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How to achieve PCI compliance in the public cloud


The Payment Card Industry Data Security Standard (PCI DSS) is a globally recognized regulation that protects consumer credit card information from theft and disclosure. It applies to all organizations that store, process, or transmit credit card information—even if it’s just a few transactions each year.

PCI compliance levels

Although PCI DSS applies to all businesses that accept or process payment cards, the requirements vary. For example, if your organization processes more than six million transactions a year, it must adhere to PCI Level 1 compliance modules. If it processes fewer than 20,000, the requirements are less stringent.

A merchant’s PCI level depends on how many card transactions they handle each year:

  • PCI Level 4: Fewer than 20,000 annual transactions
  • PCI Level 3: 20,000 – 1,000,000 annual transactions
  • PCI Level 2: 1,000,000 – 6,000,000 annual transactions
  • PCI Level 1: 6,000,000+ annual transactions

PCI Level 1 compliance requirements

For PCI Level 1 compliance, you need to meet 12 distinct modules and address 200+ individual items within those modules.

  1. Building and maintaining a secure network and systems, including firewalls and server hardening
  2. Changing vendor-supplied default passwords and security parameters
  3. Network segmentation or segregation of PCI data from the rest of your environment
  4. Protecting cardholder data using encryption-at-rest
  5. Encrypting data during transmission across public networks
  6. Quarterly or annual vulnerability scans and regular monitoring and testing of networks
  7. Restricting user access to sensitive data and applications (using principle of least privilege)
  8. Maintaining an Information Security Policy
  9. Controlling access through authentication and identity management
  10. Monitoring and tracking all network access to PCI data
  11. Regularly testing processes and security system
  12. Restricting physical access to PCI data

PCI assessors and solutions

Besides having internal staff certified to conduct PCI audits and network testing, you might need to reach out to a Qualified Security Assessor (QSA) or Approved Scanning Vendor (ASV) for additional assistance.

What is a QSA?

A QSA is a PCI-certified organization that can help you identify and meet compliance conditions. Your QSA performs the following tasks:

  • Determine which modules you need to address
  • Determine how stringent you need to be to meet the requirements
  • Conduct audits and assess compliance over time

What is an ASV?

An ASV is an organization certified by the PCI council, through stringent testing of its own, to scan your perimeter and any cardholder assets. These include any internet-facing assets used to store, process, or transmit credit card information. Your ASV typically runs a quarterly or annual scan, but you can request more scans over time—such as when you’re implementing remediation efforts or trying to correct compliance issues.

Consequences for PCI noncompliance

Achieving compliance is not just about ticking a box. The steps you take along the way can make your business more secure and less vulnerable to attackers. Noncompliance, on the other hand, can result in steep consequences, including the following:

  • Financial penalties: Credit card companies can charge merchants penalties ranging from $5,000 to $100,000 per month.
  • Costly breaches: The average cost of a data breach is $150 per record.
  • Lost revenue: Breaches can bring your business to a standstill, leading to customer churn and lost revenue.
  • Damaged reputation: When customers lose trust in your abilities to protect their personal data or financial information, they often won’t return.
  • Legal action: Data breach lawsuits are becoming an increasingly active and costly threat.

PCI DSS compliance in the public cloud

Simply choosing a PCI-compliant public cloud platform doesn’t automatically make your organization PCI compliant. While your public cloud service provider (CSP) is responsible for the infrastructure and how the environment is used, you’re responsible for your applications that store, process, or transmit payment card data. PCI compliance is a shared responsibility between you and your CSP.

By working closely with your CSP, you can achieve PCI compliant hosting on the public cloud by doing the following tasks:

  • Create and maintain a cybersecurity strategy, including a cloud security policy and control documents.
  • Conduct penetration testing.
  • Institute proactive threat detection and rapid remediation measures, including intelligence, monitoring, intrusion detection, and response.
  • Design, build, manage, and secure solutions across your environments and platforms.
  • Ensure all public cloud architecture components are PCI compliant across all your environments, including production, disaster recovery, development, and test.
  • Implement multi-layered security across global public cloud data centers.
  • Use cloud-native services for networking, identity management, databases, and applications to protect sensitive data.
  • Implement management and access controls, encryption, monitoring, firewalls, and environment and network segregation.

Maintain PCI compliance

It can be challenging to maintain PCI compliance as your organization, network, and infrastructure change—and as your business needs evolve and grow. You must have a CSP that works with you and provides the cloud security expertise you need to answer your questions and solve problems.

Get started with PCI compliance on public cloud

Let our multicloud security and compliance specialists work with you to understand your challenges and goals and build a path to your desired outcomes. Our expertise across public clouds means you can address your PCI compliance needs more efficiently across AWS®, Google Cloud Platform®, and Microsoft® Azure® public clouds. Get started today.

Learn more about how to achieve PCI compliance in the public cloud.

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Zahid Mustafa

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