What Does the Separation of Duties and Needs-to-Know Principles Stand for the PCI Requirement 7

Do all your staff have access to credit card information with the same authority? If so, you’re making it much easier for attackers to steal credit card information. Or what if a dissatisfied employee wants to take revenge and sell your information? If you don’t use Role-based Access control, your card data could be in great danger.

Needs to know is defined as the least amount of data an employee needs to be in a position to do his job. PCI DSS requirement 7 focuses on the “need to know” basis of business restrictions on accessing cardholder data.

See Also: How to Perform User Access Review

Employees often do not share the same obligations. The accountant has different duties than the manager of your program. If your accountant has the same system-level privileges as your system administrator, a new attack vector may have been developed within your organization.

If the accountant’s system is hacked, hackers can use them to access other systems and infiltrate other networks. This could potentially lead to a data breach for cardholder data. This is why PCI Requirement 7 is so vital to security.

Why Should You Restrict Access to Cardholder Data?

While one of the smallest parts of the PCI DSS requirements is PCI DSS Requirement 7, it is one of the most critical requirements.

PCI DSS requires you to have a Role-Based Access Control (RBAC) solution. Role-Based Access Control allows you to grant, suspend, and revoke access to all systems in your network, but most importantly, cardholder data.

See Also: What is the Separation of Duties Principle and How Is It Implemented?

An RBAC approach allows system administrators to create unique usernames and passwords for each individual within the company. It helps develop a way of tracking who, what, where, and when a system is accessed.

Remember, usernames and passwords should never be shared or used for group purposes so that you can trackback someone in the event of a breach.

PCI DSS Requirement 7 is relatively straightforward and, if properly implemented, can provide the control and visibility system administrators need to manage the network securely.

Who Must Access Your Cardholder Data?

Below is a list of job roles that may need access to sensitive data, but this list may vary based on your business needs:

  • Accountants
  • IT staff
  • Managers
  • Support employees
  • Call center representatives

User access is for those who need access to systems. The biggest question to ask yourself is how much access each employee needs. The answers you specify as an answer to the question should be addressed in the documentation and approval section of PCI DSS Requirement 7.

What is Role-based Access Control (RBAC)?

From a technological point of view, role-based access control or RBAC limits access to approved network users. Simply put, it means that every employee has some amount of data they can access depending on their position in your company. When using role-based access, employees can only access data and activities as required by their job functions and locations.

See Also: Which Privileged Accounts You Should Manage and Keep Safe

Windows Active Directory is the most popular of RBAC systems. Lightweight Directory Access Protocol or LDAP is a popular Linux application protocol used to communicate with Active Directory.

To configure Active Directory, you must use a hierarchical, top-down approach. The Domain Name will be a top-level domain in an Active Directory environment. Organization Units or OUs can be created under the top-level area such as marketing, operations, finance. Groups and users can be advertised inside OUs.

System administrators often apply group policies, which are specific role-based permissions that govern what a user can do in OUs. Group policies can also be extended to groups and individual users, but OU-level role-based access controls are easier to manage for system administrators.

Why Use a Role-Based Access Control (RBAC) System?

Using a role-based access system to effectively implement the principles of separation of duties and the need to know for PCI DSS compliance will make your job much more comfortable. Here are five reasons to add a role-based access control system to your company.

1. RBAC is a requirement in PCI DSS.

PCI DSS Requirement 7 addresses how companies should limit employees’ access to sensitive data to know. Businesses are expected to provide an access control system according to their responsibilities.

PCI DSS 3.2.1 also includes a defined and updated list of card access roles. The role list means you need an updated list of employees in your company who can access their card information. In short, if you don’t enforce role-based access, you won’t be compatible with PCI DSS.

2. Prevents social engineering attacks.

If anyone has access to credit card information, it’s reasonably easy for a hacker to steal credentials from an employee and access all data. Restricting access to card data makes it difficult for hackers and makes it less likely for attackers to target your organization.

A hacker might find a way to steal credentials from someone with approved access to the data, but with role-based access control, it will need more effort.

3. Keeps data safe from attacks via remote access.

One of the main ways hackers steal card data is through unsecured remote access software. It is better to restrict only those who have remote access to the information they can access. This way, it will help keep your data safe from hackers.

While remote access software is useful, it can easily cause a data breach if you don’t protect it adequately. Here are some ways of ensuring that your remote access software is secure:

  • Apply multi-factor authentication
  • Use unique usernames and passwords
  • Run vulnerability scans
  • Limit login attempts

While this will not protect you from all the social engineering attacks, it will help discourage attackers.

4. Reduces data attacks.

The fewer people access your card data; the fewer opportunities hackers will have to access your card data system. Limiting access is just one way to ensure that data is not available to attackers.

Note that limiting access alone will not keep data safe from cyberattacks. Other measures that can be taken include:

  • Segmentation of networks: Keeping networks separate help reduce potential data breaches.
  • Using antivirus software and keeping it updated: Anti-virus can help detect and get rid of the malware.
  • Configuring firewalls: Many organizations do not configure firewalls correctly. You must make sure that your firewall is patched and working correctly.
  • Regular updating and patching of software: No software is foolproof and frequent patching of weak software spots is critical.

5. It prevents misunderstandings and regulates accountability.

Limiting access to employees on a responsible basis helps ensure transparency of an employee’s duties. In this way, it will also help your business to be more efficient. Properly restricting access means you don’t mix or share roles.

Confusion occurs when employees’ roles are unclear. Using role-based access, you can clarify your employees’ roles, what they need, and what information they need access to.

What Are The Ways To Integrate Role-Based Access System?

Companies don’t use access based on roles because they believe it is challenging to integrate. Here are some tips for implementing role-based access to your company effectively and efficiently:

Businesses need to determine if an employee moves from one department to another if that employee’s previous RBAC approvals are required for the new position. Otherwise, these permissions must be revoked.

By adopting role-based access in your company, you provide an extra layer of security to you and your customers. Keep your employees on a know-to-know basis and make sure no one can access your data.

The primary ways to integrate the Role-Based Access System in your company are as follows:

Document Your Access List.

Restricting access on-demand is only part of PCI DSS Requirement 7. All employees allowed to access the network must be authorized and documented by authorized employees. For example, you must document:

  • Employee’s name
  • Employee’s username
  • RBAC Group or Role
  • User Type
  • Managing the Supervisor’s Signature
  • Approval of the Manager

This documentation and approval application helps system administrators, supervisors, and administrators monitor which users can access specific systems and the permissions granted. These documents need to be modified to reflect the new RBAC roles and permissions as users move around the business.

Manage your access policies.

It needs you to think carefully about who in your business has access to system components and the effect that access has on the security of your cardholder’s data environment. Managing your access policies is even more complicated if you have multiple branches or data centers or if you store any of your data using cloud-based service providers.

You need to manage your access control policies at a relatively granular level, carefully define your organization’s specific user roles, and determine which parts of your network and data you can access.

In practice, you need to have adequate controls to create a realistic and efficient access control strategy. Therefore, you should take enough time to develop the best system to meet your needs.

Assign access privileges “with least privileges.”

You must extend and apply the least access privilege to all user accounts documented and accepted access requests. This is because you only give sufficient access to certain parts of the device or data they need to perform their business functions. For example, an administrator can create an access policy for another user to view cardholder data but cannot read the data directly on himself.

Depending on your environment and the way you do business, you may need to consider different device types and different access levels for use and management at the network, server, and application level. This role will be challenging, for example, when you need to grant special access rights to your databases to various types of users.

By default, it’s best to disable access to data and then allow only those required. This approach supports the avoidance of grant access errors that could lead to data breaches.

Canceling data access

If the user has a change of position, report the change and change the user’s rights as needed. Similarly, you must disable or delete the user account according to your company’s policies and procedures when a user leaves your company.

A straightforward process established will help manage privileges well. Besides, it is recommended that you regularly run and analyze queries on user accounts to check account activity. For example, you can run a scheduled script quarterly to analyze accounts and their privileges.

Additional Tips for Complying with PCI DSS Requirement 7

Below are a few additional tips on compliance with PCI DSS requirement 7:

Assign access levels to employees as needed: If possible, create a chart of the various jobs that require the most work with card data. Your accountant will need more access rights than the concierge, for example.

Provide regular training for employees: Employees must understand the extent of access they have and what others are doing. The tutorials help prevent social engineers from using stolen credentials to steal card data.

Document everything: Documenting which employees have access, how much information they have access to, and whether new employees have been introduced is the best way to avoid misunderstandings. Remember to update these records periodically.

  • Check the RBAC solution regularly for inactive users and then permanently disable or remove the designated users.
  • Periodically call users with unnecessary permissions and revoke them during the RBAC system check.
  • Create unique usernames and passwords to provide individual credentials for each employee.
  • Do not use group or shared usernames and passwords.
  • Educate employees on the limited access policy. Keep staff up-to-date on changes by providing ongoing security awareness training.
  • Consult a PCI QSA to help determine where you need to concentrate.
  • Harden your firewall correctly and configure it to secure your RBAC platform from attacks.
Surkay Baykara
Surkay Baykarahttps://www.pcidssguide.com
A passionate Senior Information Security Consultant working at Cyberwise. Over the past 15+ years my professional career has included several positions beginning as a developer and IT administrator, working my way up to a senior Technical Performance Consultant before joining Biznet back in 2015. I had several different roles at Cyberwise, including Penetration Tester and PCI DSS QSA. In my job as a QSA, I found my passion and worked closely with the Audit and Compliance team. I've been working inside InfoSec for over 15 years, coming from a highly technical background. I have earned several certifications during my professional career including; CEH, CISA, CISSP, and PCI QSA.

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