compliance healthy. If you have difficult times with PCI DSS compliance, an auditor will be happy to assist.

If you can reach your QSA throughout the year, do so and ask any questions you need help with. Organizations can grow within a year, card data environments change, and PCI DSS requirements can be updated. QSAs are an excellent resource to help you prepare for a PCI DSS audit. This way, you can have more time to troubleshoot any problems that may arise.

Involve All Stakeholders in the PCI DSS Compliance Process

You need to know precisely where the card-related information is stored, processed, or sent. PCI DSS Requirement 1.1.3 requires companies to provide a clear data flow chart for cardholders. If you know where the data flows, stores, and communicates with the card, a card flow diagram can be created quickly to show how data flows and affects your environment.

Business stakeholders need to be involved in the new procedures and overall PCI compliance after finding out where systems store, process, or transfer cardholder data.

For example, ask employees to find specific locations where data can be hidden unknowingly. Popular areas and departments that store data are as follows:

Error logs generally store unencrypted credit card data. Because it usually generates an error log when an error occurs during card authentication or processing, and it usually contains full card data.
Accounting departments typically have processes that store unencrypted data for financial purposes.
Sales departments can inadvertently email or print forms containing credit card numbers.
Marketing departments with market research databases containing transaction data.
Customer service representatives can obtain credit card numbers or view all card numbers over the phone. So look for handwritten or printed card information.
Administrative assistants can create a spreadsheet with credit card numbers for easy access when paying from a business or a manager.

Get Support from a Third-Party Expert in Your Missing Issues

In most cases, it makes sense to collaborate with a third party. Because each firm’s expertise is in a different field, second, they provide a new perspective on processes that may be too familiar to your employees and push them to make objective assessments.

Also, experts can propose changes and improvements found to provide significant benefits elsewhere as they gain more competence in their field.

You can outsource activities such as reviewing firewall rules, analyzing source code, vulnerability and correction works, and updating documents.

Assign a Compliance Leader for the PCI DSS Audit Process

PCI compliance is not just a “yes” check for all questions of the Self-Assessment Questionnaire (SAQ) or PCI DSS requirements. Effective PCI DSS compliance requires you to execute each control item properly.

PCI DSS compliance can be time-consuming and sometimes challenging. Therefore, assigning a person responsible for PCI compliance will help you run the process more smoothly. Adequate support and time should be given to the compliance leader to manage PCI compliance. Compliance officers should be able to criticize and change company practices and policies.

Final Words on PCI DSS Audit Readiness

PCI controls are an inevitable compliance factor when you play a role in online payments. A voluntary six-month review is preferable to a non-compliance audit or even a breach. Audits show that your organization regularly meets its obligations to protect sensitive data.

Compliance with PCI DSS should not be a mere one-year check task. Your workforce, infrastructure, card data environment, and security procedures change throughout the year, so you need to regularly maintain PCI compliance. Stay in touch with your QSA throughout the year to assist the process, especially as you prepare cardholder data for any improvement in your environment.