Incident response plans are crucial to PCI compliance. PCI Requirement 12.5.3 requires that you have an individual assigned to establish, document, and distribute security incident response and escalation procedures to ensure timely and effective handling of all situations. Without this role, incident response programs could be completely ineffective and security incidents could lead to great damage.
For this role, it’s important that organizations develop transition and/or succession plans to avoid potential gaps in this security assignment, which could result in responsibilities not being assigned and therefore not performed.
PCI Requirement 12.5.3 establishes the need to assign the roles and responsibilities around distributing your security incident response procedures and all of that relative training. Your assessor is going to be looking for who that role has been assigned to.
Someone to Monitor and Analyze Security Alerts
In PCI Requirement 10, we discussed a critical aspect of data protection: logging and tracking. Implementing logging mechanisms at your organization gives you the ability to track user activities, which is crucial in preventing, detecting, and minimizing the consequences of a data breach. Without logging and tracking, it’s almost impossible to find the source of the data breach or compromise. In PCI Requirement 12.5.2, we take this a step further; it’s not sufficient just to have logging and alert systems in place. PCI Requirement 12.5.2 asks you to establish a role to monitor and analyze security alerts and information, and distribute appropriate personnel.
For this role, it’s important that organizations develop transition and/or succession plans to avoid potential gaps in this security assignment, which could result in responsibilities not being assigned and therefore not performed.
Back in PCI Requirement 10, we talked about having all the logging and log review programs established. PCI Requirement 12.5.2 establishes the need to define the roles and responsibilities and assign someone to manage and monitor the log review and all those other things. Once again, it’s not sufficient to just have a logging program, somebody needs to actually mange that and be actively part of that program.
Someone to Establish, Document, and Distribute Security Policies and Procedures
Building a PCI compliance program takes teamwork, and according to PCI Requirement 12.5.1, someone must establish, document, and distribute security policies and procedures. This role is crucial because formal documentation, implementation, and maintenance is required. By assigning someone this responsibility, you ensure that security policies will be held up to PCI standards.
For this role, it’s important that organizations develop transition and/or succession plans to avoid potential gaps in this security assignment, which could result in responsibilities not being assigned and therefore not performed.
We need to have somebody that’s formally responsible for developing policies, distributing them, and managing them. It’s not just good enough to develop the policies, we actually need somebody to manage them. From an assessment perspective, we’re looking to define who that physically is.
Assigning Information Security Management Responsibilities
Building a PCI compliance program takes teamwork. PCI Requirement 12.5 recognizes this and requires that you assign an individual or team to the following information security management responsibilities:
Establish, document, and distribute security policies and procedures
Monitor and analyze security alerts and information, and distribute to appropriate personnel
Establish, document, and distribute security incident response and escalation procedures to ensure timely and effective handling of all situations
Administer user accounts, including additions, deletions, and modifications
Monitor and control all access to data
Anyone with information security management responsibilities should be aware of their tasks through a specific policy. Without this accountability, gaps in processes may present risks to critical resources or cardholder data.
To verify compliance with PCI Requirement 12.5, an assessor will look for a formal Chief Security Officer (or other roles like this) and check for other formally assigned information security roles.
It’s not just enough, from an organizational perspective, that you establish all of these programs. You also need to define who is going to be responsible for managing these things. PCI Requirement 12.5 looks to call out very specific things around assigning the roles and responsibilities. From an assessment perspective, we’re not only looking that you have this documented, but we’re looking to see that these activities are actually fully managed.
Tone from the Top
PCI Requirement 12.4.1 is a sub-requirement of PCI Requirement 12 and applies to service providers only. It requires that executive management shall establish responsibility for the protection of cardholder data and a PCI DSS compliance program, which includes overall accountability for maintaining PCI compliance and defining a charter for a PCI DSS compliance program and communication to executive management.
PCI Requirement 12.4.1 is vital for a “tone from the top” attitude. The PCI DSS guidance says, “Executive management assignment of PCI DSS compliance responsibilities ensures executive-level visibility into the PCI DSS compliance program and allows for the opportunity to ask appropriate questions to determine the effectiveness of the program and influence strategic priorities.” Executive management could include your board of directors, C-level positions, investors, or other stakeholders.
To verify compliance with PCI Requirement 12.4.1, an assessor will examine documentation to see that executive management has some accountability assignment and review the PCI charter.
PCI Requirement 12.4.1 requires that service providers define and appoint somebody within your organization the overall responsibility for managing the security of the PCI DSS. What we’re looking for is that you have a formal charter that defines what that looks like. We’re looking for the actual individual to interview them and to talk to them about the charter and how they go about managing those responsibilities for PCI DSS.
We know that PCI DSS compliance can be intimidating, so we’ve provided this PCI DSS charter document template to help you comply with PCI Requirement 12.4.1.
PCI DSS Charter Document Template
Purpose:
The purpose of this charter is to establish the policies and procedures for complying with the Payment Card Industry Data Security Standard (PCI DSS). This charter defines the roles and responsibilities of employees and management in maintaining the confidentiality, integrity, and availability of cardholder data.
Scope:
This charter applies to all employees, contractors, and vendors who handle or have access to cardholder data in the organization’s systems or network. The scope of the PCI DSS compliance program covers all payment channels, including point-of-sale (POS), e-commerce, and mail order/telephone order (MOTO).
Roles and Responsibilities:
The following roles and responsibilities are defined for PCI DSS compliance:
Executive Sponsor: The executive sponsor is responsible for providing the necessary resources and support for the PCI DSS compliance program. The executive sponsor is also responsible for ensuring that the compliance program aligns with the organization’s overall security strategy and objectives.
Compliance Officer: The compliance officer is responsible for overseeing the PCI DSS compliance program, including managing the compliance project, conducting risk assessments, developing policies and procedures, and coordinating with internal and external auditors.
Security Officer: The security officer is responsible for ensuring the security of the organization’s systems and network, including implementing and maintaining technical security controls to protect cardholder data.
IT Operations: The IT operations team is responsible for implementing and maintaining the organization’s systems and network, including applying security patches and updates, monitoring systems for security incidents, and ensuring the availability of systems and network.
Business Units: Business units are responsible for ensuring that the systems and processes they use for handling cardholder data are compliant with the PCI DSS requirements.
PCI DSS Compliance Program:
The PCI DSS compliance program consists of the following elements:
Risk Assessment: The organization will conduct a risk assessment to identify the risks to cardholder data and the systems and processes that handle cardholder data.
Policies and Procedures: The organization will develop and implement policies and procedures that comply with the PCI DSS requirements.
Technical Controls: The organization will implement and maintain technical security controls to protect cardholder data, including firewalls, encryption, and access controls.
Security Monitoring: The organization will monitor its systems and network for security incidents and take appropriate action to address any security issues that arise.
Training and Awareness: The organization will provide training and awareness programs to employees, contractors, and vendors who handle cardholder data to ensure they understand their roles and responsibilities for protecting cardholder data.
Compliance Reporting:
The compliance officer will provide regular reports to executive management on the status of the PCI DSS compliance program, including the results of the risk assessment, progress in implementing policies and procedures, and any security incidents that occur.
Conclusion:
This PCI DSS charter document outlines the organization’s approach to achieving and maintaining compliance with the PCI DSS requirements. By following this charter, the organization can protect the confidentiality, integrity, and availability of cardholder data and ensure the trust of its customers and partners.
Still have questions about PCI DSS?
Do you still have questions about PCI Requirement 12.4.1, charter documentation, or just PCI DSS in general? We’ve got you covered. Here at KirkpatrickPrice, we want to partner with you for all of your PCI needs.
