It's Okay Not to Be PCI Compliant*

PCI DSS (Payment Card Industry Data Security Standard) compliance is a cornerstone security framework for organizations handling sensitive payment card data. Yet, despite best intentions, even the most security-conscious businesses will find themselves falling out of compliance. Before panic sets in, it's important to understand that non-compliance is not impossible to overcome. It's a challenge that, with the right approach, can be addressed and corrected. So, while we say it's okay not to be PCI compliant, it's important to know that you should always strive to maintain your compliance to minimize your risk, and  develop strategies to return to a compliant state. Below, we discuss three common reasons organizations fall out of compliance and outline the steps you can take to get back on track. 

Why Do Organizations Fall Out of Compliance?

Falling out of PCI compliance rarely  stems from negligence or poor management. More often than not, it is often a result of the fast-paced changing nature of modern, customer focused, and competitive business models. Let's explore three common causes. 

1. New Systems and Technologies

Technology advancements often bring complexity. Organizations implement new systems, whether upgrading their payment infrastructure, migrating to a cloud provider, or integrating with third-party vendors. While these changes are necessary for business growth and efficiency, they can inadvertently introduce gaps in compliance.

For example, you might need to configure a new payment processing system to encrypt cardholder data correctly, or a cloud provider might not adhere to the same security controls as the organization. These oversights can create vulnerabilities that push a business out of compliance.

2. Mergers, Acquisitions, and Expansions

Growth is exciting but can be disruptive to security frameworks. Acquiring a new company, being acquired, or expanding into new markets often involves integrating IT systems. Ensuring that all systems align with PCI DSS standards can be challenging during this process.

For instance, a newly acquired company might use legacy systems that don't meet the current compliance requirements. Integrating these systems into your infrastructure without proper due diligence and planning can create compliance blind spots.

3. Balancing Time, Effort, and Business Needs

Achieving and maintaining PCI compliance takes significant time and effort, which can sometimes conflict with operational demands. Prioritizing day-to-day business activities over security initiatives, especially during busy periods, can cause critical updates or audits to fall by the wayside. 

Additionally, limited resources in smaller organizations may lead to postponed risk assessments, leaving them unknowingly exposed to potential compliance violations. 

We often hear “I had to make a decision to serve our customers.” The balance between customer service or business process convenience vs compliance is a difficult decision for front line workers. It is essential to have the right education and decision path to ensure the right decision is provided. A review of the scenario will ensure your team is able to adapt to evolving conditions and make decisions that do not open the organization to unneeded risk. 

What Happens When You Are Not PCI Compliant?

Falling out of compliance does not immediately equate to a security breach. It can however   increase your risk for breach if not addressed. A compromised environment, while non-compliant, can lead to data breaches, reputational damage, and hefty fines. However, the situation is manageable if addressed and remediated promptly.

Work Your Way Back Into Compliance

A lapse in PCI DSS compliance is a setback. Still, it's also an opportunity to reassess, refine, and strengthen your security posture. Here's how you can get back on track.

Assess the Current State

The first step is to identify the areas where your organization has fallen out of compliance. This involves conducting a comprehensive gap analysis to pinpoint specific issues. For instance:

• Are there misconfigured systems that don’t meet PCI DSS requirements?
• Have new technologies or integrations introduced vulnerabilities?
• Are employees following proper procedures and security protocols?
• Do our current processes meet the demands of the business and security?

A thorough internal or external evaluation will help you understand the scope of the problem and prioritize corrective actions.

Engage Your Partners and Providers

You're not alone in your compliance journey. Reach out to your payment processors, service providers, or Qualified Security Assessors (QSAs) for guidance. These partners can help you:

• Review existing processes and identify gaps.
• Implement necessary updates to regain compliance.
• Develop a roadmap for ongoing security improvements

Providers often have experience in helping businesses navigate compliance challenges. They may be able to provide advice or solutions tailored to your unique situation.

Implement Corrective Actions

Based on your gap analysis, work to address deficiencies systematically. This might include:

• Updating security configurations for new systems.
• Segmenting cardholder data to limit exposure.
• Conducting employee training to reinforce the need for security.
• Modify your business and security practices to address Gaps in customer service and evolving business needs.

Remember that PCI DSS is not a one-size-fits-all framework; you can adapt it to your business needs. Ensure that any corrective actions you take are both practical and sustainable.

Document Everything

Compliance is as much about demonstrating efforts as it is about maintaining security. Keep detailed records of your remediation efforts, including risk assessments, policy updates, and system changes. Proper documentation will help during audits and serve as a reference for future compliance initiatives. Make sure that stakeholders know where to find this documentation when it's needed in the future. 

Establish a Plan for Continuous Operational Compliance

Once you’re back in compliance, focus on maintaining it! This involves:

• Incorporating regular reviews of systems and processes.
• Conducting periodic risk assessments.
• Scheduling ongoing employee training.
• Staying informed about updates to PCI DSS standards.

Integrating compliance into your day-to-day operations to the best of your ability ensures you're proactive rather than reactive to future challenges.

When Falling Out of Compliance Becomes a Growth Opportunity

It's important to recognize that falling out of compliance isn't a failure; it's an opportunity to improve. Compliance lapses often highlight areas of vulnerability that might otherwise go unnoticed. Addressing these gaps can strengthen your overall security posture and reduce the likelihood of future issues.

Demonstrating transparency and a commitment to resolving non-compliance can build trust with your vendors and partners. Being upfront about challenges and showing clear efforts to address them reflects a culture of accountability and responsibility.

Final Thoughts on PCI Compliance

Security framework compliance is a journey, not a destination, and occasional lapses are inevitable. The key is to approach non-compliance with a clear plan and a proactive mindset. By understanding why gaps occur, engaging the right partners, and committing to an operational compliance model, you can navigate compliance challenges and emerge stronger than before.

Remember, it's okay not to be PCI compliant; just not for very long. What matters most is how you define your path back.

*Control Gap is here to help businesses tackle PCI DSS compliance challenges head-on. Reach out to learn how we can guide you through the process and ensure your security framework meets today's standards. Contact our team today.