PCI DSS FAQ Chronicles: Shedding Light on Assessment Scope and Location
PCI DSS compliance often involves dispelling common myths and understanding the nuances of scope and locations in assessments. Misconceptions surrounding the obligations of Qualified Security Assessors (QSAs), the inclusion of work-from-home environments, and the scope of disaster recovery (DR) sites can lead to confusion and uncertainty for organizations striving to maintain compliance. In this comprehensive article, we address these myths head-on, providing clarity based on insights from PCI SSC FAQs.
By debunking these myths and providing answers to key questions, organizations can approach PCI DSS compliance assessments with confidence and precision.
Myth 1: QSAs must be physically present at all client premises during PCI DSS assessments.
There's a common misconception that Qualified Security Assessors (QSAs) are required to be physically present at every client location during PCI DSS assessments.
Some may believe that remote assessment methods are not acceptable.
Answer: While on-site assessments are generally preferred, the PCI SSC acknowledges that certain validation methods can be achieved remotely, provided they are well-documented and deemed reasonable. This approach allows for flexibility while ensuring thorough compliance assessment.
Myth 2: Assessors are required to visit work-from-home environments to validate PCI DSS compliance.
There's a belief that assessors must physically visit work-from-home environments to ensure PCI DSS compliance, assuming that remote work environments pose unique security risks that need to be assessed on-site.
Answer: According to PCI SSC, entities are responsible for implementing controls and processes to ensure compliance in work-from-home environments. Assessors are not mandated to conduct onsite visits to these locations. Instead, entities should have policies and procedures in place to govern how personnel access payment card account data from remote locations.
Myth 3: Entities need to conduct onsite audits of personnel work-from-home environments.
Some entities may believe that onsite audits of work-from-home environments are necessary to validate compliance with PCI DSS requirements, assuming that remote work environments pose inherent security risks that need to be assessed on-site.
Answer: PCI SSC clarifies that entities are not required to conduct onsite audits of personnel work-from-home environments. Instead, entities should focus on implementing controls and processes to ensure compliance in remote work settings. This approach allows for effective compliance management without the need for onsite audits in private residences.
Myth 4: Assessors must retest PCI DSS requirements at TPSP locations, even if the TPSP is already compliant.
There's a misconception that even if a third-party service provider (TPSP) has already been validated as PCI DSS compliant, the entity's assessor is still required to conduct onsite retesting at the TPSP's location. This assumption may stem from a belief that onsite validation is always necessary, regardless of the TPSP's compliance status.
Answer: According to PCI SSC, entities' assessors are not mandated to conduct onsite retesting at TPSP locations if the TPSP has already been validated as PCI DSS compliant. This underscores the importance of relying on the TPSP's validation and focusing assessment efforts on areas specific to the entity's environment and interactions with the TPSP. It also highlights the efficiency gained by leveraging the compliance status of TPSPs to streamline assessment processes.
FAQ 1290
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Refer to the following FAQs for additional insights:
FAQ 1065: How are third-party service providers (TPSPs) expected to demonstrate PCI DSS compliance for TPSP services that meet customers' PCI DSS requirements or may impact the security of a cardholder data environment?
FAQ 1312: How is an entity's PCI DSS compliance impacted by using third-party service providers (TPSPs)?
FAQ 1576: What evidence is a TPSP expected to provide to customers to demonstrate PCI DSS compliance?
Myth 5: All of a company's sites, even those located in other countries, must be included in the company's PCI DSS review.
There's a misconception that all of a company's sites, regardless of their location, must be included in the company's PCI DSS review. This assumption may arise from a lack of clarity regarding the global applicability of PCI DSS and the requirements for assessing sites in different countries.
Answer: According to PCI SSC, the PCI DSS is a global standard applicable to all entities that process, transmit, or store cardholder data, regardless of geographic location. However, each payment brand manages its PCI DSS compliance and enforcement programs independently. Sites in other countries can be eliminated from the scope of the primary assessment only if they are properly segmented from the primary assessed environment. If desired, specific sites/locations can be excluded from the assessment, but this should be noted in the report of compliance. Alternatively, one review can include all sites and system components for all international locations.
Myth 6: Disaster recovery (DR) sites are always in scope for PCI DSS.
There's a misconception that all disaster recovery (DR) sites are automatically in scope for PCI DSS compliance. This assumption may stem from uncertainty about the configuration and usage of DR sites and their potential impact on cardholder data security.
Answer: The scope of PCI DSS for a DR site depends on its configuration and usage. "Hot standby" or "warm standby" approaches, where the DR site contains live or ready-to-use copies of cardholder data environment (CDE) systems, backups of cardholder data, or other components impacting cardholder data security, are in scope for PCI DSS.
Conversely, "cold standby" approaches, where the DR site does not contain any CDE systems or cardholder data and does not connect to the CDE, may be excluded from scope when not in use.
However, if the DR site is activated, the entity must ensure it maintains PCI DSS requirements for the duration of its use and securely deletes cardholder data upon completion. Testing activities involving cardholder data presence at the DR site are also in scope for PCI DSS requirements.
In the realm of PCI DSS compliance, understanding the scope and locations of assessments is paramount for organizations seeking to protect cardholder data and maintain regulatory compliance. By addressing common myths and providing clear answers to frequently asked questions, organizations can navigate the complexities of PCI DSS assessments with confidence.
By staying informed and leveraging guidance from the PCI SSC, organizations can ensure robust security measures and uphold the integrity of their payment card data environments.
In much the same way as #covid19 has had an impact on business operations, quite rightly, the PCI Security Standards Council have responded to meet these changes.