PCI Compliance on AWS: PCI Requirement 12.3
Supporting PCI Requirement 12.3 in AWS
PCI Requirement 12.3 surrounds usage policies for critical technologies. To be compliant, the PCI DSS stipulates that your usage policies for AWS must require:
- Explicit approval by authorized parties
- Authentication for the use of the technology
- A list of all devices and personnel with access
- A method to accurately and readily determine owner, contact information, and purpose
- Acceptable uses of the technology
- Acceptable network locations for the technologies
- List of company-approved products
- Automatic disconnect of sessions for remote-access technologies after a period of inactivity
- Activation of remote-access technologies for vendors and business partners only when needed
- For personnel accessing cardholder data via remote-access technologies, prohibit the copying, moving, and storage of cardholder data onto local hard drives and removable electronic media
- Protection of the data in accordance with all applicable PCI DSS requirements
AWS says, “Amazon Web Services provides customers the ability to proactively limit the software and technologies in use in their accounts. Customers can use AWS Control Tower with Service Control Policies to manage software deployed in their CDE. AWS Config Managed Rules also offer customers the ability to check for applications not allowed on their AWS Config-managed instances.” Compliance with PCI Requirement 12.3 is a critical part of protecting cardholder data in AWS.
When we are taking a look at the PCI Requirement 12, everyone thinks it is about policies. PCI Requirement 12.3 is about policies, but it is also about how you use your equipment. The personal usage policy in PCI Requirement 12.3 defines (or should define) what can and cannot be installed on systems that are part of the cardholder data environment. This process needs to be formalized. There are things like appropriate approvals for devices to go in, appropriate approvals for changes, and authentication or authorization to actually use the technology and install it. The primary deliverable from PCI Requirement 12.3 is a list of critical devices and those who are authorized to use the devices. That list needs to include the stakeholder or owner, their contact information, the purpose of the device, how it is inventoried, and who is authorized to use it.