Cardholder Data Protection: An Overview of PCI DSS

July 17, 2025 | Compliance, Cybersecurity, PCI DSS

The Payment Card Industry Data Security Standard (PCI DSS) was established to promote global adoption of consistent security practices that protect payment account data. It outlines a set of technical and operational requirements aimed at securing cardholder information and mitigating threats within the broader payment ecosystem. Although primarily focused on environments handling payment data, PCI DSS can be applied more broadly to enhance overall security.

Understanding PCI DSS and Its Importance

PCI DSS was established by the PCI Security Standards Council (PCI SSC), which includes major payment card brands including American Express, Discover Financial Services, Mastercard, Visa Inc., JCB International, and UnionPay. The ultimate goal of PCI DSS is to bolster security measures around payment account data to protect the confidentiality of cardholders.

By setting a baseline of technical and operational requirements, PCI DSS helps organizations protect Cardholder Data (CHD) and Sensitive Authentication Data (SAD). This standard is essential for reducing vulnerabilities and preventing data breaches, thereby building trust among consumers and stakeholders.

Key Components of Cardholder Data

CHD encompasses critical information such as a payment card’s 15- or 16-digit Primary Account Number, cardholder name, expiration date, and the service code used for magnetic stripe processing.

SAD, on the other hand, includes full track data (magnetic stripe data or chip equivalent), the Card Verification Code/Value (CVC/CVV), and PINs/PIN blocks. Both CHD and SAD require stringent protection measures to prevent unauthorized access and misuse.

The 12 core requirements of PCI DSS serve as a framework to help organizations secure cardholder data and maintain compliance. These include: installing and maintaining firewalls, removing vendor default settings, protecting stored cardholder data, encrypting payment data in transit, keeping antivirus software up to date, deploying secure systems and apps, limiting access to cardholder data, assigning unique user IDs, monitoring network access, regularly testing systems and processes, and maintaining a robust information security policy. 

With each iterative DSS update, such as the release of PCI DSS 4.0 in 2022, these core requirements remain but have been updated and expanded to reflect modern security practices and offer clearer guidance on implementing effective security controls. These updates inevitably generate some confusion, which is often addressed by the PCI SSC on the official PCI DSS FAQ.

Who Needs to Comply with PCI DSS?

PCI DSS compliance may be mandatory for any entity that stores, processes, or transmits CHD and/or SAD. This includes merchants of all sizes, service providers, and any other organizations that could impact the security of CHD/SAD.

Merchants are categorized into four levels based on their annual transaction volume with major card brands:

  • Level 1 includes those processing 6 million or more transactions per brand (2.5 million for American Express, 1 million for JCB) and requires a Report on Compliance (ROC) and an external vulnerability scan. 
  • Level 2 covers merchants with over 1 million but up to 6 million transactions (50,000 to 2.5 million for Amex, under 1 million for JCB) and requires a Self-Assessment Questionnaire (SAQ) and possibly an external scan. 
  • Level 3 applies to merchants processing 20,000 to 1 million transactions (10,000 to 50,000 for Amex) and also requires an SAQ and external scan if applicable. 
  • Level 4 includes all others, who must complete an SAQ and, if applicable, an external vulnerability scan.

Even merchants that fully outsource CHD collection and processing must comply with PCI DSS, as must service providers that affect the security of environments containing CHD. Compliance helps ensure all parties involved in the payment processing chain adhere to robust security standards.

Types of PCI DSS Assessments

The type of PCI DSS assessment an entity undergoes depends largely on its role and the volume of transactions it handles annually. SAQs allow entities to self-attest their compliance, but often, customers or acquiring banks require an independent assessment by a PCI DSS Qualified Security Assessor (QSA), like BARR Advisory.

While face-to-face and e-commerce merchants are eligible for different types of SAQs, service providers generally complete an SAQ D Service Provider. All entities, regardless of their role, are eligible for the more comprehensive ROC. The acquiring bank, customer entities, and payment card brands determine the specific type of assessment required.

How to Get Started

With BARR Advisory’s PCI DSS compliance services, organizations can navigate the complexities of compliance by following our proven process:

  1. Define Scope: Clearly document your cardholder data environment, identifying where cardholder data is processed, transmitted, and stored.
  2. Assess Compliance: Conduct self-assessments, readiness assessments, and engage a QSA to evaluate your organization’s adherence to PCI DSS requirements.
  3. Remediate: Address identified vulnerabilities and non-compliance issues by implementing necessary security measures and controls.
  4. Validate: Complete and submit all required documentation and compliance reports for official validation.
  5. Monitor and Update: Continuously monitor security controls, perform regular security testing, and update measures to counteract new threats.

Achieving PCI DSS compliance offers multiple advantages. It ensures the protection of customer data, thereby fostering trust and confidence among stakeholders. Compliance also helps organizations meet business and regulatory requirements, avoiding potential fines and penalties. 

Interested in learning more about PCI DSS  compliance? Contact us today to get started.

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