PCI compliance doesn’t happen by mistake. To follow the framework’s strict risk management standards and data security best practices, organizations must have effective policies, processes, and controls. Not surprisingly, all 12 PCI DSS core standards in version 4.0 require that “roles and responsibilities for performing activities” in each section be “documented, assigned, and understood.” In other words, successfully implementing PCI DSS roles and responsibilities is the only path to compliance.
Is There a Specific List of PCI DSS Roles and Responsibilities?
PCI DSS applies to companies of different sizes and in many different industries. No single set of “standard” roles would fit the circumstances of such a large group. Depending on your operations, PCI DSS compliance can overlap:
- Network engineering and infrastructure management
- IT and network security roles
- Application security and software development teams
- Finance department roles
- Cloud computing and database security
- Access control management, including physical security teams
Many enterprises have a broad scope of PCI DSS responsibilities, such as Fintech firms, SaaS developers, and cloud hosting companies. The PCI DSS framework is effective because it adapts to the needs and circumstances of organizations that handle cardholder data.
To become PCI compliant, your organization must have policies that cover its unique scope of risk, privacy, and cybersecurity controls involving cardholder data. Roles ensure that someone is in charge of implementing, maintaining, managing, and adjusting your PCI compliance framework as needed.
What Are the Most Important PCI DSS Roles and Responsibilities?
The roles required for PCI compliance depend on the size of your organization, the type of cardholder data it stores, its total transaction volume, and the complexity of its data processing. Large enterprises may have a full PCI compliance team with representatives from IT, finance, legal, and risk management departments. Other organizations assign specific PCI DSS responsibilities to experienced leaders in each department.
1. PCI Compliance Management
One of the biggest changes with PCI DSS version 4.0 is the emphasis on oversight for framework requirements. During a PCI audit, it’s no longer enough to show that you have acceptable policies. To comply with the “X.1.2” section of each requirement, you must provide a detailed list of individuals or roles that are managing the respective controls.
The PCI compliance management role is above everything else. This position is in charge of developing, monitoring, evaluating, auditing, and adjusting the organization’s overall PCI DSS framework and compliance initiatives. In enterprise-level organizations, a PCI Compliance Committee usually manages these responsibilities.
2. Information Security Management System
Another key role under PCI DSS Requirement 12 is developing a comprehensive information security framework for cardholder data management. An ISMS needs clear policies and processes for data security, endpoint device management, risk management, security awareness training, and vendor management. This is an organization-level responsibility.
3. Network Security Management
To be PCI compliant, you must assign an officer or team to manage controls for network security, including firewalls, platform configuration, advanced encryption, and network monitoring. Even the design of network hardware, software, communication protocols, and ports is involved in security.
Many roles are usually necessary to manage this area, from network engineers to system administrators. Many organizations use a network security team led by the CTO or CISO.
4. Cardholder Data Security Management
Technology safeguards are only one line of defense in infosec. The way personnel handle cardholder data must also comply with PCI DSS best practices. Linked responsibilities include:
- Managing your company’s data retention policy
- Making sure sensitive authentication data isn’t being stored after confirmation
- Ensuring primary account numbers are properly masked and encrypted at rest and in transit
- Verifying encryption standards, tokenization, and hashing processes
- Configuring secure network transmission protocols for PAN, such as TLS
This area of PCI compliance requires significant technical expertise, cybersecurity experience, and knowledge of financial regulations.
5. Vulnerability Management and Testing
Most cyberattacks are financially motivated (~90%), with more than 65% involving bad actors associated with organized crime. Payment card data and the institutions that store it are prime targets, with more than 3,300 attacks against financial organizations in 2024. Regularly testing network security and eliminating vulnerabilities is vital.
Vulnerability management responsibilities include:
- Deploying and configuring anti-malware systems and continuous monitoring software
- Applying and managing security patches
- Conducting periodic cyber risk and vulnerability assessments
- Coordinating network security scans
- Performing in-house security audits
- Schedule regular internal and third-party penetration tests
Other responsibilities depend on your company’s PCI DSS level. Smaller processors must choose an Approved Scanning Vendor, complete an Attestation of Compliance, and submit the correct self-assessment questionnaire. High-volume merchants must work with a Qualified Security Assessor for annual independent audits and submit a Report on Compliance afterward.
6. Compliance Documentation
All PCI DSS activities must have the appropriate logs and documentation to prove compliance. Managing these reports can be a role in itself. To make the process more efficient, many organizations use a workflow automation and compliance tracking platform like Compyl. Automating report generation and log storage reduces the risk of errors or miscommunications.
What Is a RACI Matrix for PCI DSS Roles and Responsibilities?
Enterprises often need to implement and manage hundreds of individual controls for PCI DSS. The responsibilities range from overseeing broad systems to tracking compliance at the employee level. To avoid confusion with so many potential PCI DSS roles and responsibilities, you can map a RACI matrix onto your PCI framework:
- Responsible: Who performs the task
- Accountable: Who oversees the responsibility and manages its policies
- Consulted: Who provides input on policy creation (e.g., audit teams or external consultants)
- Informed: Who receives reports (e.g., the PCI compliance team)
Some enterprises use a simplified matrix with just the Responsible and Accountable columns. Be adaptable. You may only need to map RACI to detailed subcontrols when multiple departments are involved with compliance.
Simplify PCI DSS Roles and Responsibilities With Data-Driven Decisions
PCI compliance isn’t about checking off boxes. It’s critical for protecting your organization. To avoid confusion, redundancy, and vulnerabilities, your PCI DSS framework needs centralized data.
Compyl provides deep insights into program compliance. Determine the best way to allocate resources and assign responsibilities based on real-time data. Choose a customized PCI compliance solution. Request a demo today to see how seamless continuous compliance can be.
