The PCI DSS specifies security requirements across many domains, from documentation and physical security to network encryption and software design, all designed to ensure the safe storage, transmission, and use of sensitive cardholder information.
As defined by the PCI Data Security Standard V1.1, “These security requirements apply to all ‘system components.’ System components are defined as any network component, server, or application that is included in or connected to the cardholder data environment. The cardholder data environment is that part of the network that processes cardholder data or sensitive authentication data.”
This definition has indeed caused some heartburn among merchants, as they refer to these standards as too broad in scope — or too narrow in some instances — to actually comply with. In essence, there are 12 requirements and approximately 178 sub requirements to deal with.
Furthermore, organizations are required by credit card companies to comply with all these security requirements or face stiff penalties. Case-in-point: Under the new penalties issued by VISA last year, acquirers will be fined between $5,000 and $25,000 a month for each Level 1 or Level 2 merchant that is not validated PCI compliant by September 30, 2007, and December. 31, 2007, respectively.
However to add a twist, there is also an interesting cavetto to the all-or-nothing approach PCI mandate, found in Appendix B of the PCI Data Security Standard v1.1 requirements called, Compensating Controls. According to PCI Security Council’s Glossary, “Compensating controls may be considered when an entity cannot meet a requirement as explicitly stated, due to legitimate technical or documented business constraints, but has sufficiently mitigated the risk associated with the requirement [3.4] through implementation of other controls.”
Requirement 3.4 deals with the Primary Account Number (PAN), or the payment card number that identifies the issuer and the particular cardholder account. The compensating controls may consist of either a device or combination of devices, applications and controls that meet all of the following conditions:
- Provide additional segmentation
- Provide ability to restrict access to cardholder data based on:
- IP/MAC Address
- Application Service
- User Accounts/Groups
- Data Type
- Restrict logical access to the database
- Prevent/detect common application or database attacks
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