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.
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.
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.
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.
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.
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.
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.
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:
A thorough internal or external evaluation will help you understand the scope of the problem and prioritize corrective actions.
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:
Providers often have experience in helping businesses navigate compliance challenges. They may be able to provide advice or solutions tailored to your unique situation.
Based on your gap analysis, work to address deficiencies systematically. This might include:
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.
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.
Integrating compliance into your day-to-day operations to the best of your ability ensures you're proactive rather than reactive to future challenges.
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.
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.