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PCI Is Not Just For Cardholder Data Anymore

December 8th, 2010

It seems like a no-brainer that you should encrypt your PII (requirement 3). Based on the WikiLeaks fiasco we are all following in the newspapers and online, it is clear somebody also didn’t effectively restrict access to the data. PCI requires that access to cardholder data be restricted to those persons with a business need to know (requirement 7). The same requirement should apply to your PII: The more people who have access to confidential information, the greater the risk that data can be compromised, leaked, lost or stolen.

PCI requires quarterly vulnerability scanning and, in particular, annual penetration testing. In this context I’d suggest making sure your penetration test includes a social engineering element. Your call center or customer helpdesk is a ripe target for voice or E-mail phishing attacks. You spend a lot of time and money training your staff. A good social engineering penetration test can tell you whether or not you are doing a good job. If you don’t do this part every year, at least do it every couple of years. Have a security policy, train your staff and then check to make sure the policy is being followed (requirement 12).

Frank’s comments on the Pentagon and requirement 9 refer to sub-requirement 9.7: “Maintain strict control over the internal or external distribution of any kind of media that contains cardholder data.” I agree completely with him. I also would add that you want to ensure nobody sends unencrypted PII to suppliers, vendors or anybody else, for that matter, by E-mail, fax, interoffice mail or carrier pigeon (requirement 4).

Lastly, consider what you will do if the worst happens and you suffer a data compromise. An incident response plan (requirement 12.9 can be a good guide) will get you through the first difficult hours, when things go off the rails and nobody seems to be able to make a rational decision.

My point is that retailers have an excellent set of data protection best practices, and it is called PCI DSS. It isn’t perfect; it won’t do everything; and it most certainly won’t make you secure. What it can do, though, is go a long way toward making sure you won’t lose the personal data on your best customers, employees, partners, patients, alumni, donors and others.

The time has come to take PCI out of the cardholder data closet and apply at least some of its requirements to protect all your PII.

What do you think? I’d like to hear your thoughts. Either leave a comment or E-mail me at


One Comment | Read PCI Is Not Just For Cardholder Data Anymore

  1. Della Lowe Says:

    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. :-)


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