How to Prepare for a PCI DSS Audit Programme in Scotland

Businesses that accept credit card payments must comply with the Payment Card Industry Data Security Standard. For Level 1 merchants and service providers, this requires annual third-party audits as well as network scans performed by approved scanning vendors. The PCI DSS audit framework contains 281 directives that must be observed, with successful compliance revolving around limiting scope.

man working banner network with cyber security overlay on floor

What is the PCI DSS?

The PCI DSS is a set of cybersecurity regulations designed to keep credit card account data safe. Backed by major credit card brands like Visa, MasterCard, Discover, JCB, and American Express, companies that store, process, and transmit credit card data must abide by its rules or face fines.

Security best practices dictate 12 main requirements with over 300 subrequirements that define PCI validation requirements. One important strategy is granularly segmenting the cardholder data environment (CDE) so only necessary systems undergo PCI validation; this reduces compliance costs, operations expenses, and the risk of fraud.

Merchants and service providers need to demonstrate compliance by either being assessed by a qualified third-party assessor or by submitting an AOC with self-assessment questionnaires similar to what would be seen during an audit; both documents will then be evaluated by external auditors for accuracy and consistency.

Requirements of a PCI DSS Audit

An external qualified security assessor (QSA) must conduct a PCI DSS audit to assess your business processes, systems, network, and controls against PCI DSS requirements. They will write a report detailing their analysis and recommendations for compliance; this document is known as a RoC or Report of Compliance and can then be sent directly to your acquiring bank for validation of compliance.

As part of your PCI DSS audit preparations, it is critical that you first scope your cardholder data environment (CDE). Identify and understand all systems that store, process, or transmit cardholder data—from POS terminals to mobile phones—in your CDE and document how the card data flows within it.

Partnership with a QSA can assist your business to complete all specifications necessary for ROCs and SAQs; keeping up-to-date documentation is also key; businesses evolve as systems change or vulnerabilities emerge; these must all be reflected within their documentation.

How to Prepare for a PCI DSS Audit

Preparing for the PCI DSS assessment should be treated like any major event; planning ahead ensures you won’t run into unexpected issues and ensures all policies, procedures, and systems are ready for inspection by your QSA.

Start by mapping all your systems that store, process, or transmit card data. This exercise will enable you to identify and limit the scope of your evaluation.

Stay in regular communication with your QSA throughout the year and arrange quarterly vulnerability scans; this will keep them apprised of system changes while helping you get ahead of audits. The PCI SSC website contains a directory of qualified security assessors to assist you in finding one who operates in your region.

How to Conduct a PCI DSS Audit

At the heart of each PCI audit is an authorised QSA (Qualified Security Assessor), who will conduct an in-depth examination of your card data environment, including network components, systems, and documents, through personnel interviews and sample tests, in order to ascertain your adherence to each of the framework’s 281 directives.

Your first step towards being PCI DSS audit-ready should be creating a prioritised list. This involves documenting existing vulnerabilities, assessing the risk of each vulnerability, and prioritising key issues.

Maintaining updated business policies and card data environments is also of vital importance, particularly as businesses grow and evolve over time. Your QSA will need access to up-to-date documentation during an onsite audit in order to streamline it efficiently and reduce stress levels during audit procedures.