Seven Tips to Avoid PCI Audit Fatigue

When it comes to your business, choosing the right, knowledgeable partner can make all the difference in preventing audit fatigue.

Audit
PCI
Auditor Tips
Seven Tips to Avoid PCI Audit Fatigue

During SecurityMetrics’ 20+ years in the audit industry, our team of experienced professionals has collected some helpful tips, tricks, and resources to help you and your compliance staff avoid audit fatigue. 

1. Find an Excellent PCI DSS Compliance Partner

When it comes to your business, choosing the right, knowledgeable partner can make all the difference in preventing audit fatigue. Not every PCI DSS Compliance Partner’s quality of service is equal. Asking your industry peers who they recommend is always the best place to start. Many of your industry peers will consistently tell you that if you are able to leverage the 20+ years of experience from SecurityMetrics PCI Assessors, then you can potentially minimize the effects of audit fatigue. 

A good PCI DSS Compliance partner will prioritize relationship building and, it’s something you should be actively seeking in a PCI assessor. You will experience this firsthand during your assessment with SecurityMetrics. Our team will go above and beyond to answer your questions intelligently, thoughtfully, and empathetically prior to the engagement. Relationship-building PCI assessors will encourage conversations that move the needle and audit process along at a “hummingly” comfortable pace. 

The better PCI Compliance partners will also keep the conversation and dialogue flowing after your assessment too. This should include returning your phone calls timely throughout the year so you are better prepared for your next PCI audit.  This is the SecurityMetrics PCI difference, where your business receives white-glove service and experience with competitive pricing.

Of course, industry credentials matter, too. Credentials like CISSP and QSA are important for establishing a baseline of credibility. However, credentials can only help you so far. To avoid audit fatigue, you really want a PCI assessor who has firsthand experience in your specific industry, sector, or business environment. 

Finding a good PCI partner requires time, patience, and a thorough screening of potential PCI assessors to partner with. Ideally, the better PCI assessors have a “holistic approach” that goes beyond PCI to also include a bigger picture. A great PCI assessor will provide you with ideas and pathways for areas of improvement around cybersecurity, IT environments, SaaS, Cloud, OT, or maybe even physical security. A great PCI partner is committed to making sure your total environment is better secured to fight against these modern threat actors. 

“For every minute spent organizing, an hour can be earned” -Anonymous

The more organized and prepared you are, the more you can potentially minimize your audit fatigue. Staying organized and prepared is a continual process that occurs throughout the year. Here is a short list of preparations you may want to consider, including: 

2. Stay up-to-date

PCI DSS 4.0.1 standard has arrived. Adapting to these changes requires knowledge. When you have that knowledge, then you can ask your PCI assessor better questions. The latest standard requires your business to adapt to changes in new technologies, threats, and risks. Make sure you're following the latest requirements. 

To help you with the latest changes, SecurityMetrics has released our annual PCI Guide, now in its 9th edition, which can be found on our website for FREE.

3. Educate and motivate your staff: 

There can be a perception that PCI assessments are hard, boring, or something worse.
But once you are armed with knowledge and education, you can then share this information with your staff. You can motivate and encourage them to develop their own PCI questions prior to the Assessment. Encourage them to read our PCI Guide 9th edition.

Do not forget to educate your employees about your security policies, procedures, and best practices.

4. Preparation starts with documentation: 

An old CISO quote comes to mind, “If it’s not written down, then it doesn't exist.”  Documentation is a difficult task for ANY sized business. The effects of audit fatigue are magnified when you cannot find the documentation required for the PCI assessor. Proper documentation serves to protect your business by keeping your security processes, policies, and best practices in clear order. 

Regularly reviewing and updating documentation throughout the year keeps your audit ahead of the PCI game. 

Remember– it is this security documentation that will help your PCI assessors see what security measures you’ve already established. 

Know Your Network Architecture: 

When you or a staff member can speak knowledgeably about your entire network infrastructure, then you can minimize audit fatigue. 

This goes beyond maintaining updated and accurate network diagrams. Accurate diagrams are important for showing how your systems interact with card data. What really matters is ensuring your team can accurately explain how all systems in your networks store, process, or transmit card data. 

A great way to stay ahead of any PCI audit task is to create a diagram that shows how a cardholder enters, stays, and then exits your network environment. 

Don’t forget you will want to make a diagram for each card flow that exists. 

Risk Assessments - start early: 

While this is a requirement for PCI compliance, risk assessments can create a majority of your audit fatigue. This is because network environments are nearly always changing as the “goalposts” always seem to move. Your risk assessment helps you identify your organization's vulnerabilities and threats. Get started early on your scans so you can begin the process of remediation. 

Know your third-party compliance: 

Assessing your third parties can also contribute to audit fatigue. This is especially true when you try to contact your third party to have security questions answered, but they don't answer or return communications in a timely manner. 

Audit fatigue is very real when it comes to verifying that your third parties are compliant.

5. PCI Preparation on Purpose

Audit fatigue can be greatly reduced with two specific tools. Good PCI Audit Partners will generally offer clients a simple-to-follow preparation checklist and easy-to-use PCI portal, along with many other optional resources to minimize that fatigue. 

SecurityMetrics PCI IT Checklist

This is jam-packed with a timeline and specific steps to take at every point in the audit process.
For example, our pre-assessment phase timeline includes activities for you and your team to accomplish one year before, nine months before, six months, three months, one month, and right up to two weeks before the assessment. 

Our timeline and checklist include activities to do during the 1-3 weeks onsite and post-assessment phase.

PCI Portal: 

Many PCI audit partners provide access to their very own PCI portal. SecurityMetrics offers an audit portal that provides access to all the documentation you will ever need during the audit process. PCI Portals ensure your team can begin collecting the required documentation BEFORE your audit even begins! 

Another feature of good PCI Portals should include the option to securely store past SAQ questions, answers, and historical data. You want to avoid future audit fatigue to help make next year’s PCI audit that much easier. 

SecurityMetrics PCI Portal offers both of these features. 

6. Build Executive Buy-in first, then Team Support

Some businesses have an entire team that oversees PCI compliance, while other environments have a single person running their entire PCI show. Audit fatigue can happen regardless of the size, scope, scale, or resources of the team. No matter what your situation is– you need executive buy-in. Ideally, an Executive sponsor at the business level who prioritizes becoming PCI Compliant as a business-critical need. The executive sponsor should receive updates while also helping hold people accountable for the achievable PCI marathon. 

SecurityMetrics PCI Assessors and coordinators routinely work with empathy to help businesses manage their entire PCI process. Even if you are the one tasked with overseeing your company’s PCI assessment, it doesn’t mean that you need to take on the whole responsibility yourself. 

Your PCI Partner should provide resources, ideas, and checklists going above and beyond your expectations whenever possible. This sort of support can help you ensure tasks are divided evenly or assigned to different stakeholders who know their department and documents better than you do.

7. Assessments are Marathons, Not Sprints

Assessment expectations are one of the more challenging parts of any PCI audit. The audit fatigue comes in faster and harder when expectations do not meet reality. Oftentimes this happens because the PCI Partner will over-promise and under-deliver. Sometimes it can happen when the client potentially has an alternative perception of reality regarding what the audit process should be like. These kinds of situations can create potential emotional vacuums, leading to more stress, fatigue, and generate cognitive dissonance. 

An achievable assessment timeline should be your ultimate goal. You and your PCI partner should set expectations early and ideally in writing. You want an achievable timeline that fits within the needs of the business operations, staff resources, and budget. Be sure to work closely with your audit team and coordinator to make sure there are no gaps in communication. When gaps do occur, all sides should work together to over-communicate. One helpful feature of the SecurityMetrics PCI portal is the ability to communicate with your team and have those messages saved and shared with everyone involved. You can also automate tasks where you’re able to (logging, scanning, etc.) to help save time. 

Final tips on minimizing audit fatigue by leveraging relationships

The beginning of this article stressed the importance of prioritizing good relationship-building to minimize audit fatigue. 

When selecting a PCI audit partner, research and use your established peer relationships to ask for recommendations. The relationship building continues after you select your PCI audit partner, too. 

Then, once the audit is complete, the post-assessment phase requires relationship building for remediation and report delivery. 

SecurityMetrics, Inc. is proud to have been building relationships for over 20+ years, and we look forward to potentially being your next PCI partner. 

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