Documentation and compliant evidence pose a challenge for IT and security departments, but they are crucial for satisfying PCI DSS compliance and PCI Qualified Security Assessors (QSAs) and ensuring a successful PCI compliance audit. The effectiveness of PCI DSS compliance programs relies heavily on accurately and consistently recording events, as well as adhering to well-defined policies and procedures.
These documents play a vital role in informing staff about their responsibilities and outlining the necessary actions to create a secure and compliant environment. Some PCI requirements necessitate periodic review of specific documents or the execution of instructions at designated intervals. Failure to carry out required actions, such as firewall rule reviews or external vulnerability scans, can jeopardize the entire compliance initiative. To mitigate this risk, organizations are advised to centrally analyze their documentation and evidentiary needs, summarizing them in a way that allows for easy tracking of content and resulting actions.
Security policies and procedures are not a new concept, and with the abundance of established security standards developed over the past few decades, there is no need to reinvent the wheel. As long as the documents are clear, concise, effectively convey the intended message, are tailored to the specific environment, and encourage the necessary behaviors, they will achieve the desired outcome. It is crucial to ensure that all PCI control statements requiring explicit documentation are included in the relevant documents, as this will save time and resources when tackling this necessary yet challenging task.
While not all documents will be mandatory for every organization, a considerable number must be implemented to achieve a successful outcome in a PCI DSS audit. By having these documents, procedures, and activities in place to produce the required evidence, organizations are well on their way to achieving PCI DSS compliance. To give you an idea of the types of documents and evidence (although not an exhaustive list) typically needed to be developed and implemented for a PCI DSS audit, here are some examples to start with:
DOCUMENTS
Here is a rephrased version of the list of documents and evidence artifacts typically needed to achieve compliance with the PCI DSS:
Policy for managing network devices
Procedure for scanning wireless networks to detect rogue access points
Policy for remote access, applicable to staff and vendors
Standards for configuring devices
Policy for managing visitors
Procedures for operational security
Please note that this list is not exhaustive, but it provides a starting point to illustrate the types of documents and evidence required.
EVIDENCE
Here is a rephrased version of the additional items for the list of documents and evidence artifacts typically needed to achieve compliance with the PCI DSS:
Diagrams depicting the network architecture
Diagrams illustrating the flow of data within the network
Documentation of incident response testing
Matrix outlining role-based access permissions
Reports from vulnerability scanning activities
Register documenting identified risks
Soft copies of contracts with third-party vendors
Please note that this list is not exhaustive, but it provides a broader range of documents and evidence artifacts that are commonly required for PCI compliance.