The PCI DSS (Payment Card Industry Data Security Standard) guidelines are instrumental to any organization that manages, stores, transmits, or processes customer payment card information. It is a globally recognized and trusted information security standard that provides methods and controls for organizations to use while handling sensitive card details.
However, due to varied constraints, technical limits, or particular operational requirements, obtaining full compliance can still be difficult for some organizations. This is where compensating controls come into play.
PCI DSS compliance entails more than 100 pages of requirements. However, Appendices B and C describe the compensating controls and provide ideas for minimizing your risks. Limiting risk also entails being able to limit your scope. When you lack the architecture to meet a requirement, compensating controls assist you in remaining compliant with PCI DSS criteria.
In this blog, we will give you a brief overview of PCI DSS’s compensating controls.
What are PCI DSS Compensating Controls?
Organizations can use PCI DSS compensating controls to meet security standards that cannot be satisfied due to technological challenges or business restrictions. By allowing companies to apply compensatory controls, PCI DSS provides some flexibility or different solutions for mitigating the risk specified in the requirement.
Compensating controls are only valid once an assessor has evaluated them. The effectiveness of these controls is determined by factors such as:
- what situation it is required in;
- the perimeter security controls; and,
- the configuration of the applicable controls.
You must remember that PCI compensating controls are not a quick fix for achieving compliance. You should have a good reason when you don’t implement a control. While these are useful as a stopgap measure, you should try to attain the initially recommended compliance.
Implementing Compensating Control Measures
Within the PCI DSS 3.2.1 whitepaper, the PCI SSC provides guidelines for establishing alternative security measures or compensating controls. The Council expressly states:
“For each and every compensating control, the Compensating Controls Worksheet must be completed. Additionally, compensating control results should be documented in the RoC in the corresponding PCI DSS requirement section.”
In other words, before any compensating control can be regarded as effective, your organization must analyze the risk associated with the controls and how you intend to manage any risks discovered during the inquiry. Analysis documentation is also required to complete parts of the Report on Compliance (RoC) or the Self-Assessment Questionnaire (SAQ) forms. These are two formal documents used to demonstrate that you are properly processing credit card information and are in compliance with the PCI DSS. They will be required when Qualified Security Assessors do the yearly audit.
The following section will delve into the requirements of PCI DSS’s alternative security control measures.
What are the Requirements of Compensating Controls According to Appendix B?
To create and implement a compensating control, a PCI-compliant organization must meet the conditions listed below:
- Meet the objectives and rigor of the original PCI DSS requirements
To meet these requirements, the compensating control must offer the same level of security as the original control requirement. For example, consider the PCI DSS need to maintain a firewall to protect cardholder data and the organization’s failure to do so. Therefore, they would need a compensating measure to protect cardholder data from attackers and unauthorized user access. The alternative security measure must provide the same level of protection as a firewall.
2. Provide a degree of security comparable to the original PCI DSS requirement
While this criterion may appear redundant to the first, it focuses on compensating control’s practical implications. If the original requirement is designed to give a specified level of protection and the compensating control cannot match that level of security, an auditor or quality assessor may find the compensating control ineffective. As expressed, compensatory restrictions must be as powerful and effective as the original need.
3. Be above and beyond other PCI DSS requirements
To fulfill this requirement, an organization must ensure that if a compensating control is implemented and poses an additional risk, the compensating control must also account for this possibility or risk of being deemed invalid or ineffective. In other words, the compensating control must be more secure and cover more risk ground than simply complying with other PCI DSS requirements.
4. Be proportionate to the additional risk caused by failing to comply with the PCI DSS requirements
This requirement is frequently over-complicated, although it is basic. If your compensating control replaces one PCI need, it cannot be used to replace any other PCI requirement. In other words, you must only use compensating controls once.
When compensating control is determined to be valid, organizations must document its effectiveness in their context. This documentation should include the following items:
- List of Restrictions
- Objectives
- Risks Identified
- Definition of Compensating Controls
- Maintenance
It is vital to ensure you can clearly and successfully answer these questions when adopting compensating controls and justifying them to a QSA.
Now, let’s learn what a compensation control worksheet consists of.
What is Included in the Compensating Controls Worksheet as Given in Appendix C?
The PCI compensating control worksheet is intended for organizations that have completed a risk assessment. To achieve compliance, they must have reasonable business constraints to execute the original controls. It is the duty of your organization to complete this paper. After you have finished it, a Qualified Security Assessor (QSA) can suggest improvements.
The worksheet can be found listed under Appendix C.
Here are some best practices you should keep in mind while filling out this worksheet:
- In your reasons, avoid using bad or weak arguments. Businesses, for example, frequently claim that they do not want to utilize controls or are impossible to implement. Budget restrictions, time limits for implementation, or a lack of application facility to run it are stronger justifications.
- Many organizations establish compensating measures but must explain how they intend to maintain their effectiveness and functionality. Documentation lets you gain insight into potential risks and areas where your controls may be ineffective. You can provide deadlines for resolving control test failures.
- Your compensatory controls, processes, and systems should already be operational. You cannot, for example, make plans and statements such as will do, will implement, has to be examined, still to be added, and so on. Control planning is not the same as control implementation. The compensating worksheet is not your ticket out of compliance; thus, ensure everything mentioned is operational.
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