Robust information security is essential to protect electronic payment systems and keep sensitive user data safe. Cybercriminals would love nothing more than to steal credit card information or sensitive identity data. Performing regular PCI audits is one of the best ways for modern businesses to build strong defenses against data breaches. This guide explains what a PCI audit is, what to expect, and how to become PCI compliant cost-effectively.
What Is a PCI Compliance Audit?
In general terms, a PCI audit is an in-depth assessment of how well your organization complies with the PCI Data Security Standard. The PCI DSS framework contains hundreds of controls, grouped into 12 target categories and six objectives:
- Building and Maintaining a Secure Network
- Protecting Cardholder Data
- Maintaining a Vulnerability Management Program
- Implementing Strong Access Control Measures
- Regularly Monitoring and Testing Networks
- Maintaining an Information Security Policy
There are a few different types of PCI audits.
In some cases, an approved audit firm, called a Qualified Security Assessor, reviews your information security systems and certifies compliance. Other businesses are only required to conduct internal PCI audits using a Self-Assessment Questionnaire.
You can also hire an independent auditor to perform a PCI readiness assessment. This less-formal audit shows your current cybersecurity maturity level and highlights any areas for improvement.
What Does a PCI Audit Involve?
What a PCI audit looks like depends mainly on the requirements of your card issuer. Visa, Mastercard, American Express, and other brands all have different tiers for merchants based on annual transaction volume, revenue, risk level, and history of data security.
PCI Audits With a Qualified Security Assessor
PCI compliance audits review your organization’s security policies, practices, controls, and compliance documentation. The exact process can vary, but it generally includes five or six steps.
1. Scoping the Audit
First, the QSA determines the audit’s scope. It varies depending on what type of card data you process, how much you handle, and who has access to it. PCI DSS requirements and audits for payment gateways are much more complex than for e-commerce retailers.
2. Reviewing Your Overall Framework
Many QSAs request a workup of your information security management system. This overview allows you to explain what processes and controls you have in place to meet each of the 12 PCI DSS requirements.
3. Selecting a Sample
Auditors don’t have time to comb through millions of transactions for evidence of compliance. Instead, the QSA selects a sample area to evaluate based on the audit scope. For example, the PCI auditor may focus on the subset of controls related to firewall configuration, Primary Account Number storage practices, or encryption processes.
4. Validating Alternative Controls
It’s common for enterprises to mitigate payment card risks or streamline PCI DSS compliance with technology. For example, your organization can avoid many security issues from PAN storage by using tokenization instead. The QSA must evaluate these solutions for effectiveness.
5. Reviewing Documents
Either before or during the PCI audit, QSAs request copies of specific compliance documentation. This often includes network access logs.
6. Testing and Observing
Many PCI auditors carry out onsite testing of the systems in the assessment’s scope. For example, an audit firm may observe how your employees respond to phishing attempts. Testing can also include trying to access sensitive data or enter restricted areas.
7. Creating the RoC
Following the onsite validation assessment, the QSA prepares an official Report on Compliance. The RoC “certifies” your PCI compliance, outlining the audit’s findings for all relevant PCI DSS requirements. Auditors use “in place” for satisfactory controls, “in place with compensating controls” for effective alternative solutions, and “not in place” for inadequate or missing controls.
Internal Audits With a Self-Assessment Questionnaire
If your organization processes a low-to-moderate number of transactions, you may only need to perform an in-house compliance audit and submit an SAQ. To begin, choose the type of SAQ that applies to your operations.
For example, SAQ A is for businesses that only handle card-not-present transactions with third-party payment processing. SAQ D is more restrictive, and it means you store some cardholder data on your systems or premises.
Next, perform a gap analysis and risk assessment to determine your current PCI compliance level. This should be handled by your compliance board, IT/cybersecurity team, CRO, or CISO.
You also need to conduct periodic vulnerability testing using an Approved Scanning Vendor. ASV tools scan your network for potential security and configuration issues.
Finally, fill out the SAQ and prepare an Attestation of Compliance. This document reports the findings of your internal PCI audit and details your controls.
How Often Are PCI Audits Required?
Whether you’re required to submit a RoC from the QSA firm or conduct internal reviews with an SAQ, PCI compliance needs to be validated annually. Vulnerability scanning reports are necessary every three months.
What Businesses Need a PCI Compliance Audit?
PCI DSS applies to all businesses that process cardholder data or payment card transactions. This includes:
- Online stores and retailers
- B2B merchants
- Issuing and acquiring banks
- Payment gateways
- Apps and SaaS platforms that process payments
- Cloud storage/computing providers
For Visa and Discover, merchants with more than 6 million annual transactions (or those that have suffered a hack) are required to use a QSA for audits. American Express requires external audits for companies that process more than 2.5 million transactions.
Should You Conduct a PCI Readiness Assessment?
Readiness assessments from QSAs can simplify the process of achieving PCI compliance, offering professional guidance and recommendations tailored to your organization. That said, the right solution for your business often depends on factors like audit cost, your current cybersecurity maturity level, and the risk level of your operations. Highly recommended audit firms provide white glove services, but they don’t come cheap.
Redefining PCI Audits for Enterprise Organizations
Compyl is a cutting-edge and cost-effective solution for enterprises with complex PCI compliance needs. Its comprehensive tools improve in-house readiness assessments, ongoing PCI DSS management, and preparation for official validation audits. Streamline PCI compliance with powerful automation, tracking, and data analysis. Contact us to learn more about the PCI audit process for your organization.
