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PCI DSS v4.0 is coming: how to meet its continuous compliance challenges

If your organisation accepts card payments—think Visa, Mastercard, American Express and so on—then you’ll know it has to comply with the Payment Card Industry Security Standards Council’s PCI Data Security Standard version 3.2.1 (PCI DSS v3.2.1).

No ifs. No buts. If your organisation accepts card payments, then compliance is a requirement. And of course so too are the regular—and usually annual—audits that compliance entails.

PCI DSS v3.2.1 came out in 2018. And version 3.2.1 was little changed from version PCI DSS v3.2.0, and indeed version PCI DSS 3.0.0: simply put, within the business world, the standard—and its accompanying audits—are by now well understood.

All change

But in March 2022, the Payment Card Industry Security Standards Council released a new version of the standard: version 4.0—and PCI DSS v4.0 is something of a radical departure from PCI DSS v3.2.1 and earlier PCI standards.

The core PCI DSS v3.2.1 requirements remain, revised for today’s world, today’s technologies, and today’s threats. But a whole new set of requirements have been introduced, reflecting a very different view of what contemporary data security best practice looks like.

The challenge: compliance is still mandatory, and the clock is ticking.  PCI DSS v3.2.1 will be retired on 31 March 2024, after which organisations must immediately move to PCI DSS v4.0 in respect of those core updated aspects of PCI DSS v3.2.1. And they have until a year later—early 2025—to comply with PCI DSS v4.0’s wholly new requirements.

All of which is already focusing minds.

So what is new in PCI DSS v4.0?

Let’s get something straight, at the start.

PCI DSS v4.0 is no cloistered, ivory tower-based, theoretical, and abstract security standard. It’s very much grounded in the real-world thinking.

It was developed with global industry collaboration. Over 200 companies provided detailed feedback—over 6,000 pieces of feedback in total. No fewer than three drafts were sent out for comment.

So in setting out these new requirements, PCI DSS v4.0’s goals very much reflect a direction of travel that is grounded in real-world best practice. And the four goals in question make that clear.

First, to increase flexibility for organisations to use different methods to achieve security objectives, fostering innovation and risk-based security controls. Second, the use of enhanced validation methods and procedures. And third, the promotion of security as a continuous process.

All of which combine to deliver a fourth and final objective: evolution of security practices so as to meet the changing needs of organisations as threats themselves emerge and evolve.

So what must we do?

That’s the question that organisations are asking themselves. And in doing so, they’re focusing on the notion of security as a continuous process, and the move away from periodic audits, which—let’s face it—could often to some extent be stage-managed.

Moving instead to a process of continuous compliance is obviously quite a radical departure. Adding flexibility and enhanced validation methods and procedures to the mix only adds to the challenge.

Yet it’s a necessary challenge if data security practices are to be fit for purpose in an ever-changing threat landscape. The world is not the same place as it was when PCI DSS v3.0 was formulated—which is why organisations must move with the times and embrace PCI DSS v4.0, and do so in good time, rather than in a rush as 2025 approaches.

But how?

As it happens, here at Quod Orbis we know quite a lot about continuous compliance. It’s what we do, and is what our solution—called Continuous Controls Monitoring—delivers.

With Continuous Controls Monitoring, every security control is audited continuously, in real time, using telemetry. Not a sample of controls. Not periodically. Every security control.

Doing so delivers ‘hard’ information that is accurate, definitive, completely non-subjective, and complete. It’s not a PCI assessor’s opinion at a point in time: it’s solid factual evidence, gathered continuously.

And gathered flexibly, as well—so that as threats and technologies evolve, the organisation can respond appropriately, rather than being confined to strictures codified in an out-of-date standard. And those enhanced validation methods and procedures? That’s what Continuous Controls Monitoring is, in short.

Where next?

Want to know more about continuous compliance, and the Quod Orbis approach to it? Check out our recent blog solely on the subject of continuous compliance, here.

Want to know how we might be able to help your organisation transition to PCI DSS v4.0? Then we’d be pleased to assist, so please call Alastair Dickson on 07939 286 006.

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Liam Flavin

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Ekaterina Kuzevanova

Back End Developer -

Mohamed Mohamud

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Juan Morales

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Luke Bakare

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Rutvik Belapurkar

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Jason Wilkes

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Ian Waggott

Consulting Practice Director -

A very experienced and respected Senior Leadership Executive, with over 30 years’ experience in Information Technology, Information/CyberSecurity and Risk. Specialises in delivering business transformation, leading people through change and taking them on a journey to deliver and exceed company expectations. Highly regarded by his peers and colleagues across the globe. A very confident and effective communicator at CXO level, and valued as an expert presenter at numerous worldwide forums  . Across his career been in Senior CISO and leadership positions in Banking, Telco, Network & Utilities, Several UK Government Departments, 

Has extensive Cyber Security, Operational Risk, Compliance and Business Transformation expertise, gained across a broad range of industries. Former Director of Cybersecurity for CGI and CapGemini and Ex CISO for O2.

Will Tonge

Head of Recruitment -

Will has spent the last 9-years embedded in Cyber Security working with global, household names and innovative start-ups.

Passionate about bringing people and technology together, Will has worked in various settings, helping build high-growth organisations across multiple sectors. During this time, he has built an extensive network with access to some of the best talent out there.

Outside of QO, his young daughter keeps him well on his toes!

Shaun Barnes

DevOps Team Lead

Mark Hudson

Non-Exec Director -

Mark works with SMEs and charities to develop strategies to help them grow and access development capital. He is a NED, charity trustee and mentor to a wide range of people. His plural career started in 2017 after 16 years at pwc as a Deals partner working with large corporates and PE houses; at pwc he also ran the Retail and Consumer practice and was Chairman of the pwc UK Supervisory Board. Prior to pwc he was an executive director at Welcome Break and Iceland Group, and a partner at Bain and Company. He trained as an engineer at Imperial College and has an MBA from INSEAD. 

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Eamon Flavin

Non-Exec Director -

Eamon is a highly regarded and massively respected technology career professional as well as serial entrepreneur. He has started, grown and successfully taken to market three technology business.

Genuinely expert in technology, Eamon has enjoyed long-term working relationships with many of the world’s top companies and organisations in finance, banking, government, manufacturing, engineering, technology and the charities sector.

He draws on unparalleled contacts and experience and provides advice, solutions and recommendations, as well as helping respond to emergencies. Eamon has grown in-house and client teams and has a gift for hiring great people.

Peter Martin

Non-Exec Director -

Peter has the ability to do what many fail to and that is to consistently bring together highly professional teams and build a business environment that is supportive, agile, professional and where everyone enjoys coming into the office.

Bringing a unique blend of business acumen and technical knowledge to the role of non-exec director, Peter has already demonstrated his ability to bring an exceptional flair for dealing with complex situations with a clear, considered approach.

Personally, Peter brings humility and a strong moral compass to the team. His disarming and self-deprecating approach wins everyone over.

Anwen Haynes

Head of Marketing -

Anwen has worked in B2B and B2C marketing for over 20 years. From transforming end-to-end customer journeys in retail with strategic customer-centric plans to target driven focused strategies for B2B sales. With extensive experience in digital marketing including SEO, as well as Brand development, she loves to develop a cohesive approach to brand image and communications to drive and develop the business proposition and perception.

Alice Walker

Customer Success Manager -

Alice has worked in the IT industry for 20 years. Starting in Procurement, she moved into Software Asset Management before transitioning into Customer Success Management. Working across a variety of roles for different industries as both a customer and a service provider has given her a great understanding of what makes a great service. She has always been passionate about building and maintaining great customer relationships and helping her customers achieve their goals.

Owain Rowley

Lead Developer -

Owain has spent nearly a decade building software solutions and products within the cyber security sphere for the likes of government entities, large telecommunication companies, banks and card transaction companies.

This level of experience allows him to swiftly identify business and security processes that can be streamlined with automation, increase the efficiency of existing processes, as well as generate insightful data visualisations and models for members of an organisation at each different level.

Ami Penolver

Head of HR & Legal -

Ami is a finance sector career professional, with many years’ experience working in financial services, both in London and throughout the UK. In addition to financial control, she looks after HR and legal for the company.

Being a mother of two also equips her with the basic skills required to manage a senior team of management and technology consultants.

Ami’s sense of balance and perspective is an essential ingredient of the Quod Orbis culture.

Alastair Dickson

Sales Director -

Alastair has spent the last 20 years working in Cyber Security and Risk Management. He is a passionate believer that security solutions should enable a business to take advantage of all the benefits of the digital world, while not putting the organisation’s data or productivity at risk.

Alastair has developed high-performing teams in some of the industry’s most competitive markets and launched new innovative technologies to market.

Being a rugby coach, and also having four sons at home, means he has lots of experience in keeping a passionate team in order but always has time for some fun!

Gary Penolver

CTO -

Gary has 15 years’ experience in senior technology roles, and has already been closely involved in starting and taking two technology companies to market.

Totally comfortable with a fast-moving, state-of-the-art technical landscape, he helps his clients maintain and improve security and compliance.

He has a reputation for delivering pragmatic and easy to maintain solutions – business owners and managers enjoy knowing that the security and compliance is well managed and automated, properly instrumented and reported at a competitive cost point.

Honest, open, unflappable and very social, Gary is trusted by many household-name organisations to protect their, and their client’s data.

Martin Greenfield

CEO -

Martin is an experienced technology and organisational transformation specialist and an excellent, proven leader and communicator in mission-critical operations, particularly in security technology.

Over the past 20 years, multi-billion pound commercial organisations, including global banks, utilities and major investment funds have trusted Martin to transform their operations to meet financial, operational and compliance targets.

Martin optimises operations, managing and transforming operational teams of between 50 and 500 people, to deliver the highest levels of audit compliance, risk management and financial efficiency.

Often working with other major consultancies and suppliers for new global corporate owners or management teams, Martin will help integrate and streamline operations on a global basis.

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