Can you hold Payment Card Information (PCI) data in a cloud-based service? Yes, but doing so isn't straightforward, so the PCI Security Standards Council has published a guideline that clarifies what approaches compliance-minded businesses can take.
"Obviously, it's OK to use the cloud," says Bob Russo, the Council's general manager. "But we want [businesses] to understand the models of deployment." The 50-plus page document, titled "Information Supplement: PCI DSS Cloud Computing Guidelines," delves into what businesses should expect and demand from their cloud service provider regarding protection of sensitive PCI data, as well as emphasizing the core responsibility for the PCI data that the business must accept.
The Council's supplemental guidance out today doesn't change any of the main PCI Data Security Standards (PCI DSS) that have long applied to how PCI data is held or processed in enterprise networks or the many specialized PCI data processors. But it does go into detail about how these traditional security controls ought to be applied in cloud-computing environments, whether they be models defined as infrastructure-as-a-service, platform as-a-service or software-as-a-service.
"It doesn't replace the standard," Russo says. But he points out that the Council's PCI cloud guidance details how if cloud providers say they are "PCI compliant," that doesn't mean that merchants using their services should "think their job is done." In reality, the merchant should be asking what more needs to be done to adequately protect payment card data held in the cloud using the needed PCI security controls such as encryption, anti-virus and access control spelled out in the PCI DSS.
To help merchants and cloud providers navigate through this as regards PCI data, the Council's guidance extensively details the considerations and questions that should be examined in many cloud situations. These include private, community, public and hybrid clouds. The guidance will also certainly influence how PCI assessors that audit PCI data will be looking at how merchants manage PCI data in cloud environments, too.
"The lines of accountability and responsibility will be different for each service and deployment model," the Council's cloud guidance states. "Clear policies and procedures should be agreed upon between client and cloud provider for all security requirements, and clear responsibilities for operation, management and reporting need to be defined for each requirement."
The Council is stressing that no business should go blindly into cloud deployment for PCI. Any business using the cloud for PCI data must "understand the level of oversight of visibility they will have into security functions that are outside their control. If these security responsibilities are not properly assigned, communicated, and understood, insecure configurations or vulnerabilities could go unnoticed and unaddressed, resulting in potential exploit and data loss or other compromise."
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