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PCI Compliant File Sharing: Essential Requirements & Effective Compliance Strategies

by Bob Ertl updated June 11, 2024 PCI Compliance

Reading Time: 9 minutes

PCI compliance plays a critical role in bolstering the integrity and security of credit card data that businesses process, handle, and share with trusted third parties. Whenever businesses share this data, they risk exposing it to unauthorized users. Unauthorized access comes in many forms: malware attacks, ransomware attacks, corporate espionage, misdelivery, phishing, and more. These risks require businesses to put advanced safeguards in place that go beyond standard firewall protections. PCI compliance exists to ensure that credit card data is protected from unauthorized access, which can lead to this sensitive data being used for fraud or identity theft. From transmission to storage, secure file sharing provides organizations with a more robust security framework, a necessity for demonstrating PCI compliance.

So, if you’re looking for a PCI-compliant file sharing solution, this post will provide you with the essential requirements and compliance strategies. A PCI-compliant secure file sharing solution mitigates not just risk of a data breach, but also risk of non-compliance, which can be costly in the near-term (fines and penalties, business disruption, litigation) but also in the long-term (loss of customer trust and brand erosion). The risks of non-compliance therefore are substantial.

Table of Contents

PCI Compliance Overview

The Payment Card Industry Data Security Standard (PCI DSS) is a framework meant to support anyone accepting payments via credit or debit cards. Enforced by a consortium of credit card processors like Visa, Mastercard and American Express, PCI DSS isn’t nationally mandated but instead is an integral part of processing any credit payment.

PCI DSS includes 12 security requirements:

Install and maintain a firewall configuration to protect cardholder data
Do not use vendor-supplied defaults for system passwords and other security parameters
Protect stored cardholder data
Encrypt transmission of cardholder data across open, public networks
Use and regularly update anti-virus software or programs
Develop and maintain secure systems and applications
Restrict access to cardholder information by business need to know
Assign a unique ID to each person with computer access
Restrict physical access to cardholder information
Track and monitor all access to network resources and cardholder data
Regularly test security systems and processes
Maintain a policy that addresses information security for all personnel

Brick and mortar as well as e-Commerce merchants and retailers are often the most concerned about PCI, and other companies that accept payments but who aren’t merchants often will employ third-party payment processors who are themselves PCI compliant. Banks that issue credit cards often outsource the processing of the transactions, and require the highest levels of PCI compliance from the outsourcer.

Cardholder data includes credit card numbers, CVV numbers, expiration dates, information from an EMV chip or magnetic stripe and any personal data about the cardholder. Penalties for non-compliance with PCI can include:

Fines up to and including $100,000 per month until compliance is achieved.
Damage to your merchant account due to non-compliance, which can make it costly, if not impossible, to process card payments.
The negative impact to your merchant account due to fraud or chargeback activity that isn’t caught through compliant technology standards.

These risks and penalties are only PCI-specific. A data breach involving cardholder data would likely draw fines, penalties, and repercussions from other customer, consumer, or citizen data privacy laws like the EU’s GDPR, California’s CCPA, Germany’s BDSG, Canada’s PIPEDA, the UK’s DPA 2018, and many others.

You are still responsible for demonstrating PCI compliance if you use a third-party payment processor, as they are required to demonstrate PCI compliance. That means any secure file sharing, secure file transfer solution you or the processor use to exchange cardholder data must also be PCI-compliant.

How to Achieve PCI Compliance

Becoming PCI compliant is a multi-step process that requires a comprehensive review of your existing systems and processes.

The first step is to identify which payment card types you accept and how the transactions are processed. This requires an assessment of all the different parts of your system, including software, hardware, and networks. Once you know where the sensitive data is stored and how it flows through your system, you can then start to investigate which PCI DSS requirements apply.

The next step is to assess how compliant your existing systems are with the PCI DSS. This usually requires a review of all the hardware, software, and processes that are part of your system. This includes, of course, any system, solution, or application used to share or store credit card data. File sharing examples include Microsoft Outlook and Gmail while file storage examples include Google Drive, Microsoft OneDrive and SharePoint, Box, and Dropbox. It is important to look for any weaknesses in your systems and solutions that do not meet the requirements set by PCI DSS.

Once the review is completed, you can then start to implement any required changes to ensure that your system meets the requirements of the PCI DSS. This can range from upgrading hardware and software to implementing additional security measures, such as firewalls or encryption. You will also need to ensure that you have a data security policy in place, which outlines how you will protect customer data and how to respond to a data breach.

Once all the changes have been implemented, you will need to test and monitor them to ensure that they meet the requirements of the PCI DSS and remain as secure as possible. This is also the time to develop a regular compliance audit schedule to ensure that your system remains compliant in the future.

After you have completed all the steps you need to take to become PCI compliant, you should apply to one of the Payment Card Industry Security Standards Council’s (PCI SSC) accredited organizations. They will assess your system and issue you a Certificate of Compliance if they determine that you are PCI compliant.

Secure File Sharing and PCI Compliance

PCI compliance, as well as other regulatory compliance laws and standards, has forced file sharing software providers to fundamentally rethink file sharing protocols that now prioritize security over functionality and ease of use. These solutions now offer, in varying degrees, comprehensive controls covering encryption and key management, access control, and regular vulnerability assessments. A PCI-compliant secure file sharing solution ensures that cardholder data is stored, processed, and transmitted over a secure network. This offers reassurances to businesses, employees, and customers alike, establishing a secure communication channel for sensitive credit card data.

Secure File Sharing Requirements for PCI Compliance

The requirements for PCI-compliant file sharing systems focus on stringent security protocols. Organizations that fail to meet these requirements could face significant consequences, including fines, litigation, customer loss, and more in the event of a data breach that exposes cardholder data and customers’ personally identifiable information (PII). Let’s take a closer look at some of the secure file sharing requirements for PCI compliance below.

Data Encryption for PCI Compliance

PCI DSS encryption requirements are industry-leading safeguards that companies must implement to protect credit card information when it’s stored and shared. The PCI DSS requirements for encryption are not only complex but also quite nuanced. First, the encryption must be used to protect any data classified as “sensitive authentication data”, which includes any primary account numbers (PANs) or the full magnetic stripe data of the credit or debit card. Additionally, the encryption must meet an approved industry standard, such as AES encryption for data at rest and TLS for encryption of data in motion.

Encryption is also required for any data that is sent over public networks. This means that any data that is sent from one machine to another must be encrypted, as well as any merchants that want to accept payments online. All data must be encrypted when it leaves the point of origin, as well as when it reaches its destination. This includes any data that is stored on any kind of database where customers’ personal information is kept.

Access Controls for PCI Compliance

Another top PCI compliance requirement for secure file sharing solutions is the use of strong access controls. By employing and enforcing role-based permissions and role-based access controls, businesses ensure that only employees with a business need should have access to this sensitive information.

Multi-factor authentication (MFA) further ensures only authorized employees have access to cardholder data to verify the identity of the user. It is also highly recommended that all employees that have access to the database be provided with unique tokens or passwords that must be used to access the database.

Additional Secure File Sharing Requirements for PCI Compliance

Organizations must meet several additional PCI DSS requirements beyond encryption and access controls. These include implementing an incident response plan, bolstering network security, conducting regular audits and security checks, and documenting a detailed information security policy. In addition, businesses should adopt physical security measures to safeguard systems containing cardholder data, require employee awareness training, and properly document all security procedures.

PCI Compliance Challenges

PCI compliance, however, comes with its own set of unique challenges. The complexity and cost associated with building a PCI compliant infrastructure serve as a significant obstacle for many organizations, especially smaller businesses. Also, ensuring regular updates and performing systematic audits per PCI standards can be labor-intensive and time-consuming. In addition, businesses can fall into a trap of complacency or a false sense of security after achieving PCI compliance. It’s essential therefore to understand that PCI compliance is not a one-time endeavor but an ongoing process that requires constant checking and periodic enhancements.

How to Achieve PCI Compliance With Secure File Sharing

Ensuring your secure file sharing solution is PCI-compliant is critical for businesses as it secures cardholder data, mitigates risk, and builds customer trust. Here are some practical steps and strategies businesses should strongly consider in their efforts to achieve PCI compliance with secure file sharing:

Build and Maintain a Secure Network	Create and uphold a secure network. Install robust firewalls that regulate traffic between the public network and the internal network where sensitive data is stored. Require data encryption during transmission to protect cardholder data. Conduct regular software updates and comprehensive scanning for vulnerabilities. Segregate networks and system hardening to fortify your network. Invest in intrusion detection and prevention systems (IDS) that further help in detecting and blocking potential threats.
Protect Cardholder Data	Cardholder data stored in files should be securely encrypted using strong cryptographic measures, ensuring it remains unreadable even if breached. Tokenization can also be utilized to replace sensitive card information with unique identification symbols, while maintaining the essential information without compromising security.
Maintain a Vulnerability Management Program	Conduct regular risk assessments to identify and rectify potential security gaps. Implement effective advanced threat protection (ATP) and antivirus (AV) solutions to protect against malicious programs that can compromise cardholder data.
Implement Strong Access Control Measures	Restrict access to cardholder data to only authorized personnel. Create intricate password policies, implement two-factor or multi-factor authentication, and establish a rigorous process for granting and revoking access rights. Adopt a zero trust security mindset to minimize the number of individuals who have access to sensitive cardholder data.
Regularly Monitor and Test Networks	Regularly monitor and test networks to identify and close any security loopholes promptly. This should include regular audits of all system components, monitoring and analyzing network traffic, and conducting regular penetration testing and vulnerability assessments to identify weaknesses.
Maintain an Information Security Policy	Define roles and responsibilities, procedures for identifying and responding to potential breaches, and standards for maintaining and disposing of cardholder data. Hold regular security awareness training programs to ensure that all staff understand and adhere to these policies.

PCI Compliant File Sharing and Vendor Risk Management

A third-party vendor can provide secure file sharing and storage capabilities that meet PCI while supporting the following:

Secure file sharing: This includes AES-128 or AES-256 encryption for data at-rest and TLS 1.2 or higher for data in-transit.
Audit logging: Comprehensive audit logs provide unbroken evidence of any security event for diagnostic or prevention purposes. Likewise, this gives you additional tools to prove that you are meeting requirements during an assessment or audit.
Firewall protection: PCI DSS requires a firewall to protect access to servers, and your secure file sharing solution should as well, including special protections for sharing across the firewall barrier and protecting cardholder data.
Secure methods of file sharing with external users: PCI-compliant email employs encryption and therefore is a safe and secure channel for sharing cardholder data and other sensitive content in compliance with PCI DSS. Secure web forms, folders, and virtual data rooms (VDRs) can also be used to share cardholder data, assuming they meet PCI requirements.

Kiteworks Helps Organizations Demonstrate PCI DSS Compliance with PCI Compliant File Sharing

The Kiteworks Private Content Network, a FIPS 140-2 Level validated secure file sharing and file transfer platform, consolidates email, file sharing, web forms, SFTP, managed file transfer, and next-generation digital rights management solution so organizations control, protect, and track every file as it enters and exits the organization.

The Kiteworks platform is used by organizations to help them meet a variety of compliance standards and mandates, including PCI-DSS.

FIPS 140-2 certified encryption enhances the security of the Kiteworks platform, making it suitable for organizations that handle sensitive data like payment card information. In addition, end user and administrator activity is logged and is accessible, crucial for PCI-DSS compliance, which requires tracking and monitoring of all access to network resources and cardholder data.

Kiteworks also offers different levels of access to all folders based on the permissions designated by the owner of the folder. This feature helps in implementing strong access control measures, a key requirement of PCI-DSS.

Kiteworks deployment options include on-premises, hosted, private, hybrid, and FedRAMP virtual private cloud. With Kiteworks: control access to sensitive content; protect it when it’s shared externally using automated end-to-end encryption, multi-factor authentication, and security infrastructure integrations; see, track, and report all file activity, namely who sends what to whom, when, and how. Finally demonstrate compliance with regulations and standards like GDPR, HIPAA, CMMC, Cyber Essentials Plus, IRAP, and many more.

To learn more about Kiteworks, schedule a custom demo today.

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