On February 7, 2013, the Payment Card Industry (PCI) council released a supplement to the payment card industry data security standards (PCI-DSS) on the use of cloud technologies and considerations for maintaining PCI DSS controls in cloud environments.  The supplement is intended for merchants, service providers, assessors, and other entities in evaluating the use of cloud computing in the context of PCI DSS.

The supplement considers “cloud computing” to mean a model for enabling on-demand network access to a shared pool of computing resources (e.g., networks, servers, storage, applications, and services) that can be rapidly provisioned and released with minimal management effort or cloud provider interaction.  Both cloud computing users and cloud service providers (CSPs) have compliance responsibilities under the supplement that depend on a number of variables, including (1) the purpose for which the client is using the cloud service, (2) the scope of PCI DSS requirements that the client is outsourcing to the CSP, (3) the services and system components that the CSP has validated within its own operations, (4) the service option that the client has selected to engage the CSP (Infrastructure as a Service, Platform as a Service, or Security as a Service), and (5) the scope of any additional services the CSP is providing to proactively manage the client’s compliance. 

The supplement provides cloud-related considerations for each of the PCI-DSS standards and allocates responsibility for each consideration between the user and CSP depending on the specific service option.  There are a number of compliance challenges associated with the use of cloud computing, such as the lack of visibility into CSPs’ security infrastructure and oversight of cardholder data storage, and the supplement provides guidance for addressing those challenges within the context of the user-CSP relationship.

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Photo of Mike Nonaka Mike Nonaka

Michael Nonaka is a partner in the firm’s Financial Institutions practice group. He represents banks and other financial institutions on a wide variety of bank regulatory, enforcement, legislative and policy issues.  Mr. Nonaka also is co-chair of the firm’s Fintech Initiative and works…

Michael Nonaka is a partner in the firm’s Financial Institutions practice group. He represents banks and other financial institutions on a wide variety of bank regulatory, enforcement, legislative and policy issues.  Mr. Nonaka also is co-chair of the firm’s Fintech Initiative and works with a number of banks, lending companies, money transmitters, payments firms, technology companies, and service providers on innovative technologies such as big data, blockchain and related technologies, bitcoin and other virtual currencies, same day payments, and online lending.