Recent high-profile credit card data breaches have prompted an upsurge in media coverage of PCI DSS - a data security standard that applies to anyone to stores, processes or transmits cardholder information. Infamously there was the Heartlands System breach, where unauthorised persons hacked into Heartlands computer network. The attackers gained access to confidential financial data associated with approximately 130 million credit and debit cards. At the time the data breach occurred Heartland were officially recognised as PCI DSS compliant and were listed on the PCI Data Security Standards website. This case reminds us of course that PCI compliance is achieved at a snapshot in time i.e. when the audit occurs. 

Of course, the compromised cards were reissued and the financial institutions which had issued those cards incurring significant costs as a result of this breach. Records from the court filing on the resulting case against Heartland by those institutions are now publicly available. The filing gives some insight into how PCI DSS compliance was viewed by Heartland. According to the courts filing Heartland conducted a private webinar for its high level employees, sales representatives and relationship managers on the day after the breach was discovered. During this webinar managers were told that "PCI compliance was not a big deal". 

According to the court filing Visa's Chief Enterprise Risk Officer, Ellen Richey reportedly said that the Heartland Data Breach would not have occurred had the company been vigilant about maintaining PCI compliance. Heartland may have held a PCI Compliance certificate at the time the breach occurred but, as this illustrates this only signifies compliance at audit time. The problem is a lack of ongoing vigilance in maintaining a compliance standard. It is not simply enough to achieve PCI DSS Compliance to pass inspection, the true test is maintaining the standard at all times. In order to do this security must be a priority for the organisation who must understand its importance and aspire to exceed the standards set down by the PCI Security Standards Council (PCI SSC).

Dave

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