Standard: PCI Data Security Standard (PCI DSS)

Version: 1.0

Date: October 2014

Author: Security Awareness Program Special Interest Group

PCI Security Standards Council

Information Supplement:

Best Practices for Implementing a Security Awareness Program

The intent of this document is to provide supplemental information. Information provided here does not replace or supersede requirements in any PCI SSC Standard.

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Information Supplement • Best Practices for Implementing a Security Awareness Program • October 2014

Table of Contents

1 Introduction………………………………………………………………………………………………………………………………….. 1

1.1 Importance of Security Awareness ………………………………………………………………………………………………… 1

1.2 Intended Audience ………………………………………………………………………………………………………………………. 2

1.3 Terminology ……………………………………………………………………………………………………………………………….. 2

2 Best Practices in Organizational Security Awareness ……………………………………………………………………. 3

2.1 Assemble the Security Awareness Team ……………………………………………………………………………………….. 3

2.2 Determine Roles for Security Awareness ……………………………………………………………………………………….. 3

2.2.1 Identify levels of responsibility …………………………………………………………………………………………………. 3

2.2.2 Establish Minimum Security Awareness …………………………………………………………………………………… 4

2.2.3 Determine the content of training and applicability based on PCI DSS …………………………………………. 5

2.3 Security Awareness throughout the Organization ……………………………………………………………………………. 5

3 Security Awareness Training Content …………………………………………………………………………………………… 7

3.1 All Personnel………………………………………………………………………………………………………………………………. 8

3.2 Management ………………………………………………………………………………………………………………………………. 9

3.3 Specialized Roles ……………………………………………………………………………………………………………………….. 9

3.3.1 Cashier/Accounting Staff ………………………………………………………………………………………………………. 10

3.3.2 Procurement Team ………………………………………………………………………………………………………………. 10

3.3.3 IT Administrators and Developers ………………………………………………………………………………………….. 10

3.4 Define Metrics to Assess Awareness Training ………………………………………………………………………………. 11

4 Security Awareness Program Checklist ………………………………………………………………………………………. 12

Appendix A: Sample Mapping of PCI DSS Requirements to Different Roles, Materials and Metrics ……….. 13

Appendix B: Security Awareness Program Record ………………………………………………………………………………. 20

Acknowledgements …………………………………………………………………………………………………………………………….. 24

The intent of this document is to provide supplemental information. Information provided here does not replace or supersede requirements in any PCI SSC Standard.

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Information Supplement • Best Practices for Implementing a Security Awareness Program • October 2014

1 Introduction

In order for an organization to comply with PCI DSS Requirement 12.6, a formal security awareness program

must be in place. There are many aspects to consider when meeting this requirement to develop or revitalize

such a program. The best practices included in this information supplement are intended to be a starting point

for organizations without a program in place, or as a minimum benchmark for those with existing programs

that require revisions to:

 Meet PCI DSS requirements;

 Address the quickly and ever-changing data security threat environment;

 Reinforce the organization’s business culture.

Establishing and maintaining information-security awareness through a security awareness program is vital to

an organization’s progress and success. A robust and properly implemented security awareness program

assists the organization with the education, monitoring, and ongoing maintenance of security awareness

within the organization.

This guidance focuses primarily on the following best practices:

 Organizational Security Awareness: A successful security awareness program within an organization

may include assembling a security awareness team, role-based security awareness, metrics,

appropriate training content, and communication of security awareness within the organization.

 Security Awareness Content: A critical aspect of training is the determination of the type of content.

Determining the different roles within an organization is the first step to developing the appropriate type

of content and will also help determine the information that should be included in the training.

 Security Awareness Training Checklist: Establishing a checklist may help an organization when

developing, monitoring, and/or maintaining a security awareness training program.

The information in this document is intended as supplemental guidance and does not supersede, replace, or

extend PCI DSS requirements. While all references made in this document are to PCI DSS version 3.0, the

general principles and practices offered here may be applied to any version of PCI DSS.

1.1 Importance of Security Awareness

One of the biggest risks to an organization’s information security is often not a weakness in the technology

control environment. Rather it is the action or inaction by employees and other personnel that can lead to

security incidents—for example, through disclosure of information that could be used in a social engineering

attack, not reporting observed unusual activity, accessing sensitive information unrelated to the user’s role

without following the proper procedures, and so on. It is therefore vital that organizations have a security

awareness program in place to ensure employees are aware of the importance of protecting sensitive

information, what they should do to handle information securely, and the risks of mishandling information.

Employees’ understanding of the organizational and personal consequences of mishandling sensitive

information is crucial to an organization’s success. Examples of potential consequences may include

The intent of this document is to provide supplemental information. Information provided here does not replace or supersede requirements in any PCI SSC Standard.

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Information Supplement • Best Practices for Implementing a Security Awareness Program • October 2014

penalties levied against the organization, reputational harm to the organization and employees, and impact to

an employee’s job. It is important to put potential organizational harm into perspective for personnel, detailing

how such damage to the organization can affect their own roles.

1.2 Intended Audience

This guidance is intended for any organization required to meet PCI DSS Requirement 12.6 to implement a

formal security awareness program within their organization. The guidance is applicable to organizations of all

sizes, budgets, and industries.

1.3 Terminology

Data Loss Prevention (DLP) Scanning: A process of monitoring and preventing sensitive data from leaving

a company environment.

Phishing: A form of social engineering where an attempt to acquire sensitive information (for example,

passwords, usernames, payment card details) from an individual through e-mail, chat, or other means. The

perpetrator often pretends to be someone trustworthy or known to the individual.

Privileged Access: Users who generally have elevated rights or access above that of a general user.

Typically, privileged access is given to those users who need to perform administrative-level functions or

access sensitive data, which may include access to cardholder data (CHD). Privileged Access may

encompass physical and/or logical access.

Social Engineering: As defined by (ISC) 2 : An attack based on deceiving users or administrators at the target

site—for example, a person who illegally enters computer systems by persuading an authorized person to

reveal IDs, passwords, and other confidential information.

The intent of this document is to provide supplemental information. Information provided here does not replace or supersede requirements in any PCI SSC Standard.

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Information Supplement • Best Practices for Implementing a Security Awareness Program • October 2014

2 Best Practices in Organizational Security Awareness

Security awareness should be conducted as an on-going program to ensure that training and knowledge is

not just delivered as an annual activity, rather it is used to maintain a high level of security awareness on a

daily basis.

Protecting cardholder data (CHD) should form part of any organization-wide information security awareness

program. Ensuring staff is aware of the importance of cardholder data security is important to the success of a

security awareness program and will assist in meeting PCI DSS Requirement 12.6.

2.1 Assemble the Security Awareness Team

The first step in the development of a formal security awareness program is assembling a security awareness

team. This team is responsible for the development, delivery, and maintenance of the security awareness

program. It is recommended the team be staffed with personnel from different areas of the organization, with

differing responsibilities representing a cross-section of the organization. Having a team in place will help

ensure the success of the security awareness program through assignment of responsibility for the program.

The size and membership of the security awareness team will depend on the specific needs of each

organization and its culture.

2.2 Determine Roles for Security Awareness

Role-based security awareness provides organizations a reference for training personnel at the appropriate

levels based on their job functions. The training can be expanded upon—and subject areas combined or

removed—according to the levels of responsibility and roles defined in the organization. The goal is to build a

reference catalogue of various types and depths of training to help organizations deliver the right training to

the right people at the right time. Doing so will improve an organization’s security as well as help maintain PCI

DSS compliance. Whether the focus is a singular, holistic, or a tiered approach, the content can be scoped to

meet an organization’s requirements.

All types of roles may not apply to all organizations, and some roles may need to be divided into subsections

to align with responsibilities. This can be modified according to the requirements of the organization.

2.2.1 Identify levels of responsibility

The first task when scoping a role-based security awareness program is to group individuals according

to their roles (job functions) within the organization. A simplified concept of this is shown in Figure 1 on

the following page.

The intent of this document is to provide supplemental information. Information provided here does not replace or supersede requirements in any PCI SSC Standard.

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Information Supplement • Best Practices for Implementing a Security Awareness Program • October 2014

Figure 1: Security Awareness Roles for Organizations

The diagram above identifies three types of roles, All Personnel, Specialized Roles, and

Management. A solid awareness program will help All Personnel recognize threats, see security as

beneficial enough to make it a habit at work and at home, and feel comfortable reporting potential

security issues. This group of users should be aware of the sensitivity of payment card data even if their

day-to-day responsibilities do not involve working with payment card data.

Additional training for those in Specialized Roles should focus on the individual’s obligation to follow

secure procedures for handling sensitive information and recognize the associated risks if privileged

access is misused. Examples of users in this category may include those processing payment cards,

writing applications that process payment cards, building databases to hold CHD, or designing and

building networks that CHD traverses. Each of these specialized roles requires additional training and

awareness to build and maintain a secure environment. Additionally, specific training may be required to

include understanding of PCI DSS and PA-DSS requirements.

Management has additional training needs that may differ from the two previous areas. Management

needs to understand the organization’s security policy and security requirements enough to discuss and

positively reinforce the message to staff, encourage staff awareness, and recognize and address

security related issues should they occur. The security awareness level of management may also need

to include an overall understanding of how the different areas fit together. Accordingly, managers of staff

with privileged access should have a solid understanding of the security requirements of their staff,

especially those with access to sensitive data. Management training will also help with decisions for

protecting the organization’s information.

2.2.2 Establish Minimum Security Awareness

Establishing a minimum awareness level for all personnel can be the base of the security awareness

program. Security awareness may be delivered in many ways, including formal training, computer-based

training, e-mails and circulars, memos, notices, bulletins, posters, etc. The security awareness program

The intent of this document is to provide supplemental information. Information provided here does not replace or supersede requirements in any PCI SSC Standard.

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Information Supplement • Best Practices for Implementing a Security Awareness Program • October 2014

should be delivered in a way that fits the overall culture of the organization and has the most impact to

personnel.

The following diagram depicts how the depth of awareness training should increase as the level of risk

associated with different roles.

Figure 2: Depth of Security Awareness Training

2.2.3 Determine the content of training and applicability based on PCI DSS

Training content can be broken down further to map to applicable PCI DSS requirements. Appendix A

contains a chart listing the high-level requirements of PCI DSS, with examples of roles listed that may

need security awareness training in these control areas. Section 3, Security Awareness Training

Content, contains further information related to training content for the different levels within an

organization.

2.3 Security Awareness throughout the Organization

The key to an effective security awareness program is in targeting the delivery of relevant material to the

appropriate audience in a timely and efficient manner. To be effective, the communication channel should

also fit the organization’s culture. By disseminating security awareness training via multiple communication

channels, the organization ensures that personnel are exposed to the same information multiple times in

different ways. This greatly improves how people remember the information presented to them. Content may

need to be adapted depending on the communication channel—for example, the content in an electronic

bulletin may be different than content in an instructor-led training seminar, even though both have the same

underlying message. The communication channel used should match the audience receiving the training

content and the type of content, as well as the content itself.

The intent of this document is to provide supplemental information. Information provided here does not replace or supersede requirements in any PCI SSC Standard.

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Information Supplement • Best Practices for Implementing a Security Awareness Program • October 2014

Electronic communication methods can include e-mail notifications, eLearning, internal social media, etc. It is

important to target electronic security awareness notifications to the appropriate audience to ensure the

information is read and understood. It is easier for electronic notifications to go unread or ignored by busy

personnel. By targeting the material and communication channel to relevant personnel, the security

awareness team can improve adoption of the security awareness program.

Non-electronic notifications may include posters, internal mailers, newsletters, and instructor-led training

events. In-person security awareness events that involve active participation by personnel can be extremely

effective. Audience size in an instructor-led presentation is important: the larger the group, the greater risk

that content may not be communicated effectively, as individuals may lose focus on the material presented if

they do not feel engaged. Including activities that engage the audience, such as scenario-based activities,

helps ensure the concepts are understood and remembered. For example, a structured social-engineering

exercise will teach personnel quickly how to identify a social-engineering attack and react appropriately.

Internal seminars, training provided during lunch breaks (commonly called “lunch-and-learns” or “brown bag”),

and employee social events are also great opportunities for the security awareness team to interact with

personnel and introduce security concepts. Appendix B provides a list of the common methods to

communicate security awareness throughout the organization.

It is recommended that communication of security awareness be included in new-hire processes, as well as

role changes for existing personnel. Security awareness training may be combined with other organizational

requirements, such as confidentiality and ethics agreements. Each job position in the organization should be

identified based on level of data access required. See Section 2.2, Determine Roles for Security Awareness,

for more information. To ensure that the security awareness team is notified whenever a role identified as

needing security awareness is filled, it is recommended this step be included in the process for all new-

hire/re-classifications. Inclusion in the new-hire/re-classification process ensures the overall training goals are

promoted without reliance on individual organizational units.

Management leadership and support for the security awareness program is crucial to its successful adoption

by staff. Managers are encouraged to:

 Actively encourage personnel to participate and uphold the security awareness principles.

 Model the appropriate security awareness approach to reinforce the learning obtained from the

program.

 Include security awareness metrics into management and staff performance reviews.

The intent of this document is to provide supplemental information. Information provided here does not replace or supersede requirements in any PCI SSC Standard.

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3 Security Awareness Training Content

As discussed in Section 2.2, Determining Roles of Security Awareness, it is recommended training content be

determined based on the role and the organization’s culture. The security awareness team may wish to

coordinate with the appropriate organizational units to classify each role in order to determine the level of

security awareness training required for those specific job duties. This is vital in development of content, as it

is just as easy to “over-train” an employee as it is to “under-train” an employee. In both cases, if information is

not properly absorbed, it could lead to unnecessary organizational risk. Regardless of role, it is recommended

that all staff receive basic security awareness training, developed in accordance with organizational policy. In

addition to general security awareness training, it is recommended personnel be exposed to general concepts

of cardholder data security, to promote proper data handling throughout the organization, according to their

role in the organization.

Training materials should be available for all areas of the organization. Security awareness and training

materials may be developed in-house, adapted from a professional organization’s work, or purchased from a

vendor. There are security awareness vendors that provide prepared materials such as computer-based

training (CBT), posters, and newsletters. For example, PCI SSC and other eLearning vendors offer training on

topics such as understanding PCI DSS, secure password practices, avoiding social engineering, avoiding

malicious downloads, etc.

The following are examples of reference materials that may help in the development of a Security Awareness

Program:

 National Institute of Standards and Technology (NIST) Special Publication 800-50, Building an

Information Technology Security Awareness and Training Program, www.nist.gov

 International Standards Organization (ISO) 27002:2013, Information technology — Security techniques

— Code of practice for information security controls, www.iso.org

 International Standards Organization (ISO) 27001:2013, Information technology — Security techniques

— Information security management systems, www.iso.org

 COBIT 5 Appendix F.2, Detailed Guidance: Services, Infrastructure and Applications Enabler, Security

Awareness, www.isaca.org/cobit

Additionally, due to the increased focus on cyber security awareness, many government agencies and

industry bodies provide training materials to the public at no cost.

Choosing which materials to use in a security awareness training program is highly dependent on the

organization. Each organization should consider the time, resources, and culture when selecting the materials

to use for the security awareness training. Please see “Training Materials” in Appendix A for more

information and examples. All best practices listed here may be included in an organization’s security

awareness program; however, the best practices are not a requirement.

The intent of this document is to provide supplemental information. Information provided here does not replace or supersede requirements in any PCI SSC Standard.

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3.1 All Personnel

It is recommended that general security training for all personnel include defining what constitutes cardholder

data (CHD) and sensitive authentication data (SAD) and the organization’s responsibility to safeguard both. A

high level overview of the importance of the PCI DSS may also be included; to ensure personnel fully

understands the purpose behind an organizational policy to safeguard cardholder data. To ensure all

personnel are engaged stakeholders in the security awareness program, the roles and responsibilities of all

staff to protect CHD and SAD should be outlined during all security awareness training, in accordance with

organizational policy.

Because data is at risk both in electronic form and in non-electronic (paper) form, it is recommended that the

different ways to safeguard information for different media be covered at a basic level for all personnel. For

instance, considerations for protecting data in electronic format may include secure storage, transmission and

disposal. Considerations for paper-based formats may also include secure storage and disposal as well as a

“clear desk” policy. Without an understanding of how different media types need to be protected, personnel

may inadvertently handle data in an insecure manner.

Another important consideration for inclusion in general security training is awareness of social engineering

attacks. One way an attacker may use social engineering is to acquire a user’s credentials and work their way

through the organization from a low-security area to a high security area. Tailoring this awareness to reflect

the types of attacks that the organization may encounter provides the most effective results. Users should be

aware of the common methods by which fraudsters, hackers or other malicious individuals might try to obtain

credentials, payment card data, and other sensitive data, to minimize the risk of personnel unintentionally

disseminating sensitive information to outsiders. Training in organizational policies and procedures that

specify proper data handling, including sharing and transmission of sensitive data, is also recommended.

The training program should require personnel to acknowledge they have received and understand the

content being delivered. This is crucial to the success of the security awareness program. If content is being

delivered and not understood, the employee may still inadvertently put the organization’s information at risk.

Feedback on training content and comprehension are key to ensuring personnel understand the content and

the organization’s security policies.

Below is an example of content that is commonly included in general security awareness training:

 Organization’s Security awareness policy

 Impact of unauthorized access (for example: to systems or facilities)

 Awareness of CHD security requirements for different payment environments

 Card present environments

 Card-not-present environments

 Phone (individual or call center)

 Mail

 Fax

 Online (eCommerce)

 Where to get further information on protecting CHD in the organization (for example, security officer,

management, etc.)

The intent of this document is to provide supplemental information. Information provided here does not replace or supersede requirements in any PCI SSC Standard.

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 Importance of strong passwords and password controls

 Secure e-mail practices

 Secure practices for working remotely

 Avoiding malicious software – viruses, spyware, adware, etc.

 Secure browsing practices

 Mobile device security including BYOD

 Secure use of social media

 How to report a potential security incident and who to report it to (see PCI DSS Requirement 12.10)

 Protecting against social engineering attacks

 In Person – Physical Access

 Phone – Caller ID Spoofing

 E-mail – Phishing, Spear Phishing – E-mail Address Spoofing

 Instant Messaging

 Physical security

 Shoulder Surfing

 Dumpster Diving

NOTE: General security awareness training should be implemented even for organizations that outsource all

payment acceptance and processing, to ensure personnel are aware that sensitive information, including

CHD, must be protected.

3.2 Management

In addition to content for all personnel, management training should include more detailed information

regarding the consequences of a breach to management stakeholders. Management should understand not

only the monetary penalties of failing to safeguard CHD, but also the lasting harm to the organization due to

reputational (brand) damage. This factor is often overlooked when organizations outsource payment

processing, but is critically important.

As previously discussed, management will need to understand security requirements enough to discuss and

reinforce them, and encourage personnel to follow the requirements. It is recommended that management

security awareness training include specific co