What are the common pitfalls to avoid when implementing PCI DSS standards?

1 Lack of scope definition

One of the first steps to achieve PCI DSS compliance is to define the scope of your cardholder data environment (CDE). This is the network of systems, devices, applications, and people that handle card data or connect to the systems that do. You need to identify and document all the components and processes that are in scope and apply the appropriate PCI DSS controls to them. However, many businesses fail to define their scope accurately or completely, which can lead to gaps in security, missed requirements, or unnecessary costs. To avoid this pitfall, you should perform a thorough scoping exercise, use network segmentation to isolate your CDE from other systems, and review and update your scope regularly.

2 Insufficient staff training

Another common pitfall is not providing adequate training and awareness to your staff who handle or access card data. PCI DSS requires you to educate your employees on the importance of data security, the policies and procedures they need to follow, and the risks and consequences of non-compliance. However, many businesses neglect this aspect of PCI DSS or provide only superficial or outdated training. This can result in human errors, negligence, or malicious actions that can expose card data to unauthorized parties. To avoid this pitfall, you should develop and deliver comprehensive and ongoing training programs, test your staff's knowledge and skills, and foster a culture of security within your organization.

3 Over-reliance on third parties

Another common pitfall is relying too much on third parties, such as service providers, vendors, or consultants, to handle your PCI DSS compliance. While outsourcing some aspects of your card data processing or security can be beneficial and cost-effective, it does not absolve you of your responsibility for PCI DSS compliance. You still need to ensure that your third parties are compliant themselves, that they follow your security policies and procedures, and that they report any incidents or issues to you. However, many businesses fail to do proper due diligence, monitor, or communicate with their third parties, which can result in misalignment, confusion, or breaches. To avoid this pitfall, you should establish clear roles and responsibilities, perform regular audits and assessments, and maintain open and transparent communication with your third parties.

4 Lack of testing and monitoring

Another common pitfall is not testing and monitoring your PCI DSS compliance and security on a regular basis. PCI DSS requires you to perform various tests and checks to verify that your controls are working effectively, that your systems are secure and updated, and that your data is protected. However, many businesses treat PCI DSS compliance as a one-time project or a checkbox exercise, and do not conduct regular or sufficient testing and monitoring. This can result in outdated or ineffective controls, undetected vulnerabilities or threats, or delayed or inadequate responses to incidents. To avoid this pitfall, you should implement a robust testing and monitoring program, use automated tools and alerts, and review and improve your processes and controls continuously.

5 Lack of documentation

Another common pitfall is not documenting your PCI DSS compliance and security activities and evidence. PCI DSS requires you to maintain various records and documents to demonstrate that you have implemented and maintained the required controls, policies, and procedures. However, many businesses do not document their compliance and security efforts adequately or consistently, which can result in gaps in information, confusion, or non-compliance. To avoid this pitfall, you should create and update your documentation regularly, follow the PCI DSS documentation guidance, and store and secure your documents properly.

6 Here’s what else to consider

This is a space to share examples, stories, or insights that don’t fit into any of the previous sections. What else would you like to add?