Of the roughly 400 separate requirements in the PCI DSS, 46% of them require the review or examination of some form of documentation. From policy, to procedure, to configuration standard to diagram, a very significant chunk of achieving PCI compliance starts with paperwork.
How is it then that in the 10 years I’ve been performing PCI and PCI-esque assessments the ‘paperwork’ is almost invariably the last thing to close? I’ve seen large organisations get centralised logging in place before they managed to get their policies and procedures in order.
In Want REAL Information Security? Start With Your Policies I have already gone into why organisations should take polices and procedures more seriously, so I’m not going to repeat myself. But I will just say now that if you didn’t start your project to formalise your policies and procedures at the beginning of your assessment, stop, go back, and start there. A good QSA will fail you for crap policies just as quickly as they would for lack of encryption on stored card holder data.
All too often the client response to a request for documentation is to provide a handful of polices taken from the internet with the company name changed, but no effort whatsoever to customise the content in line with reality. Procedures are virtually non-existent, everything is in unprotected Word docs, several years old, and in no way standardised. The look on the faces of those being asked to provide just the location of the official copies is usually one of confusion, or worse, blank incomprehension.
The worst thing you can do is hand your QSA a bunch of crappy docs and say “You tell me what’s missing.” It does not work that way, and all you’ve done is thoroughly irritate someone who should be on your side. It is YOUR job as the client to tell the QSA which documents and specific language YOU think meets the intent of the DSS requirement testing procedures. The best way to do this (if you don’t have access to a GRC tool with DMS built-in, see below) is just to start with the DSS on a spreadsheet and map your existing documents to it. Your QSA will tell you the gaps, which gives you the necessary action items to begin your remediation.
Here’s the one I give my clients, help yourself; PCI DSS v3.0 – Document Mapping Matrix
- Policy Content – In terms of policies, procedures and standards, these are the major headings I generally expect to see; PCI DSS v3.0 – Policy & Procedure Checklist.
- Document Management System (DMS) – This does not have to be a major expense, a folder on an intranet share will suffice, but the point is to have a centralised location to place all of your latest approved documents. They should however have access control mechanisms in place to ensure only those with a real need to see them, can. Some of the more elaborate DMSs will take care of version control, ownership, review cycles and so on, as well as automated mappings to regulatory compliance regimes like PCI. Choose what’s right for your business, and look at the Governance Risk & Compliance tools that may have this built-in.
- Pre-Packaged Templates – There are many organisations that can offer pre-packaged policy templates, but none that can provide pre-packaged procedures. Best practice policies are numerous and can be customised to suit your business, but procedures are written by your organisation and are necessarily specific to it. Don’t buy anything claiming policies AND procedures out of the box, and don’t buy anything specific to PCI. Cover your business, and if you have to spend money to get your ‘paperwork’ together, focus more on expert guidance. Avoid policies that match the next two points.
- Monolithic vs. Modular – It is generally best to have each of your separate policies as stand alone documents with their own version history and ownership, a single policy document is very hard to maintain.
- PCI Relevance – The phrase ‘card holder data’ should appear only once, maybe twice, in all of your policies; in the Data Classification Policy. Every other policy refers to the classification in which card holder data was contained (e.g. Highly Confidential).
Like everything in security, getting policies right is not easy, but it is simple. There are many people out there who can help you if you don’t know where to start, and this is not something you should do half-arsed.
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