PCI compliance starts with a solid policy. In this guide, experts share how to write a PCI DSS policy to protect cardholder data and meet the v4.0.1 PCI DSS standards. Explore key sections, download a free template, and customize your policies to meet the latest security standards.
What is a PCI compliance policy?
A PCI compliance policy outlines a company’s approach to credit card data security. To achieve PCI compliance, you must meet the Payment Card Industry Data Security Standard (PCI DSS). The policy is your game plan.
“A PCI policy is the right place to start for any organization that wants to establish security policies related to credit card data,” says Stephen Ferrell, CISA CRISC, and Chief Strategy Officer at Strike Graph.
Any organization that handles or stores credit card data falls into one of the four levels of PCI DSS compliance. These organizations typically create a PCI DSS policy to address the 12 core requirements they must meet under the PCI DSS v4.0.1, the latest PCI DSS standard.
“A PCI DSS policy speaks directly to PCI requirements,” says Blazej Jedras, Head of IT Governance at Compliance Path, an Ideagen Software Company. Jedras emphasizes that while PCI DSS does not mandate a PCI policy, adopting one is a best practice for any reputable organization.
A PCI policy doesn't usually delve into all the details of your compliance approach. Instead, companies also maintain technical policies that focus on implementing security controls and addressing specific technical factors.
According to Michelle Strickler, Information Security and Data Privacy Compliance Strategist at Strike Graph, “A PCI policy is an industry-standard best practice from which procedures and work instructions can evolve.”
Key takeaways:
- A PCI policy outlines how an organization plans to meet PCI DSS standards.
- A PCI policy focuses solely on PCI DSS and handling cardholder data, unlike an information security policy, which covers broader security approaches.
- Organizations typically base their PCI policies on the 12 core PCI requirements.
- Customize your PCI policy by incorporating industry-specific terms and relevant security considerations.
- Begin drafting a PCI DSS policy by using a robust PCI policy template and tailor it to your organization with expert guidance.
No, there is no difference between a PCI policy and a PCI DSS policy. Both terms refer to a document outlining how an organization will keep credit card information safe and meet the PCI DSS standard.
“The terms 'PCI policy' and 'PCI DSS policy' are interchangeable," says Strickler. "It’s simply a matter of a company’s preference or convention.”
Is there a difference between a PCI policy and an information security policy?
Yes, a PCI policy differs from an information security policy. A PCI policy focuses solely on credit card security. An information security policy addresses all types of data.
In fact, the PCI DSS standard mandates that an organization establish, maintain, and disseminate an overall information security policy. In contrast, an information security policy doesn’t mandate a separate PCI DSS policy.
“Like PCI DSS, most compliance frameworks mandate that companies articulate their security requirements and intentions through an information security policy,” Jedras explains. “This policy details high-level actions and commitments related to overall data security, not just credit card security."
Why do you need a PCI DSS policy?
Companies need a PCI policy to explain how they will meet PCI DSS standards. The policy also sets clear employee expectations and shows you are serious about credit card security.
Here's a summary of the major reasons to create a PCI DSS policy:
- Helps organizations create security procedures
“A good policy will go beyond checking PCI boxes and establish a foundational security framework that guides an organization’s security measures,” Strickler says. “From this policy, an organization can create procedures and work instructions so that the company is keeping credit card information safe.”
- Aligns employees and stakeholders
Strickler adds that a PCI policy brings together everyone who deals with credit card security. "It gives them clear rules and expectations and makes sure that everyone is on the same page and working toward common goals.”
- Helps meet PCI DSS documentation requirements
The PCI DSS standard contains many documentation requirements. Many organizations will use their PCI policy to help meet these requirements.
“PCI DSS requires auditable documentation for each requirement like policies and procedures,” says Jedras. "Organizations often leverage their PCI policy to fulfill some of these documentation needs, especially for overarching operational aspects rather than specific controls and technologies.”
Jedras adds that most organizations will need additional policies to detail specific technical and operational requirements that are too specific for a PCI policy.
Required sections in a PCI DSS policy
A PCI DSS policy must address the 12 core requirements, ranging from a firewall to security testing. It also must have a section on the organization’s PCI scope, a list of important company roles and responsibilities, and a basic overview.
Here's a summary of the major sections you should include in your PCI DSS policy, with examples of important items to include. You can find a more exhaustive example in our PCI template.
- Purpose
This section describes the purpose of the PCI policy. It explains that the document will document policies to safeguard credit card data and comply with PCI DSS.
- Scope
The scope describes the people affected by the policy, including employees, contractors, external service providers, and vendors. It also defines the organization’s credit card environment.
- Roles & responsibilities
(Relevant PCI DSS 4.0.1 Requirements: 12.1 (12.1.3, 12.1.4)
This section defines roles related to maintaining the cardholder data environment (CDE) or complying with PCI DSS. It also describes the responsibilities for each role.
Examples of what to include:
- Responsibilities of key roles like the chief information officer, IT senior leadership, and the chief information security officer.
- Responsibilities of chief administrative officers, supervisors, and anyone responsible for handling or processing card data.
For example, identify the responsibilities of key roles like the chief information officer, IT senior leadership, and the chief information security officer. Other roles include any chief administration officers and supervisors and anyone responsible for handling or processing card payments.
- Policy reviews and maintenance
Relevant PCI DSS 4.0.1 Requirements 12.1 (12.1.1, 12.1.2)
State how often the policy will be updated. Reference the information security policy for additional guidelines.
- PCI DSS Standard requirements
Broadly outline how your organization will comply with each of the 12 PCI DSS requirements. There are various approaches to organizing this section. For example, some organizations will create a section for each specific requirement, while others may group common requirements. Below is an example approach that groups requirements addressing similar security issues together.
- Secure networks and systems
Relevant PCI DSS 4.0.1 Requirements: (1.1, 1.2, 2.1, 2.2)
This section defines a policy for securing network configurations, including firewall settings and system parameters, to protect the CDE and comply with important PCI DSS requirements. It establishes your policy of security controls against network threats.
Examples of what to include:
- Firewall configuration: Develop and implement formal standards for firewalls and routers.
- Network diagrams: Establish a policy of maintaining network and data flow diagrams that show all the connections and data flows within the CDE. Outline any approach to using micro-segmentation to divide the network.
- Default system and security parameters: Define a policy of changing default settings for wireless environments. Establish a policy of maintaining an inventory of all systems in the CDE and changing vendor default passwords and settings.
- Device management: Ensure that only authorized personnel can access devices that handle cardholder data.
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- Protect cardholder data
Relevant PCI DSS 4.0.1 requirements (3.1 – 3.7, 4.1 – 4.2)
This section summarizes data protection and retention policies to ensure the organization manages data throughout its lifecycle.
Examples of what to include:
- Protection of stored cardholder data
Outline policies to securely store cardholder data and ensure no party can recover sensitive authentication data (SAD) after authorization. Outline access controls and define a policy of redacting any SAD from paper documents.
- Encryption of transmitted cardholder data: Define data encryption standards for transmitting credit card information.
- Vulnerability management in PCI DSS
Relevant PCI DSS 4.0.1 requirements (5.1 – 5.4, 6.1- 6.7)
This section outlines policies to identify, protect against, and manage vulnerabilities in the CDE. It focuses on protecting the CDE from malware and establishing secure systems and applications.
Examples of what to include:
- Malware protection: Outline your policies for deploying and configuring malware protection and anti-virus software on all servers and software in the CDE.
- Secure systems and applications: Outline policies to implement automated vulnerability scans.
- Secure coding practices: Require development teams to follow secure coding practices.
- Risk assessment: Outline policies to categorize and assess system risks.
- Access management and access controls
Relevant PCI DSS 4.0.1 requirements (7.1 – 7.3, 8.1 – 8.6, 9.1 – 9.5)
This section defines policies to control CDE access and outlines ways to ensure that only those with authorization can access sensitive information.
Examples of what to include:
- Logical access control measures: Outline access restrictions and specify a schedule to review access authorizations.
- Authentication to system components: Require multi-factor authentication (MFA), like two-factor authentication (2FA), to access the CDE.
- Physical access control: Establish policies for safeguarding physical data, like secure video surveillance for storage areas containing high-risk data.
- Remote access: Outline remote access control policies with external vendors.
- Network monitoring and testing
Relevant PCI DSS 4.0.1 requirements (10.1 – 10.7, 11.1 – 11.6)
Define policies to continuously monitor and test network resources against threats.
Examples of what to include:
- Monitoring of network resources: Specify policies surrounding activity logging and auditing procedures.
- Network scanning and secure testing systems: Define policies around performing internal and external vulnerability scans by approved scanning vendors (ASVs). Regularly test intrusion detection and prevention systems (IDPPS) and perform routine penetration testing.
Additional sections for a PCI DSS policy
PCI DSS policies may include additional sections beyond the core ones. For example, you can insert a glossary and communication plan. You can also have a training plan and policies for third-party vendors.
Here’s a summary of some additional sections organizations may want to include in their PCI policy:
- Definitions and acronyms
Provide a list of definitions and acronyms that you use to ensure every stakeholder understands the policy.
- Communications plan
Describe how your organization will communicate the policy to employees and relevant third parties.
- Security awareness & training
Relevant PCI DSS 4.0.1 Requirements (12.6)
Outline a security awareness and training program that educates employees about PCI DSS and protecting cardholder data.
- Third-party management
Relevant PCI DSS 4.0.1 Requirements (12.8, 12.9)
Outline policies for managing third-party service providers who have access to the cardholder data environment. Ensure that third parties comply with PCI DSS requirements and maintain appropriate security controls.
- Incident response plans & risk assessment
Relevant PCI DSS 4.0.1 Requirements (12.10)
Develop a comprehensive incident response plan to address potential security breaches. Outline steps for identifying, responding to, and mitigating incidents involving cardholder data security.
- Policy monitoring
Identify who will review the PCI policy and specify how often to conduct a review.
- PCI compliance monitoring & reporting
Establish procedures for monitoring compliance with PCI DSS requirements and reporting on compliance status. Include guidelines for completing your self-assessment questionnaires (SAQ) accurately or engaging with a qualified security assessor (QSA) as needed. Also, include guidelines on preparing and submitting reports on compliance (ROCs) and attestations of compliance (AOCs).
PCI DSS policy template
Strike Graph’s PCI DSS Policy template is a customizable framework for a robust PCI policy. It’s the ideal starting point for organizations that need an effective policy to protect cardholder data and comply with PCI DSS.
Download Strike Graph’s PCI DSS Policy Template now to create your PCI policy and safeguard cardholder data with confidence.
How to customize a PCI policy template for your company
You can customize a PCI policy template with your organization’s specific security needs and terminology. All companies will define their scope and purpose. Beyond that, they may modify the template sections to include items tailored to the industry or organization.
However, Ferrell explains, “PCI DSS concerns itself solely with credit card data, so organizations across different sectors —whether in healthcare or education — will find their PCI policies share many common elements. Most differences arise in how each organization integrates PCI requirements into specific operational frameworks and complies with regulations like HIPAA in healthcare. These specifics belong in an information security policy rather than a PCI policy.”
Here's a summary of which sections to customize for your PCI policy, along with industry-specific customizations and tips:
- General areas of customizations
- Purpose
The purpose should clearly state your organization’s intention to protect cardholder data and comply with PCI DSS. To customize the purpose, highlight any additional objectives specific to your industry, such as integrating with HIPAA for healthcare organizations or FERPA for educational institutions. Reference your information security policy when discussing additional regulatory frameworks.
- Scope
Identify specific stakeholders, including relevant departments, third-party vendors, and service providers. Define your specific cardholder data environment (CDE) to include all areas where you process, store, or transmit cardholder data.
- Roles and responsibilities:
Define specific roles and responsibilities within your organization.
- PCI DSS Standard requirements:
Based on your compliance level and unique security risks, broadly outline your strategies to meet the relevant PCI DSS requirements. Not all organizations need to comply with the entire standard, so focus on the sections that apply to your specific operations. Detail which SAQ you will use or whether you need to engage with a QSA.
- Customizations for educational institutions
- Purpose:
Emphasize the protection of cardholder data in the context of study payments and transactions. Refer to your information security policy as it relates to other relevant regulations, like the Family Educational Rights and Privacy Act (FERPA).
- Scope:
Include all departments handling cardholder data, such as admissions, bookstores, dining services, and more. Define the credit card environment within the entire campus network.
- Roles and responsibilities
Assign specific roles to financial services staff across the campus. Establish a security policy to ensure student workers handling payment data receive training and understand their responsibilities.
- PCI DSS Standard requirements:
Focus on securing networks across multiple campuses.
Implement data encryption and secure storage practices specific to educational settings.
- Customizations for fintech companies
- Purpose:
Highlight the importance of protecting cardholder data within digital payment systems and applications. Reference your information security policy and any additional fintech security standards.
- Scope:
Define the credit card environment across all digital platforms, including mobile apps and online payment gateways. Include all third-party service providers that work in payment processing.
- Roles and responsibilities
Define the roles of the organization’s staff in handling credit card data.
- PCI DSS Standard requirements
Fintech companies may need to consider more stringent security standards to handle emerging threats. For example, consider implementing advanced encryption for cardholder data. Also, establish a policy to conduct periodic security assessments and vulnerability scans.
- Customizations for healthcare organizations
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- Purpose
Explain the importance of prioritizing credit card security in a healthcare environment. Reference your information security policy and related healthcare regulations, such as HIPAA. Emphasize that security measures and protocols protect cardholder data and patient health information.
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- Scope:
Define the CDE within all healthcare facilities, including online payment portals. Include all areas where you process, store, or transmit cardholder data.
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- Roles and responsibilities:
Outline a policy to train staff handling payment data in both PCI DSS and HIPAA requirements. Provide specialized training for staff on handling and reporting incidents involving payment and health information. Reference your information security policy to emphasize the importance of these roles.
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- PCI DSS Standard requirements:
Develop an incident response plan to address healthcare scenarios, such as breaches involving both cardholder data and sensitive patient information. Implement stringent access controls and multi-factor authentication to safeguard both types of data. Ensure continuous monitoring, logging, and regular security assessments to maintain a high level of security.
The easiest way to create custom compliance policies
Strike Graph’s compliance tools enable companies to customize their PCI approaches. These convenient tools include a template library and dashboard. Use them to tailor a strong PCI policy that reflects your organization’s vision and commitment.
Here’s how Strike Graph can help you create effective policy documents that create a centralized approach to security:
- Extensive compliance template and security control library
Access our extensive library of templates to get comprehensive policy templates for all major frameworks, from PCI DSS to HIPAA. Plus, you can access over 450 audit-tested compliance controls that you can apply to diverse frameworks and include in your policy.
- Compliance dashboard
Strike Graphs’ compliance dashboard helps you integrate your policy into day-to-day operations. Use the dashboard to clarify roles, assign ownership of specific security risks, and automate evidence collection, so your team can use their innovative security measures for multiple controls. The dashboard offers a broad view of your organization’s approach alongside detailed insights, so everyone has the information they need to put policy into action.
- Seamless integrations
“Many of the major security frameworks ask for similar security controls,” describes Ferrell. “Strike Graph is unique in that it looks at all of these frameworks together so that anyone can pull a control from one framework and apply it to another. This type of approach helps teams design clear and strong policies that meet security requirements across various frameworks.”
How Strike Graph makes PCI DSS v4.0 compliance easier
Strike Graph makes PCI DSS v4.0 compliance a seamless part of your organization’s daily operations. Unlike companies providing generic checkbox solutions, Strike Graph empowers clients to design compliance programs that align with their unique environments and broader security strategies.
Strike Graph offers a unique approach that helps organizations across industries use robust compliance dashboards, template libraries, controls, and automated evidence collection.
Here’s how Strike Graph streamlines PCI DSS compliance:
- Automated compliance: Say goodbye to the hassle of manually filling out compliance forms. Strike Graph uses your data to automatically fill out reports like your SAQs, ROCs, AOCs, and more.
- Get ready for v4.0.1: Stay ahead with Strike Graph. It identifies gaps in your compliance program under the latest version, 4.0.1, and recommends controls and evidence to enhance your security posture.
- Integration with multiple frameworks: Beyond PCI DSS, Strike Graph seamlessly integrates with other security frameworks such as SOC 2 and HIPAA. This holistic approach ensures consistent protection of all assets and customer data across your organization.
- Efficiency and cost savings: Strike Graph identifies which controls and evidence you can apply across multiple frameworks, saving you time and money.
PCI DSS compliance isn’t simple, but with Strike Graph, achieving and maintaining certification is. Focus on scaling your business while Strike Graph handles evolving compliance demands.