The Imperative of Continuous PCI DSS Compliance

As we delve into the specific metrics and timeframes essential for maintaining continuous PCI DSS compliance, remember that each requirement represents an opportunity to strengthen your security posture. By diligently adhering to these standards throughout the year, organizations can build a robust defense against payment card fraud and data breaches, safeguarding their reputation, financial stability, and the trust of their customers.

Key Metrics for Year-Round Compliance

Here's a comprehensive reference guide to the key metrics, organized by frequency:

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Prior to Specific Events:

3.3.2 - Encryption of SAD before authorization completion; Prior to authorization

6.2.3 - Review of bespoke and custom software before release; Prior to release

6.5.1 - Change management procedures for production environment; Prior to changes

6.5.2 - Confirmation of PCI DSS requirements after significant changes; Upon completion of changes

6.5.6 - Removal of test data and accounts before production; Before system goes into production

12.7.1 - Personnel screening for CDE access; Prior to hire

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Every 15 Minutes:

8.2.8 - Session timeout and re-authentication; After more than 15 minutes

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Daily Activities:

10.4.1 - Audit log reviews; At least once daily

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Monthly Activities:

6.3.1 - Address critical and high-risk vulnerabilities; Within one month (~30 Days)

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Quarterly Activities (Every 3 Months)

3.2.1 - Verify deletion of stored account data exceeding retention period; At least every 3 months

11.2.1 - Wireless access point testing and identification; At least every 3 months

11.3.1 - Internal vulnerability scans; At least every 3 months

11.3.2 - External vulnerability scans; At least every 3 months

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90-Day Activities:

8.2.6 - Remove or disable inactive user accounts; Within 90 days

8.3.9 - Password changes for single-factor authentication; Every 90 days

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Bi-Annual Activities (Every 6 Months):

1.2.7 - Review configurations of network security controls; At least every 6 months

7.2.4 - Review user accounts and access privileges; At least every 6 months * 11.4.6 -For Service Providers; Penetration testing of segmentation controls; At least every 12 months

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Annual Activities (Every 12 Months)

5.3.4 - Retention of anti-malware logs; At least 12 months

6.2.2 - Software development personnel training; At least every 12 months

6.4.2 - Web Application Firewall or Manual Review; At least every 12 months

9.4.5.1 - Inventory of electronic media with cardholder data; At least every 12 months

10.5.1 - Audit log history retention; At least 12 months

11.4.2 - Internal penetration testing; At least every 12 months (6 Months For Service Providers)

11.4.3 - External penetration testing; At least every 12 months (6 Months For Service Providers)

11.4.5 - Penetration testing of segmentation controls; At least every 12 months

12.1.2 - Review and update information security policy; At least every 12 months

12.3.3 - Review of cryptographic cipher suites and protocols; At least every 12 months

12.3.4 - Review of hardware and software technologies; At least every 12 months

12.5.2 - PCI DSS scope validation; At least every 12 months

* 12.6.2 - Review and update security awareness program; At least every 12 months

12.6.3 - Personnel security awareness training; At least every 12 months

12.10.2 - Review and test incident response plan; At least every 12 months

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Service Provider Specific Requirements:

11.4.6 - Penetration testing of segmentation controls; At least every 6 months

12.4.2 - Review of personnel to follow Policies and Procedures; At least every 3 months

12.5.2.1 - PCI DSS scope validation; At least once every 6 months

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Periodically:

5.2.1 - Evaluation of system components not at risk from malware; Periodically

5.2.3 - Evaluation of system components not at risk for malware; Periodically

5.3.2 - Anti-malware scans or continuous behavioral analysis

8.3.10 - Guidance for service provider customers to change passwords; Periodically (Frequency determined by risk analysis)

9.5.1.2.1 - POI device inspections; Periodically

10.4.2 - Review of logs for non-critical system components; Periodically

12.10.4 - Training for incident response personnel; Periodically

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Other Important Metrics:

8.2.1 - Assign unique ID before system access; Before access is allowed

8.2.2 - Manage shared accounts strictly; When used

8.3.4 - Lockout policy for failed authentication attempts; Not more than 10 attempts; Minimum of 30 minutes

8.3.6 - Password complexity; Minimum of 12 characters & containing alphanumeric

8.3.7 - Password history; Not last 4 used

Effectively Implementing Continuous Compliance

1. Create a Compliance Calendar: Schedule all required activities throughout the year.

2. Leverage Automation: Use tools for continuous monitoring and automated scanning.

3. Conduct Regular Staff Training: Keep your team informed about current threats and their responsibilities.

4. Perform Frequent Risk Assessments: Regularly identify and address new vulnerabilities.

5. Establish a Security-First Culture: Encourage proactive identification and reporting of potential security issues.

Conclusion

PCI DSS compliance is an ongoing process, not a one-time event. By adhering to these metrics and embracing a continuous compliance approach, organizations can significantly enhance their security posture and be better prepared for their annual assessments. Remember, in the realm of data security, vigilance is a daily commitment.