Why is it so hard to figure out the scope of a PCI compliance assessment? Seems straightforward enough, right? In the Payment Card Industry Data Security Standard (PCI DSS), the PCI Security Standards Council has defined and redefined scope for everyone, but many companies still don’t understand how best to determine the range of what is covered by the assessment. One reason it is so difficult is that no two networks, Web applications, or point-of-sale (POS) systems operate and communicate in the same manner. When you put people into the mix of process and communication, defining what is in scope becomes even more of a wild card.
So, let’s break down the scope of a PCI compliance assessment by defining some terms – and in the process identify the areas that should be in the scope but often are unknown, forgotten, or simply ignored.
Cardholder data is the data on any payment card (credit, debit, gift card, flexible spending, prepaid, and others) that has a Visa, MasterCard, Discover, American Express, or JCB logo on it. “Cardholder data” in general refers mainly to the primary account number (PAN), but when paired with the account number, any of this information also becomes “cardholder data”:
Bear in mind that any card, whether past its expiration date or not, is considered “live” or “active” unless the card issuer has confirmed that the card has been canceled. So new, old, and archived cardholder data are all in scope. Just ask T.J. Maxx, which found out the hard way.1
Keeping the definition of cardholder data in mind, let’s move on to the cardholder data environment (CDE), which is the environment on which a PCI compliance assessment should be focused. In other words, the CDE is equivalent to the scope of the assessment.
So, yes, as the council states, the CDE is all the components – vendors, people, and processes – of all the systems that store, process, and transmit cardholder data.
But the CDE also includes all systems that are connected to those systems or that can otherwise affect the security of cardholder data. These are not just the systems that are known to be storing cardholder data. Neither is the CDE just the virtual local area network (LAN), where all the systems that store, process, and transmit cardholder data are physically placed. It is all that but much more.
You have to consider all of the systems, including the POS system (I know I shouldn’t have to say that, but trust me the POS system often is ignored), that are connected to the environment you consider in scope. These connected systems might include management systems such as anti-virus consoles, patch management servers, access management systems, and central logging servers.
Equally as important as the management systems are nontransactional systems that can communicate with the CDE without passing along cardholder data. These systems may include reporting servers, which pull inventory data but have nothing to do with cardholder information. Because the nontransactional systems communicate with systems in the CDE, it could be possible for the nontransactional systems to affect the security of the systems that handle cardholder data. Therefore, nontransactional systems should be considered when determining the PCI compliance assessment scope.
Just as the CDE includes all systems connected to the systems in scope, the CDE includes all the vendors, people, and processes that interact with any connected systems that are storing, processing, and transmitting cardholder data. Vendors, for example, may extend the network that you should include in scope while assessing PCI compliance. An HVAC vendor that monitors heating and cooling on your network may open a hole to the outside world that you haven’t considered before.
The CDE also includes all the ancillary systems employees use to send or store cardholder data for future use or record-keeping. These may include systems such as fax servers, email networks, networked file shares, hard drives, and free-form text boxes in customer relationship management applications where employees enter notes about a client. Even office vending machines that accept credit cards may sit on the network. In short, the CDE extends to lots of places you wouldn’t expect it to.
So to determine the scope of a PCI compliance assessment, you have to go on a cardholder data hunt. Talk to the people who are handling payments, follow the bread crumbs to ancillary systems, and really understand where the cardholder data is. If you don’t know where it is, then you can’t secure it; if you can’t secure it, your organization is probably out of compliance – and putting data at risk.
In accordance with applicable professional standards, some firm services may not be available to attest clients.
© 2018 Crowe Horwath LLP, an independent member of Crowe Horwath International.
As of June 1, 2016, the professionals of AbleBridge have joined Crowe Horwath LLP, a public accounting, consulting, and technology firm. We continue our focus on Microsoft Dynamics® CRM (now Dynamics 365) sales and implementation as well as innovative add-on products.
The personnel of SDGblue have joined Crowe Horwath LLP, a public accounting, consulting, and technology firm with a global risk consulting practice and offices around the world. This move provides SDGblue clients access to a broader range of products, services, and solutions, while expanding the Crowe cybersecurity risk management capabilities with a deeply specialized team.
Looking for the Client Login?
Access the SDGblue Client Portal
As of Oct. 30, 2017, the professionals of Rowbotham International have joined Crowe Horwath LLP, a public accounting, consulting, and technology firm. We continue our focus on domestic and international tax and audit compliance services, as well as advisory services.