Azure Portal & PCI DSS Compliance

TL;DR

The Azure portal itself is generally not directly in scope for PCI DSS compliance. However, the resources you manage *through* the portal (like virtual machines storing cardholder data) absolutely are. You need to focus your PCI DSS efforts on those resources and how they’re configured.

Understanding the Scope

PCI DSS focuses on protecting Cardholder Data Environment (CDE). The Azure portal is a management interface; it doesn’t store, process, or transmit cardholder data directly. Think of it like this: your bank uses a website to let you manage your account – the website isn’t storing your PIN, but it *gives access* to systems that do.

Steps to Ensure PCI DSS Compliance in Azure

1. Identify CDE Components: The first step is knowing what resources within Azure fall into the scope of PCI DSS. This includes:
• Virtual Machines (VMs)
• Databases (SQL, Cosmos DB etc.)
• Storage Accounts
• Networking components (virtual networks, network security groups)
• Key Vaults (if storing encryption keys for cardholder data)
2. Azure Security Center/Microsoft Defender for Cloud: Use Azure’s built-in security tools to identify vulnerabilities and misconfigurations. Defender for Cloud provides PCI DSS assessments.

   # Example - view PCI DSS recommendations in the portal

3. Network Segmentation: Isolate your CDE from other systems using network security groups (NSGs) and Azure Firewall. Limit access to only necessary ports and protocols.
   • Create NSGs with strict inbound rules allowing traffic only from trusted sources.
   • Use Azure Firewall to control outbound traffic.
4. Access Control: Implement strong role-based access control (RBAC) to limit who can access CDE resources.

   # Example - Assigning a contributor role to a user

5. Encryption: Encrypt cardholder data both in transit and at rest. Use Azure Key Vault for managing encryption keys.
   • Enable disk encryption on VMs storing cardholder data.
   • Use TLS/SSL for all network communication.
6. Monitoring & Logging: Enable logging and monitoring to detect suspicious activity. Send logs to a secure central location.

   # Example - Configure diagnostic settings for a VM

7. Vulnerability Management: Regularly scan your CDE components for vulnerabilities using tools like Microsoft Defender Vulnerability Management or third-party scanners.
   • Schedule regular vulnerability scans.
   • Remediate identified vulnerabilities promptly.
8. Regular Audits: Conduct regular security audits to ensure compliance with PCI DSS requirements. Review Azure configuration and logs.

   # Example - Exporting activity logs for audit purposes

The Portal Itself

While the portal isn’t directly in scope, consider these points:

• Multi-Factor Authentication (MFA): Enforce MFA for all users accessing Azure, including those managing CDE resources.
• Privileged Access Management: Use Privileged Identity Management (PIM) to grant just-in-time access to privileged roles.