WEBVTT

00:00:01.909 --> 00:00:05.545
The last requirement in all of the 12 PCI DSS

00:00:05.545 --> 00:00:07.909
requirements concerns policies and procedures,

00:00:07.909 --> 00:00:10.909
and that's what requirement 1.5 demands.

00:00:10.909 --> 00:00:11.337
Simply,

00:00:11.337 --> 00:00:16.766
an organization has to have written security policies and any associated

00:00:16.766 --> 00:00:22.909
operational procedures or processes as required by PCI DSS.

00:00:22.909 --> 00:00:24.909
The policies need to be documented,

00:00:24.909 --> 00:00:26.909
they need to be available to anyone who needs to use them,

00:00:26.909 --> 00:00:29.370
they need to be kept up to date,

00:00:29.370 --> 00:00:33.909
and they also very clearly need to be in use by the organization.

00:00:33.909 --> 00:00:36.909
In previous versions of PCI DSS,

00:00:36.909 --> 00:00:38.909
this was actually all in requirement 12 at the end.

00:00:38.909 --> 00:00:41.242
There was a general overall requirement that said you

00:00:41.242 --> 00:00:42.909
must have policies and procedures.

00:00:42.909 --> 00:00:43.659
But now,

00:00:43.659 --> 00:00:46.409
because it's recognized that different teams are typically

00:00:46.409 --> 00:00:48.337
responsible for each of the different requirements,

00:00:48.337 --> 00:00:51.576
this mandate for policies and procedures is included

00:00:51.576 --> 00:00:52.909
within each requirement separately.

00:00:52.909 --> 00:00:56.909
You'll see it at the end of every single requirement we look at.

00:00:56.909 --> 00:00:59.659
The QSA will want to review all of these policies and procedures,

00:00:59.659 --> 00:01:03.659
and they'll typically ask for these to be sent in advance of an

00:01:03.659 --> 00:01:06.909
assessment so they can read them before they come on site.

00:01:06.909 --> 00:01:10.909
When the QSA is on site, they'll want to make sure the documents are accessible.

00:01:10.909 --> 00:01:12.909
So that means they're going to be looking for them,

00:01:12.909 --> 00:01:13.195
for instance,

00:01:13.195 --> 00:01:15.242
to be on an intranet rather than being printouts and kept

00:01:15.242 --> 00:01:17.909
in the cupboards locked away somewhere.

00:01:17.909 --> 00:01:20.284
They're going to interview people who should be aware of and

00:01:20.284 --> 00:01:22.909
should be using these policies and procedures.

00:01:22.909 --> 00:01:23.909
So they'll ask, where is the policy?

00:01:23.909 --> 00:01:27.909
Show me the procedure you follow when you do something.

00:01:27.909 --> 00:01:29.909
I know that policies and procedures are boring,

00:01:29.909 --> 00:01:33.464
but without them there's no evidence that an

00:01:33.464 --> 00:01:36.909
organization intends to comply with PCI DSS.

00:01:36.909 --> 00:01:39.909
And honestly, in the event of a data breach,

00:01:39.909 --> 00:01:43.242
the lack of policies and procedures is instantly going to put liability

00:01:43.242 --> 00:01:47.159
back to the breached entity because they can't demonstrate they have

00:01:47.159 --> 00:01:50.909
the intention of complying with the standard by having the necessary

00:01:50.909 --> 00:01:52.909
policies and procedures in place.

00:01:52.909 --> 00:01:56.766
We're going to finish this module with a short conversation between Jacob

00:01:56.766 --> 00:02:00.909
and me about personal firewalls and about policies.

00:02:00.909 --> 00:02:04.766
I know you're thinking that there's probably nothing duller than two

00:02:04.766 --> 00:02:06.909
QSAs discussing information security policies.

00:02:06.909 --> 00:02:07.242
Look,

00:02:07.242 --> 00:02:10.659
I promise you we only have this discussion about policies

00:02:10.659 --> 00:02:12.909
once in respect of requirement 1.5.

00:02:12.909 --> 00:02:15.909
So, for the other 11 PCI DSS requirements,

00:02:15.909 --> 00:02:17.909
we're not going to mention them at all.

00:02:17.909 --> 00:02:20.909
And honestly, it's not that boring.

00:02:20.909 --> 00:02:24.909
After the conversation with Jacob, the next module looks at requirement 2,

00:02:24.909 --> 00:02:27.909
which is another infrastructure-focused requirement,

00:02:27.909 --> 00:02:29.909
but this time looking at systems,

00:02:29.909 --> 00:02:32.909
how systems in the cardholder data environment are

00:02:32.909 --> 00:02:38.909
built and configured to be secure.
