Businesses are increasingly adopting cloud environments to handle their operations faster than before. The payment industry is also taking advantage of this and shifting its crucial functions to cloud computing services, which introduces them to new challenges in meeting PCI compliance for the cloud due to shared responsibilities.
Whether you use cloud services or on-premise infrastructure for your payment process, you must comply with all PCI requirements. This blog post will focus on effectively using cloud technology for payment infrastructure and cover practical steps to ensure PCI-compliant cloud operations.
What is PCI compliance?
PCI compliance is the Payment Card Industry Data Security Standard (PCI DSS), established by five leading credit card companies: Visa, MasterCard, American Express, and Discover. This standard is issued by the PCI Security Standards Council and applies to all organizations that handle process, or store cardholder information. Compliance with the PCI DSS involves meeting 12 essential requirements that all merchants and payment processors must properly implement to protect cardholder data.
Organizations should periodically review user access rights to maintain PCI DSS compliance. Physical security for cloud environments is also critical.
Although PCI DSS is not a legal requirement, non-compliance can lead to penalties, fines, reputational damage, or blocked payment processes.
Why is PCI DSS compliance important for the cloud?
Cloud computing offers businesses more flexibility, efficiency (cost and performance), and scalability than the on-premise infrastructure. Still, it also brings the concept of joint or shared responsibilities for security and compliance.
While cloud service providers are responsible for handling PCI DSS controls, the customer or tenant is still responsible for monitoring the cloud provider’s compliance with all applicable requirements and compliance with their own shared responsibilities.
In cloud environments, the resources are often shared among customers, which introduces risks such as unauthorised access, data leakage, etc. Following are the key reasons why businesses must ensure that their cloud provider is PCI DSS complainant:
Address shared responsibility: The cloud model clearly defines the roles and responsibilities of both the cloud service provider (CSP) and the tenant (business utilising the cloud service). Thus, each party must take the necessary steps to ensure payment data integrity and meet PCI DSS requirements.
Cardholder data protection: Since the cloud supports a multi-tenant environment, it is important to confirm that a segmented cloud environment exists and is appropriately enforced by the provider to protect data, especially the cardholder data environment.
Business continuity: In traditional on-premise infrastructure, businesses are directly responsible for ensuring all the controls are present to prevent breaches or incidents that could disrupt business operations.
However, in cloud environments, businesses are dependent on their service provider. This is why it is essential to choose a cloud service provider that shows commitment to PCI DSS compliance practices so that businesses can operate smoothly and be resilient against incidents.
What are the key PCI compliance requirements for the cloud?
Whether businesses manage all operations themselves or opt for a cloud environment, the PCI DSS compliance requirements are the same. To become PCI DSS compliant, the cloud platform must follow the PCI DSS guidelines within the shared responsibility model. Cloud providers and businesses must contribute to meeting the standard and play pivotal roles in compliance.
The following are the PCI DSS compliance requirements for the cloud.
Build and maintain a secure network
In IaaS and PaaS models, building and maintaining a secure network is a shared responsibility between cloud service providers and businesses, whereas in SaaS, the CSP is solely responsible. Network security must be taken seriously to meet the PCI DSS compliance requirement. All the networks must be well segmented, and the firewall must be securely configured to allow necessary connections.
Also, no vendor-supplied defaults, such as passwords or other security parameters, must be used and changed immediately upon use to prevent unauthorised access to cloud infrastructure.
Protect cardholder data
In IaaS and PaaS, protecting stored cardholder data is a shared responsibility between CSP and business, whereas in SaaS, the CSP is responsible. However, industry-standard data encryption protocols need to be implemented to prevent unauthorised access during transmission over public networks to ensure the same cardholder data remains protected in transmission and at rest. For this, the responsibilities vary by cloud model:
- IaaS: The customer is entirely responsible for protecting data at rest and in transit.
- SaaS: The CSP is responsible for encryption and secure data storage and transmission.
- PaaS: Data protection is a shared responsibility, with the CSP and customer each implementing specific security measures.
Maintain a vulnerability management program
Developing and maintaining secure systems and applications is important to fulfil PCI compliance for the cloud and is considered a shared responsibility among the CSP and business. Antivirus, anti-malware solutions, and a strong vulnerability management program play a critical role in identifying and remediating security risks. Since the cloud model operates on different levels, the responsibilities vary:
- IaaS: It is entirely the customer’s responsibility to install anti-virus and malware solutions and manage the vulnerability themselves.
- PaaS: Both customers and CSP are required to do their due diligence to ensure security
- SaaS: The CSP is entirely responsible for securing the customer environment from all such security risks.
Implement strong access control measures
The key requirement for obtaining PCI compliance in the cloud is to limit access to cardholder data. A strong authentication mechanism must be used to grant access to system components based on legitimate business needs.
The business and CSP share responsibility for ensuring multi-factor authentication and regularly reviewing all permissions policies to prevent unauthorised access.
Lastly, in all cloud environments, the cloud service providers have the physical infrastructure, and therefore, it is their sole responsibility to restrict physical access to cardholder data.
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Regularly monitor and test networks
This requirement entirely focuses on monitoring and securing the network, which is only possible if both the CSP and the business (i.e., the customer) perform their due diligence and joint efforts to track suspicious activities or any unauthorised access.
They should also periodically conduct vulnerability assessments and penetration testing to assess the effectiveness of all implemented security controls in the cloud environment, ensuring compliance and protecting cardholder data.
In both IaaS and PaaS, it is a shared responsibility, whereas, in SaaS, the cloud service providers are solely responsible.
Maintain an information security policy
The last shared responsibility between business and CSP is to develop and maintain a comprehensive information security policy. The policy should cover all processes to handle and manage security-related rules, acceptable technology use, data storage, data flow, personnel, and stakeholder responsibilities.
To ensure PCI DSS compliance requirements are met, security awareness training must be conducted, and information security policy must be reviewed regularly to validate the PCI scope.
How to implement PCI DSS compliance for the cloud?
Phase 1: Choose the right cloud service providers
To achieve cloud compliance, you must understand your cardholder data environment and choose the right cloud service model accordingly. Opt for service providers with valid PCI-DSS compliance attestation. In addition, ensure that they offer strong encryption, data segregation, secure access controls, activity logging, incident response capabilities, and segregation to reduce your PCI scope.
This should not end here. When selecting the service provider, you must understand the shared responsibilities you must fulfil to meet the compliance requirement.
Phase 2: Define roles and responsibilities
With shared responsibilities in the cloud, you need to manage application security, access controls, and other functions in your scope based on the cloud model, such as SaaS or PaaS. Clearly defining roles and responsibilities requires establishing a team to manage and oversee cloud operations and PCI DSS compliance.
The team can be large or small, depending on the workload and skill set. It should include cloud security officers, compliance officers, DevOps, and others. All team members must collaborate to address all PCI DSS requirements.
Phase 3: Configure cloud security controls
The team should collaborate and implement all PCI DSS controls regarding the cloud computing environment at this stage. To prevent unauthorised access, implement an identity and access management mechanism to limit access based on job duties, enable multi-factor authentication, and refrain from using default or weak credentials.
According to Google Cloud’s Threat Horizons Report, 75% of network intrusions in 2024 were caused by weak credentials and misconfigurations. Therefore, it is necessary to avoid using weak credentials and securely configure the cloud environment.
All the cardholder data should be encrypted at rest and during transmission with strong protocols such as TLS to protect data as it moves within or outside the cloud. In addition, firewalls should be securely configured to block unnecessary traffic; the logging feature must be enabled to log activities for every critical system interacting with cardholder data. To enhance the security, integrate it with a Security Information and Event Management (SIEM) solution to detect anomalies immediately.
Phase 4: Conduct regular testing and monitoring
Once all the security controls are securely configured, the entities must conduct vulnerability assessments, cloud audits, and other relevant security testing to validate the effectiveness of security countermeasures.
Also, the effectiveness of monitoring systems must be tested to ensure that all unauthorised or malicious activities are reported promptly and immediately responded to.
Phase 5: Maintain documentation and compliance reporting
In the final phase, it’s all about keeping track of everything. Document your information security policies, the controls you’ve implemented, and all the steps you’ve taken to ensure compliance. Anytime you make changes or add new measures, update your documentation accordingly.
This meticulous documentation is crucial not only for audits but also as a testament to your commitment to upholding PCI DSS requirements. The most important thing that should be done to maintain compliance is to regularly review the PCI DSS compliance status and submit the report to the acquiring bank or payment brand.
Best practices to make sure your cloud is PCI DSS compliant
Tip 1: PCI-Compliant cloud services
Always choose a cloud service provider that is PCI DSS compliant and is transparent about the shared responsibility. In addition to it, check the CSP reputation and data breach record because recent attacks, like those by Evasive Panda, highlight the need for cloud services with minimal breach history.
Tip 2: End-to-end encryption for cardholder data
To ensure data security, use a strong encryption algorithm and periodically rotate the encryption keys through the secure key management system.
Tip 3: Centralised logging and real-time monitoring
Instead of deploying multiple logging and monitoring systems, use a centralised real-time monitoring solution that offers multiple features for threat detection and response, alerts, logs, network security etc.
Tip 4: Regular audits, Compliance training, and awareness
Conduct regular security awareness sessions to ensure your employees stay updated with security threats and know how to protect themselves and the cloud environment. Additionally, conduct regular security testing and audits to identify and promptly remediate gaps.
Tip 5: Access controls and update permissions
Implement role-based access (RBAC) to limit access to sensitive authentication data and stored account data. Review the permissions regularly and remove those no longer needed to achieve compliance in the cloud.
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Working with Qualified Security Assessors (QSAs)
Qualified Security Assessor (QSA) is a certified PCI DSS compliance professional whose validation is essential for level 1 merchants and service providers. QSA performs external audits to validate compliance and helps businesses obtain the Report on Compliance.
Businesses can take the support of QSA to assess their current security posture and implement best practices with their guidance. Engaging a qualified security assessor before the PCI DSS audit can greatly help streamline compliance efforts, especially in cloud environments.
Summary
PCI DSS compliance is not a choice but a mandatory requirement, including entities utilising cloud platforms. They must meet the PCI DSS standard for functions and their specific responsibilities. By following the mentioned structured approach, businesses can easily implement the requirements for cloud compliance, protect cardholder data, and become PCI DSS compliant.
Cyphere helps businesses understand the PCI DSS requirements according to their operations and infrastructure. Contact us today to discuss your cloud security strategy and PCI concerns.
