5 Ways to Reduce Your PCI DSS Scope

The applicability of the Payment Card Industry Data Security Standard (PCI DSS) poses challenges for most organizations that implement it. Even experienced PCI DSS compliant entities can encounter scope creep as their networks evolve.

Therefore, it comes as no surprise that reducing the scope is a highly effective and practical approach to maintain compliance with PCI DSS. This blog aims to explore several common techniques for scope reduction, which can alleviate the time, financial, and resource burdens associated with meeting PCI DSS requirements.

By implementing these scope reduction techniques, organizations can streamline their processes and focus on the specific areas that require PCI DSS compliance. This proactive approach not only helps in maintaining a secure environment but also ensures that the organization stays up to date with the evolving requirements of PCI DSS compliance.

1: Segmentation

The initial technique, which should be the primary consideration for organizations aiming to reduce scope, is network segmentation. Although not mandatory according to the PCI DSS, the PCI Security Standards Council (SSC) and nearly all PCI Qualified Security Assessors (QSAs) highly recommend it.

The crucial aspect of network segmentation is either establishing distinct physical networks to eliminate any chance of segmented systems falling within the scope or, if employing logical segmentation (such as VLANs), ensuring a proper configuration that prevents out-of-scope systems from connecting to those within scope.

2: Outsourcing

Outsourcing, particularly prevalent among e-commerce platforms, is another widely used technique. In this approach, organizations delegate a portion or the entirety of their payment channel to a third party. This can be viewed as a form of physical segmentation. However, it is crucial to recognize that responsibility for compliance cannot be outsourced. As a merchant, you bear the ultimate responsibility for safeguarding cardholder data and must ensure that any third parties involved fully comply with all pertinent requirements.

3: Encryption

At first glance, encryption may not be perceived as a scope reduction technique since it is commonly viewed as a security control. However, according to the PCI Security Standards Council (SSC) and numerous PCI Qualified Security Assessors (QSAs), it is regarded as one of the most effective methods for scope reduction. Put simply, if cardholder data is encrypted throughout your systems, whether it is stored (at rest) or transmitted (in transit), any system or device incapable of decrypting the data can generally be considered out of scope. Nevertheless, caution must be exercised to ensure that any system or device designated as out of scope does not provide security services to another system or device within scope.

4: Data removal

While it may seem obvious, removing stored cardholder data is a direct way to reduce PCI DSS scope. Surprisingly, many organizations overlook this potential solution. The guidance from the PCI Security Standards Council (SSC) is simple: if you don't require it, don't store it. However, the challenge lies in identifying all instances of cardholder data within your environment. In older systems, cardholder data tends to appear in unexpected locations such as text files, log files, memory dumps, application logs, legacy databases, backups, and so on.

Enlist qualified support

Numerous nuanced techniques exist for scope reduction, but their applicability will depend on your unique payment channel and network infrastructure. Factors such as the utilization of network jump-boxes for access control or consolidating payment channels onto a single platform can significantly impact the effectiveness of these techniques. The challenge lies in determining whether these methods will yield a significant enough reduction in scope to justify their implementation. This is where consultants and PCI QSAs can provide valuable assistance by analyzing your specific circumstances, including infrastructure and business objectives, and identifying the most suitable techniques for scope reduction, thereby ensuring ongoing compliance.

Moreover, engaging in a regular PCI DSS audit is crucial to validate the effectiveness of implemented scope reduction measures. PCI DSS audits provide an independent assessment of an organization's compliance with the standard and help identify any potential gaps or areas of improvement. By conducting these audits, organizations can ensure that their scope reduction efforts align with the requirements of PCI DSS and maintain a strong security posture.

Consulting with experienced PCI DSS auditors can offer valuable insights and guidance throughout the audit process. These professionals possess the necessary expertise to assess the effectiveness of implemented scope reduction techniques, identify any shortcomings, and provide recommendations for enhancing compliance.

By combining the expertise of PCI QSAs, consultants, and regular PCI DSS audits, organizations can strengthen their overall compliance posture and mitigate the risks associated with handling payment card data. This proactive approach not only demonstrates a commitment to security but also helps build trust with customers and partners by ensuring the protection of sensitive information.