PCI Is Not Just For Cardholder Data Anymore

A 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).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 [email protected].