The main directive of the Payment Card Industry Data Security Standard (PCI DSS) Requirement 6 is to “develop and maintain secure systems and applications.” At a high level, the requirement seems reasonable and the language in the title is simple and straightforward. Closer investigation, however, reveals a much more complex compliance scenario.
While most of the contents of Requirement 6 are not technically difficult to achieve, maintaining the balance between an eCommerce organization’s business requirements, brand integrity, usability requirements, and security is challenging. It is the responsibility of the development team to weigh the best interests of the organization against its wish list, all while adhering to the best practices and requirements set forth in the PCI DSS standard to protect the organization and its customers.
Requirement 6 affects almost every aspect of the development process, from the planning stage to post-launch maintenance. Some of the provisions of Requirement 6 are very specific in nature and will vary depending on your deployment and development environment, and thus, this article will cover all of the general compliance guidelines.
System Configuration, Maintenance and Security
As with all of the PCI DSS requirements, it is important to consider all of the required accommodations early on and throughout the planning phase. The scope of Requirement 6 reaches beyond code to the configuration of the development and production environments as well as the administration of both.
This includes simple things, such as the requirement in Provision 6.1 that all systems (both production and development servers, as well as all developer workstations) have the latest security patches installed within 30 days of their release (or 90 days if your company’s policy requires roll-out testing); and that all security patches are tested against the vulnerability they fix prior to deployment in a production environment. Provisions 6.3.2-6.3.3 require that production and development environments be completely separate, and that a policy exists to provide a separation of duties, responsibilities and privileges between users with access to either system.
Additionally, specific system vulnerabilities may be addressed in code or as system configuration adjustments. The solution to each will be different for each configuration. Most PCI-certified vulnerability monitoring solutions will provide additional, detailed guidance for each specific instance discovered.
Data encryption seems complicated, and in most cases it lives up to that complexity. This is especially true when encryption requirements go beyond the basics, such as names and passwords, to include highly confidential information like social security numbers, credit card numbers, and protected health information.
For many ecommerce developers, the thought of designing a system to store the credit card data of their clients’ customers is chilling.
