PCI

Performing PCI QSA assessments is critical to maintaining security that will meet PCI standards and DSS requirements.

A gap assessment provides a clear understanding of where to prioritize your limited cybersecurity resources. You may not be aware that your organization’s existing security program, architecture, selected technologies, and 3rd party solutions may present obstacles to achieving certification. The gap assessment will identify roadblocks allowing you to make the necessary changes early-on, thus avoiding costly mistakes as you move through the PCI DSS compliance process with an authorized QSA company. Additionally, the gap assessment:

  • Provides an overview of the PCI QSA’s assessment process and includes a cost-effective framework to quickly identify the gaps in your organization’s cybersecurity program as they relate to account data and PCI DSS compliance.
  • Identifies the selected or required path (ROC or applicable SAQ) to ensure the necessary practices and processes are implemented or planned with your organization.
  • Reviews your organization’s boundary to ensure proper PCI DSS compliance and segregation implementation if any.
  • Identifies potential controls issues that may impact your PCI DSS compliance.
  • Prepares your organization for a PCI DSS assessment with an authorized QSA company.

Understanding the requirements needed to protect account data in storage, transit, and processing is critical to developing a robust security program. Findings from the gap assessment will allow your organization to prioritize areas of your cybersecurity program that may lack the required maturity level practices and processes. When developing your program for PCI DSS compliance, you must:

  • Align your organization’s cybersecurity program to the PCI DSS 4.0.1 security domains, capabilities, practices, and processes
  • Ensure organizational security policies and procedures are updated and aligned to PCI DSS 4.0.1 requirements
  • Address threat and risk management areas to include insider threat, 3rd party risk, and supply chain risk management at a minimum
  • Develop the necessary security documentation and plans
  • Implement the required security safeguards, controls, and practices in coordination with the development of required security documentation

Once your organization has built a program that includes the implementation of the domains, requirements, standards, capabilities, practices, and processes that align to your required ROC or SAQ, your organization should now focus on achieving PCI DSS compliance. The PCI DSS assessment must be conducted by a PCI QSA company to ensure PCI and requesting entity report acceptance. To prepare for this assessment:

  • Select a PCI QSA company that has proven experience in assessing environments and understands other regulatory frameworks.
  • Ensure the PCI QSA company provides a detailed project schedule and cost estimate that outlines the scope of the assessment.
  • Designate a project manager to interface and serve as the liaison for the PCI QSA.
  • Plan for assessment findings and ensure the necessary resources are available to remediate any findings identified by the PCI QSA company.  Please note that ROC or SAQ requirements must be fully met to achieve PCI DSS compliance

Business Considerations

Management Buy-in and Leadership is Critical

Achieving certification will require your organization’s time, money, people, and resources. Ensure that the company leadership champions the program and has oversight of all certification activities. Without management involvement, cybersecurity programs lack the ability to align cybersecurity to business objectives and the underlying risks to the organization.

Planning is Essential

Ensuring your cybersecurity program is robust, yet adaptable, is critical to today’s regulatory compliance and emerging threats. Developing a clear roadmap will avoid costly mistakes as your organization works to achieve certification. Activities such as gap assessments have the potential to save your organization from many of the costly mistakes that other government contractors have made.

Develop a Realistic Budget to Achieve and Maintain Certification

The size and complexity of your organization will impact the costs associated with maintaining an effective cybersecurity program. Ensure regulatory compliance and risk management are included in financial budgets, and plan for increased costs during the initial certification. Additionally, ensure your budget aligns to any changes or growth in your overall IT architecture, migration, and transformation strategy.

Experience Matters - Advisor and Assessment Organizations are Not Equal

Select a PCI SSC-authorized QSA company with experienced advisors and assessors who understand the complexity of regulatory compliance and have the experience and ability to map and leverage other regulatory frameworks, such as FISMA, FedRAMP, ISO, SOC, etc. to provide unique and cost-effective solutions. Vet all QSA companies to ensure you’re getting the right team to support your cybersecurity goals.

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