PCI Is Not Just For Cardholder Data Anymore
Written by Walter ConwayA 403 Labs QSA, PCI Columnist Walt Conway has worked in payments and technology for more than 30 years, 10 of them with Visa.
Many readers saw fellow StorefrontBacktalk columnist Frank Hayes’ report on the Pentagon’s problems with WikiLeaks and thought our military has a problem. If you were one of those folks, I’d advise you to think again. It isn’t just the military. All manner of government agencies, universities, hospitals, Internet service providers, telecoms and, yes, even retailers keep personally identifiable information (PII) that the bad guys would love to get. If you doubt me, consider your private label card database.
IT executives know in their hearts that we have lost the battle to control users. Ubiquitous personal smartphones (usually better than the ones companies provide for their employees), social networking, cloud applications and removable media are here to stay. As I’ve noted in the past, business requirements will trump security every time. That means we need to focus on the one thing we can still control: protecting the data.
That is where PCI becomes increasingly valuable. It is a data protection standard. It also goes further by providing a lot of detail on how that protection should be implemented. Which means if you thought PCI was only good for protecting payment card data, then you are missing a golden opportunity to protect all the PII you have stored on your systems. The reason is that, for all its perceived faults, PCI DSS is very prescriptive. Rather than just tell you to protect confidential data (for example, the Health Insurance Portability and Accountability Act, or HIPAA), PCI tells you how to go about that protection.
The need to protect personal data has not been lost on state legislatures. Nearly every state currently has a personal data breach notification law. The type of PII covered can range from the obvious, like payment card data and Social Security Numbers, to drivers license numbers and bank account information. For better or worse (and I think it’s “worse”), some states have even built PCI DSS compliance into their data breach legislation.
I’m not saying you should have a QSA assess every bit of PII you may have on your customers, but there are elements of PCI DSS that you can leverage to improve your security and keep yourself out of the headlines. You are already following PCI DSS to protect your cardholder data, so why not get the most out of your investment?
One example is to restrict any direct access between your PII and the Internet. PCI requirements 1.2 and 1.3 may be a good place to start. Just in case, though, I’d make sure all my antivirus software is current and I have all the latest security patches installed on any system that stores or even accesses my PII (requirements 5 and 6).
-Marc
December 10th, 2010 at 1:56 pm
This article is right on target in so many ways. Retailers should work toward comprehensive data protection and security policies and best practices to enforce them. As you mention, the PCI DSS does give a lot of guidance in this way. The goal should be real protection, however, not just a checkmark because that will not help you or your customers who have their information stolen during the months that go by when you are not scanning for wired or wireless vulnerability – which of course, in my opinion should be done in an automated fashion 24/7. :-)