7 Common Mistakes of PCI Assessments Handout

Download the 7 Common Mistakes of PCI Assessments here: https://info.securitymetrics.com/common-mistakes-of-pci-audits

With this checklist, you'll learn how to:

• Avoid hidden scope creep that inflates cost and risk
• Eliminate last-minute documentation scrambles
• Build PCI DSS into daily operations, not just the audit season
• Hold third-party providers accountable for compliance

Whether you’re gearing up for your first PCI DSS v4.0.1 audit or strengthening a mature compliance program, this checklist will help you be prepared for your next PCI assessment.

7 Common Mistakes of PCI Audits

Note: This handout aims to assist those who are new to PCI audits. This suggested guideline can help you anticipate your PCI tasks. This is not a comprehensive handout, and PCI compliance should be addressed based on how your organization handles cardholder data. A complete list of control requirements can be found here.

PCI compliance can seem overwhelming if your organization tries to tackle everything all at once. This handout offers advice on how to address the most common mistakes organizations make when preparing for a PCI assessment.

1. Underestimating Your PCI DSS Scope

The Mistake: 

Incorrectly defining the Cardholder Data Environment (CDE), leading to critical systems, networks, and applications being left out of the audit.

The Consequence: 

You may have an incomplete (or more expensive) audit, as well as a false sense of your security posture.

How to Avoid It:

• Conduct a thorough scoping exercise with internal and external stakeholders.
  
  • Interview every department to make sure your card flows are accurate.
• Create detailed data flow diagrams that map every point where cardholder data is stored, processed, or transmitted.
• Look for overlooked places of data flow
  
  • Call centers
  • Accounting departments
  • Backups
  • FTP servers
• Use data discovery tools, like PANscan, to actively search for unencrypted card data.
• Use network segmentation to isolate the CDE and minimize your compliance scope.
• Question unnecessary business practices. For example, if there isn’t a need to store PAN, stop storing it.
• Keep thorough documentation of your scoping efforts.

2. Inadequate Documentation and Policy Management

The Mistake: 

Lack of comprehensive, up-to-date documentation for policies, procedures, process, and evidence of controls.

The Consequence: 

The audit process becomes a painstaking, time-consuming scramble to find evidence, leading to delays and potential non-compliance findings.

How to Avoid It:

• Create and maintain a central repository for all PCI-related documentation 
  
  • Policies
  • Network diagrams
  • Risk assessments
  • Incident response plans
  • Change control tickets
  • Account management activities
• Ensure all documentation is regularly reviewed and updated to reflect changes in the environment.
• Use a checklist to track required documentation and evidence.
• Make documentation part of your security and operational culture, instead of just a chore.

3. Failing to Treat PCI DSS as a Continuous Process

The Mistake: 

Approaching PCI compliance as an annual effort to pass the audit, then letting controls lapse for the rest of the year. 

The Consequence:

Without properly maintaining security efforts, businesses make themselves easier targets for attackers. As well as it being more difficult to pass your assessment in the future, since many PCI requirements need a continuous process to be in place.

How to Avoid It:

• Treat PCI compliance as an ongoing effort through outlined processes.
• Perform regular checks and assessments
  
  • Security configuration reviews
  • Quarterly vulnerability scans‍
  • Daily log monitoring
  • Conduct an annual targeted risk assessment
  • Annual penetration tests‍
  • Monitor the status of all systems in the CDE
  • Robust change control process
• Rescope your environment after changes
• Make sure the team assigned the responsibility to manage PCI compliance year-round has:
  
  • Senior management support
  • Regular training
  • Resources to succeed
  • Documentation for all PCI-related activities

4. Neglecting Third-Party Service Provider Compliance

The Mistake: 

Assuming that outsourcing payment processing or data storage absolves the organization of its PCI compliance responsibilities.

The Consequence: 

The business can be liable for a breach that occurs with an uncertified or non-compliant third party.

How to Avoid It:

• Conduct due diligence on all third-party service providers
• Obtain and review their Attestation of Compliance (AOC)
• Ensure their PCI compliance responsibilities are clearly defined in a contract
• Have a “good” responsibility matrix defined for each TPSP
• Regularly (at least annually) monitor their compliance status

5. Not Enforcing Proper Access Controls

The Mistake: 

Granting too many employees unnecessary access to the CDE and failing to properly implement multi-factor authentication (MFA).

The Consequence: 

Increased risk of data exposure through compromised accounts, phishing, social engineering, or internal threats.

How to Avoid It:

• Implement the principle of least privilege, ensuring access is granted only on a "need-to-know" basis
• Have strong password policies in place
  
  • Minimum length of 12 character password
  • Don’t allow shared credentials
• Enforce Multi-factor authentication for all access to the CDE
• Implement role-based access control (RBAC)
• Regularly review and update access controls
  
  • Promptly revoke access for terminated employees

6. Inadequate Employee Training and Security Awareness

The Mistake: 

Assuming employees understand their role in protecting cardholder data without providing regular, targeted training.

The Consequence: 

Careless handling of sensitive data will lead to an overall weak security posture, which may allow for businesses to be vulnerable to phishing attacks.

How to Avoid It:

• Conduct annual security training, with topics including:
  
  • Recognizing social engineering
  • Proper handling of data
  • Reporting security incidents
• If possible, provide targeted training to each employee's specific responsibilities in protecting sensitive data.
• Provide reminder training throughout the year (e.g., monthly security newsletters)
• Foster a culture where every employee values training, instead of just being a distraction from their regular work

7. Inadequate Preparation for New PCI Requirements

The Mistake: 

Not proactively updating policies, procedures, and technical controls to meet the new, more prescriptive requirements of PCI DSS v4.0.1.

The Consequence: 

If you don’t have the new requirements in place, you might fail your assessment and be less prepared for a data breach.

How to Avoid It:

• Conduct a detailed gap analysis between your current state and the PCI DSS v4.0.1 requirements
• Prioritize remediation efforts for high-impact areas like:
  
  • MFA implementation
  • Password length
  • Secure coding for e-commerce payment pages.
• Make sure that your tool can fulfill 6.4.3 and 11.6.1 requirements

About SecurityMetrics

We secure peace of mind for organizations that handle sensitive data.  We have tested over 1 million systems for data security and compliance. We understand the importance of industry standards, which is why we hold our tools, training, and support to a higher, more thorough standard  of performance and service.

Using over 20 years of auditing experience, you get crafted a process that simplifies and streamlines your work. Our QSA team members hold many professional certifications including QSA, PA-QSA, QSA (P2PE), PA-QSA (P2PE), PCIP, CISSP, CISA, CISM, ITIL, MCP, MCITP, CCNP, and NERC CIP.

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