PCI DSS COMPLIANCE AND WHY IT IS NECESSARY FOR CREDIT CARD INDUSTRY
Mr. Ishan Kumar Rai
Intern,CyberPeace Foundation
PUBLISHED ON
Dec 24, 2022
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Introduction
The whole world is shifting towards a cashless economy, with innovative payment transaction systems such as UPI payments, card payments, etc. These payment systems require processing, storage, and movement of millions of cardholders data which is crucial for any successful transaction.
And therefore to maintain the credibility of this payment ecosystem, security or secure movement and processing of cardholders data becomes paramount. Entities involved in a payment ecosystem are responsible for the security of cardholders data. Security is also important because if breaches happen in cardholders data it would amount to financial loss. Fraudsters are attempting smart ways to leverage any kind of security loopholes in the payment system.
So these entities which are involved in the payment ecosystem need to maintain some security standards set by one council of network providers in the payment industry popularly known as the Payment Card Industry Security Standard Council.
Overview of what is PCI and PCI DSS Compliance
Earlier every network providers in the payment industry have their own set of security standards but later they all together i.e., Visa, Mastercard, American Express, Discover, and JCB constituted an independent body to come up with comprehensive security standards like PCI DSS, PA DSS, PCI-PTS, etc. And these network providers ensure the enforcement of the security standards by putting conditions on services being provided to the merchant or acquirer bank.
In other words, PCI DSS particularly is the global standard that provides a baseline of technical and operational requirements designed to protect account data. PCI DSS is a security standard specially designed for merchants and service providers in the payment ecosystem to protect the cardholders data against any fraud or theft.
It applies to all the entities including third-party vendors which are involved in processing storing and transmitting cardholders data. In organization, even all CDE (Card Holder Data Environment) including system components or network component that stores and process cardholders data, has to comply with all the requirements of PCI compliance. Recently PCI has released a new version of PCI DSS v4.0 a few months ago with certain changes from the previous version after three years of the review cycle.
12 Requirements of PCI DSS
This is the most important part of PCI DSS as following these requirements can make any organization to some extent PCI compliant. So what are these requirements:
Installing firewalls or maintaining security controls in the networks
Use strong password in order to secure the CDE( Card holders data environment)
Protection of cardholder data
Encrypting the cardholder data during transmission over an open and public network.
Timely detection and protection of the cardholders data environment from any malicious activity or software.
Regular updating the software thereby maintaining a secure system.
Rule of business need to know should apply to access the cardholders data
Identification and authentication of the user are important to access the system components.
Physical access to cardholders data should be restricted.
Monitoring or screening of system components to know the malicious activity internally in real-time.
Regular auditing of security control and finding any vulnerabilities available in the systems.
Make policies and programs accordingly in order to support information security.
How organization can become PCI compliant
Scope: First step is to determine all the system components or networks storing and processing cardholders data i.e., Cardholders Data Environment.
Assess: Then test whether these systems or networks are complying with all the requirements of PCI DSS COMPLIANCE.
Report: Documenting all the assessment through self assessment questionnaire by answering following questions like whether the requirements are met or not? Whether the requirements are met with customized approach.
Attest: Then the next step is to complete the attestation process available on the website of PCI SSC.
Submit: Then organization can submit all the documents including reports and other supporting documents if it is requested by other entities such as payment brands, merchant or acquirer.
Remediate: Then the organisation should take remedial action for the requirements which are not in place on the system components or networks.
Conclusion
One of the most important issues facing those involved in the digital payment ecosystem is cybersecurity. The likelihood of being exposed to cybersecurity hazards including online fraud, information theft, and virus assaults is rising as more and more users prefer using digital payments.
And thus complying and adopting with these security standards is the need of the hour. And moreover RBI has also mandated all the regulated entities ( NBFCs Banks etc) under one recent notification to comply with these standards.
The spread of information in the quickly changing digital age presents both advantages and difficulties. The phrases "misinformation" and "disinformation" are commonly used in conversations concerning information inaccuracy. It's important to counter such prevalent threats, especially in light of how they affect countries like India. It becomes essential to investigate the practical ramifications of misinformation/disinformation and other prevalent digital threats. Like many other nations, India has had to deal with the fallout from fraudulent internet actions in 2023, which has highlighted the critical necessity for strong cybersecurity safeguards.
The Emergence of AI Chatbots; OpenAI's ChatGPT and Google's Bard
The launch of OpenAI's ChatGPT in November 2022 was a major turning point in the AI space, inspiring the creation of rival chatbot ‘Google's Bard’ (Launched in 2023). These chatbots represent a significant breakthrough in artificial intelligence (AI) as they produce replies by combining information gathered from huge databases, driven by Large Language Models (LLMs). In the same way, AI picture generators that make use of diffusion models and existing datasets have attracted a lot of interest in 2023.
Deepfake Proliferation in 2023
Deepfake technology's proliferation in 2023 contributed to misinformation/disinformation in India, affecting politicians, corporate leaders, and celebrities. Some of these fakes were used for political purposes while others were for creating pornographic and entertainment content. Social turmoil, political instability, and financial ramifications were among the outcomes. The lack of tech measures about the same added difficulties in detection & prevention, causing widespread synthetic content.
Challenges of Synthetic Media
Problems of synthetic media, especially AI-powered or synthetic Audio video content proliferated widely during 2023 in India. These included issues with political manipulation, identity theft, disinformation, legal and ethical issues, security risks, difficulties with identification, and issues with media integrity. It covered an array of consequences, ranging from financial deception and the dissemination of false information to swaying elections and intensifying intercultural conflicts.
Biometric Fraud Surge in 2023
Biometric fraud in India, especially through the Aadhaar-enabled Payment System (AePS), has become a major threat in 2023. Due to the AePS's weaknesses being exploited by cybercriminals, many depositors have had their hard-earned assets stolen by fraudulent activity. This demonstrates the real effects of biometric fraud on those who have had their Aadhaar-linked data manipulated and unauthorized access granted. The use of biometric data in financial systems raises more questions about the security and integrity of the nation's digital payment systems in addition to endangering individual financial stability.
Government strategies to counter digital threats
The Indian Union Government has sent a warning to the country's largest social media platforms, highlighting the importance of exercising caution when spotting and responding to deepfake and false material. The advice directs intermediaries to delete reported information within 36 hours, disable access in compliance with IT Rules 2021, and act quickly against content that violates laws and regulations. The government's dedication to ensuring the safety of digital citizens was underscored by Union Minister Rajeev Chandrasekhar, who also stressed the gravity of deepfake crimes, which disproportionately impact women.
The government has recently come up with an advisory to social media intermediaries to identify misinformation and deepfakes and to make sure of the compliance of Information Technology (IT) Rules 2021. It is the legal obligation of online platforms to prevent the spread of misinformation and exercise due diligence or reasonable efforts to identify misinformation and deepfakes.
The Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Amendment Rules 2021 were amended in 2023. The online gaming industry is required to abide by a set of rules. These include not hosting harmful or unverified online games, not promoting games without approval from the SRB, labelling real-money games with a verification mark, educating users about deposit and winning policies, setting up a quick and effective grievance redressal process, requesting user information, and forbidding the offering of credit or financing for real-money gaming. These steps are intended to guarantee ethical and open behaviour throughout the online gaming industry.
With an emphasis on Personal Data Protection, the government enacted the Digital Personal Data Protection Act, 2023. It is a brand-new framework for digital personal data protection which aims to protect the individual's digital personal data.
The " Cyber Swachhta Kendra " (Botnet Cleaning and Malware Analysis Centre) is a part of the Government of India's Digital India initiative under the (MeitY) to create a secure cyberspace. It uses malware research and botnet identification to tackle cybersecurity. It works with antivirus software providers and internet service providers to establish a safer digital environment.
Strategies by Social Media Platforms
Various social media platforms like YouTube, and Meta have reformed their policies on misinformation and disinformation. This shows their comprehensive strategy for combating deepfake, misinformation/disinformation content on the network. The platform YouTube prioritizes eliminating content that transgresses its regulations, decreasing the amount of questionable information that is recommended, endorsing reliable news sources, and assisting reputable authors. YouTube uses unambiguous facts and expert consensus to thwart misrepresentation. In order to quickly delete information that violates policies, a mix of content reviewers and machine learning is used throughout the enforcement process. Policies are designed in partnership with external experts and producers. In order to improve the overall quality of information that users have access to, the platform also gives users the ability to flag material, places a strong emphasis on media literacy, and gives precedence to giving context.
Meta’s policies address different misinformation categories, aiming for a balance between expression, safety, and authenticity. Content directly contributing to imminent harm or political interference is removed, with partnerships with experts for assessment. To counter misinformation, the efforts include fact-checking partnerships, directing users to authoritative sources, and promoting media literacy.
Promoting ‘Tech for Good’
By 2024, the vision for "Tech for Good" will have expanded to include programs that enable people to understand the ever-complex digital world and promote a more secure and reliable online community. The emphasis is on using technology to strengthen cybersecurity defenses and combat dishonest practices. This entails encouraging digital literacy and providing users with the knowledge and skills to recognize and stop false information, online dangers, and cybercrimes. Furthermore, the focus is on promoting and exposing effective strategies for preventing cybercrime through cooperation between citizens, government agencies, and technology businesses. The intention is to employ technology's good aspects to build a digital environment that values security, honesty, and moral behaviour while also promoting innovation and connectedness.
Conclusion
In the evolving digital landscape, difficulties are presented by false information powered by artificial intelligence and the misuse of advanced technology by bad actors. Notably, there are ongoing collaborative efforts and progress in creating a secure digital environment. Governments, social media corporations, civil societies and tech companies have shown a united commitment to tackling the intricacies of the digital world in 2024 through their own projects. It is evident that everyone has a shared obligation to establish a safe online environment with the adoption of ethical norms, protective laws, and cybersecurity measures. The "Tech for Good" goal for 2024, which emphasizes digital literacy, collaboration, and the ethical use of technology, seems promising. The cooperative efforts of people, governments, civil societies and tech firms will play a crucial role as we continue to improve our policies, practices, and technical solutions.
The Expanding Governance Challenge of Artificial Intelligence
Artificial intelligence (AI) systems are increasingly embedded in economic and social infrastructure. They are being adopted in financial services, healthcare diagnostics, hiring systems, and public administration. But while these systems improve efficiency and decision-making, they also introduce new forms of technological risk.
Unlike conventional software, AI systems learn patterns from data and continue to evolve as they run. This poses governance issues since risks can arise throughout the AI life cycle, whether at the coding level or in their implementation.
The latest regulatory frameworks, such as the European Union’s AI Act (EU AI Act) and the UNESCO Recommendation on the Ethics of Artificial Intelligence, note that responsible AI governance depends on the realisation of where risks emerge across the development process.
This article maps the AI system lifecycle, identifies the risks that emerge at each stage and evaluates the policy tools used to mitigate them using the lifecycle framework developed by the Organisation of Economic Co-operation and Development (OECD).
The Lifecycle of an AI System
AI systems are developed through a structured process that includes problem definition, dataset collection and preparation, model development, testing and validation, deployment, and monitoring.
The OECD conceptualises this development process as the AI system lifecycle. Each stage entails various technical and administrative procedures, since choices made during these stages will dictate the goals and limits of an AI system. Further, the quality and representativeness of training sets will have a strong effect on the behaviour of models after implementation.
Since this is an iterative and not a linear procedure, risks can be introduced at each stage of the AI lifecycle. New data can be retrained into different models, and systems are regularly updated once they have been deployed, to address performance degradation, model errors, or unintended outputs. This iterative process means governance must address risks across the entire lifecycle, not just at deployment.
Where AI Risks Emerge
AI risks usually emerge earlier in the development process, especially in the phases when system objectives are formulated and training data are chosen. The EU AI Act and the UNESCO Recommendation on the Ethics of AI outline the following risks: bias and discrimination, privacy and data security violations, the absence of transparency in automated decision-making, and risks to fundamental rights.
AI Governance Risk Landscape: Core Risk Categories Under International Frameworks
Risk categories jointly identified by the EU AI Act and UNESCO Recommendation on the Ethics of Artificial Intelligence
Outlining the risks throughout the AI lifecycle helps understand the areas where governance interventions are most necessary. For example, discriminatory outcomes often result from biased or unrepresentative training data, while safety failures are typically linked to inadequate testing before deployment. Risks such as misinformation arise post the development process, when generative AI systems are deployed at scale on digital platforms.
AI System Lifecycle: Key Risks at Each Stage
Risks identified per the EU AI Act and UNESCO Recommendation on the Ethics of AI
Understanding where risks emerge across the lifecycle explains why governance frameworks classify AI systems by risk and apply oversight at multiple stages.
Policy Tools for Mitigating AI Risks
Governments and international organisations have developed regulatory tools to help mitigate AI risks in the lifecycle. These tools are meant to make sure that AI technologies are identified as up to standard in safety, accountability and fairness prior to and after deployment.
For example, the OECD AI Policy Observatory recommends that governments adopt policy instruments such as risk evaluations, algorithmic auditing necessities, regulatory sandboxes, and transparency necessities of AI systems. The European Union’s Artificial Intelligence Act (AI Act) is one of the most comprehensive systems of governance that introduces a risk-oriented regulation strategy. It mandates adherence to requirements concerning data governance, documentation, human oversight, and robustness, and cybersecurity. Such requirements bring regulatory checkpoints to the lifecycle of AI systems.
Mapping these policy tools across the lifecycle illustrates how governance mechanisms can intervene at different stages of AI development.
Governance Overlay: Policy Interventions Across the AI Lifecycle
Regulatory tools mapped at each stage of AI development per the EU AI Act and UNESCO Recommendation on the Ethics of AI
Several policy tools are directed at the risks that occur in the pre-developmental stages. In one example, algorithmic impact assessment has been applied in various jurisdictions to measure the possible consequences of automated decision systems on society before implementation. On the same note, the requirements of dataset documentation, including dataset transparency requirements and model cards, are aimed at enhancing accountability during the training and development stages of the AI systems. Therefore, lifecycle-based policy design allows regulators to intervene before harmful outcomes occur, rather than responding only after AI systems have caused damage in real-world environments.
The Policy Gap in AI Governance
The misalignment between risks and governance tools across the AI lifecycle indicates a critical structural gap in existing regulations. Numerous governance processes become activated after AI systems are classified as “high risk” or after they are implemented in the real world. But the most serious sources of damage have their roots in earlier stages of the development procedure.
An example is that prejudiced or unbalanced training data is almost inevitably a source of discriminative results in automated decision systems. When these types of models are applied in areas like staffing, credit rating, or in providing services to the public, such biases can quickly spread to large populations and undermine democratic rights. In the same way, the lack of transparency in model design might result in the fact that the regulator or individuals are affected by the decision-making process. This reflects a broader timing gap in AI governance, where risks originate during design and development, but regulatory intervention typically occurs only after deployment.
Analysis
1. Key risks originate before deployment: As depicted in the lifecycle mapping, the data collection and model development phase presents several significant governance risks as opposed to the deployment phase. Structural issues can be entrenched within AI systems even before they are deployed in practice due to bias in data sets, incomplete reporting of training sets, and obscured network designs.
2. Data governance is a primary point of vulnerability: Most of the instances of algorithmic discrimination listed above are associated with training material that is not representative of some population groups or is historical. Since machine learning models are optimisations of patterns that exist in datasets, these biases can be carried through the whole lifecycle and reproduced after deployment.
3. Regulatory approaches remain mismatched across jurisdictions: Different countries adopt varying approaches to AI governance, ranging from risk-based frameworks such as the EU AI Act to more sector-specific or voluntary guidelines in other regions. This divergence creates inconsistencies in safety, accountability, and enforcement standards, allowing risks to persist across borders and potentially undermining the protection of users in globally deployed AI systems.
4. Governance interventions remain uneven across the lifecycle: Whereas the various regulatory instruments aim at deployment and monitoring, fewer instruments systematically tackle the risks that are posed by the previous design and development phases.
Recommendations
1. Introduce mandatory lifecycle risk assessments: The regulatory systems need to demand systemic risk evaluation at the beginning of AI development, especially at the problem design and dataset selection phases. This would assist in detecting possible harmful applications in advance, before systems are constructed and installed.
2. Strengthen dataset governance standards: Training datasets must be supplemented with documentation as to their provenance, composition and limitations. Standardised documentation frameworks of data sets can assist in the discovery by regulators and auditors of the potential sources of bias or privacy threats.
3. Expand independent algorithmic auditing: AI systems can be assessed by regular third-party audits based on fairness, strength, and security weaknesses. The auditing mechanisms especially apply to high-risk systems employed in employment, finance or the public services.
4. Integrate continuous monitoring requirements: AI systems may be monitored regularly after implementation to identify model drift, unforeseen consequences, or abuse. Reporting systems can facilitate the process where the regulators can see the emerging risks and modify the governance systems.
Conclusion - The Need for Global AI Governance
Despite growing regulatory attention, global air governance remains fragmented. Different jurisdictions adopt varying approaches to risk classification, oversight, and enforcement, leading to inconsistencies in safety and accountability standards. Given that AI systems are often developed, deployed, and used across borders, this lack of coordination allows risks to persist beyond national regulatory frameworks.
Addressing these challenges requires a shift towards greater international cooperation and lifecycle-based governance. Developing shared standards, improving cross-border regulatory alignment, and embedding oversight across all stages of AI development will be essential to ensuring that AI systems are safe, transparent, and accountable in a globally interconnected environment.
Recognizing As the Ministry of Electronic and Information Technology (MeitY) continues to invite proposals from academicians, institutions, and industry experts to develop frameworks and tools for AI-related issues through the IndiaAI Mission, it has also funded two AI projects that will deal with matters related to deepfakes as per a status report submitted on 21st November 2024. The Delhi court also ordered the nomination of the members of a nine-member Committee constituted by the MeitY on 20th November 2024 (to address deepfake issues) and asked for a report within three months.
Funded AI projects :
The two projects funded by MeitY are:
Fake Speech Detection Using Deep Learning Framework- The project was initiated in December 2021 and focuses on detecting fake speech by creating a web interface for detection software this also includes investing in creating a speech verification software platform that is specifically designed for testing fake speech detection systems. It is set to end in December 2024.
Design and Development of Software for Detecting Deepfake Videos and Images- This project was funded by MeitY from January 2022 to March 2024. It also involved the Centre for Development of Advanced Computing (C-DAC), Kolkata and Hyderabad as they have developed a prototype tool capable of detecting deepfakes. Named FakeCheck, it is designed as a desktop application and a web portal aiming to detect deepfakes without the use of the internet. Reports suggest that it is currently undergoing the testing phase and awaiting feedback.
Apart from these projects, MeitY has released their expression of interest for proposals in four other areas which include:
Tools that detect AI-generated content along with traceable markers,
Tools that develop an ethical AI framework for AI systems to be transparent and respect human values,
An AI risk management and assessment tool that analyses threats and precarious situations of AI-specific risks in public AI use cases and;
Tools that can assess the resilience of AI in stressful situations such as cyberattacks, national disasters, operational failures, etc.
CyberPeace Outlook
Deepfakes pose significant challenges to critical sectors in India, such as healthcare and education, where manipulated content can lead to crimes like digital impersonation, misinformation, and fraud. The rapid advancement of AI, with developments (regarding regulation) that can’t keep pace, continues to fuel such threats. Recognising these risks, MeitY’s IndiaAI mission, promoting investments and encouraging educational institutions to undertake AI projects that strengthen the country's digital infrastructure comes in as a guiding light. A part of the mission focuses on developing indigenous solutions, including tools for assessment and regulation, to address AI-related threats effectively. While India is making strides in this direction, the global AI landscape is evolving rapidly, with many nations advancing regulations to mitigate AI-driven challenges. Consistent steps, including inviting proposals and funding projects provide the much-needed impetus for the mission to be realized.
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