PCI Council Publishes Guidance on Working With Third-party Providers

The Payment Card Industry (PCI) Security Standards Council has published an information supplement to help organizations that want to achieve or maintain PCI DSS compliance and work efficiently with third-party service providers.

Many entities turn to third-parties to store, process and transmit cardholder data, but they must keep in mind that these service providers can impact not only PCI DSS compliance, but also the security of the cardholder data environment. Furthermore, the use of third party services doesn’t exempt and organization from accountability and its obligation to keep cardholder data (CHD) and the cardholder data environment (CDE) secure.

The guidance, developed by a PCI Special Interest Group (SIG) comprised of over 160 organizations, provides recommendations on how to implement a robust third-party assurance program to ensure that payment data and systems entrusted to other companies are maintained in a secure and compliant manner (requirement 12.8), the PCI Security Standards Council said.

The document advises organizations to conduct due diligence and risk assessment to understand how the provided services will meet PCI DSS requirements. Another recommendation refers to the implementation of a consistent process for engaging external service providers, which includes the establishment of a communication plan, setting expectations, and understanding how the services provided by the third party correspond to applicable PCI DSS requirements to determine the potential security impact on the CDE.

While an organizations is ultimately responsible for compliance, it can be useful to develop written  agreements, policies and procedures with third parties to specify their responsibilities and obligations.

An ongoing process through which relationships with service providers are maintained and managed throughout the engagement should be implemented, organizations are advised.

“Knowing the TPSP’s (third-party service provider’s) PCI DSS compliance status helps to provide the organization engaging a TPSP with assurance and awareness about whether the TPSP complies with the applicable requirements for the services provided. If the TPSP offers a variety of services, this knowledge will assist the entity in determining which TPSP services will be in scope for the entity’s PCI DSS assessment,” the document reads.

All of these recommendations are detailed in the 47-page guide published on the website of the PCI Security Standards Council.

“One of the big focus areas in PCI DSS 3.0 is security as a shared responsibility,” said Bob Russo, PCI SSC General Manager. “This guidance is an excellent companion document to the standard in helping merchants and their business partners work together to protect consumers’ valuable payment information.”

Businesses that handle payment card data must become PCI DSS 3.0 compliant by December 31, 2014. PCI DSS 3.0 focuses on security, not compliance, and this represents one of the key challenges, Russo said in a recent interview.

“Compliance does not equal security. There’s too much focus on cramming for the test and not on being a good student year round. We have to change the conversation in the boardroom and all the way down and across our businesses. Security has to be a daily priority, built into business practices, not a one-time effort,” Russo told SecurityWeek.