While annual assessments are a critical component of compliance with the Payment Card Industry Data Security Standard (PCI DSS), these assessments are just one piece of a larger and more complex security compliance picture. Because the threat landscape evolves continuously, checking all the boxes to achieve compliance in April does not guarantee that security practices are up to date and fully protecting sensitive customer information come August. Indeed, PCI DSS mandates a combination of daily, monthly, quarterly, and annual activities to maintain true, continuous compliance. Any organization focused only on the single-point-in-time assessments is putting their compliance—and their customers’ credit card data—at serious risk.  

Compliance is more than a checkbox; it’s a culture. 

A single breach can result in millions of dollars in fines and evaporate customer trust overnight. Still, far too many retailers regularly reprioritize focus and budget dollars away from security efforts. The key to ensuring ongoing compliance and avoiding the potentially disastrous consequences of security gaps is to invest in building a culture where PCI compliance is viewed as more than a to-do list for the IT department and is, instead, embedded in the day-to-day processes and mindsets of people across different departments. For businesses who embrace this approach, security and compliance are top priorities; everyone understands their role –and the high stakes – in keeping credit card data safe.  

The good news is, shifting the culture toward continuous PCI compliance isn’t as daunting as it sounds. By adopting the following strategies, retailers can create an operating environment where compliance is baked into the day-to-day workflow and viewed as a shared responsibility across the entire organization.  

Combine attitude, effort, tools, and technology to support ongoing compliance  

1. Adopt a proactive mindset. Fostering a culture of security and compliance across the organization starts at the top with executives clearly establishing PCI compliance as an investment in risk reduction and brand protection with a direct impact on customer trust and operational continuity. Clearly communicating the importance of compliance helps engage all departments in doing their part to achieve and maintain it on an ongoing basis. Tactics such as making compliance a standing topic in regular risk and strategic reviews, integrating compliance metrics into executive dashboards, and publicly celebrating compliance successes help the company transition from a one-and-done compliance approach to a mindset of continuous management.
2. Establish real-time security awareness. Organizations are required to actively monitor systems within the PCI environment, an effort that relies on real-time detection, alerting, and response capabilities. It’s important to have a structured and centralized system for continuously observing and detecting activity across the systems that handle cardholder data, including servers, applications, databases, and infrastructure. Ideally, the monitoring framework will include a centralized logging system or a Security Information and Event Management (SIEM) solution that can perform real-time data collection and analysis and automatically alert the right parties if suspicious behavior is detected. These tools can also automate responses, such as isolating systems or blocking IPs, to further improve security posture and limit the potential damage of different types of threats.  
3. Develop a habit of risk detection and remediation. PCI DSS requires companies to run and pass vulnerability scans every 90 days and any time changes are made to the card processing environment or network, such as introducing new card readers or launching a new loyalty program. Missing just one scan can result in non-compliance and potential fines and cause companies to overlook vulnerabilities that open the door to malware or other threats that put information and systems at risk. Companies can leverage managed security services and implement continuous vulnerability scanning to ensure they complete all required scans and address any vulnerabilities in a timely manner. Managed services typically include analyzing findings from each scan as well as support with mitigating any identified risks, including implementing patches or other required fixes.  
4. Empower your team to maintain compliance. Creating a compliance culture means that team members need to have the knowledge and the authority to recognize compliance issues and make informed decisions regarding data security practices. Training is a good place to start, and PCI DSS mandates role-specific compliance training at onboarding as well as annual refreshers for roles including customer service representatives, finance staff, and internal auditors. A retailer’s HR team may work collaboratively with IT and Security to develop this training, and HR often takes the lead when it comes to tracking and reporting training completion by department. HR teams can go beyond simply verifying the training to ensure the content is engaging and to regularly reinforce key compliance concepts and the company’s commitment to ongoing compliance through year-round communications.  

Future-proof your compliance strategy  

Implementing these strategies to create a continuous compliance environment will not only help you pass your next PCI assessment; it will set you up to maintain compliance for the long term because it positions your company to stay a step ahead of emerging threats and remain flexible in securely adopting new payment and compliance technologies. This includes automation and AI, where manual effort and human error can be reduced and your people are enabled to become even more effective at understanding and responding to threats.  

By strategically investing in the right tools, services, training protocols, and, perhaps most importantly, the right mindset, you lay the groundwork for a continuous, thriving, compliance-forward culture that protects your business and your customers. If you need guidance on setting up a sustainable compliance program, reach out to W. Capra’s PCI experts and certified Internal Security Assessors (ISAs) for support. Together, we can build a continuous compliance culture that makes it easy to meet PCI requirements today and well into the future.  

Shelli Moring, VP of Risk & Compliance, and Josh Kennedy, Senior PCI & Security Consultant, at W. Capra are passionate about leading clients through their PCI initiatives. For further discussion, reach out to them at info@wcapra.com. 

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