Overcoming PCI Compliance Challenges in Higher Education

Challenge 1: Decentralized Payment Environments

In a university setting, payment processing often happens in multiple departments and locations – tuition offices, bookstores, dining services, athletic ticketing, alumni donations, research conferences, and more. Each of these units might operate its own payment systems and processes. This decentralized environment means dozens of departments taking payments face-to-face, by phone, or online. The big challenge for university leadership is knowing what every department is doing and whether they’re following PCI DSS requirements. Without centralized oversight, critical security controls can fall through the cracks.

Why it’s problematic: A fragmented payment landscape makes it nearly impossible to enforce consistency and discipline around payment security. One rogue department using an insecure payment app or storing card numbers improperly can put the entire institution at risk. Historically, universities treated each department as a separate “merchant” for PCI compliance, filing individual self-assessments. But banks and card networks are now scrutinizing campus-wide transaction volumes. This means a university is viewed as a single merchant encompassing all departments, raising the stakes for any weak link. Decentralization can also lead to “shadow” payment solutions – where a department bypasses IT to quickly adopt a new payment tool without proper vetting. These unvetted systems may lack security measures, creating compliance blind spots.

Practical solutions: To tackle decentralization, universities should strive to centralize payment oversight and standardize systems across campus. Start by conducting a campus-wide payment systems discovery to map out how every department accepts payments​

Source: arrowpayments.com

​This process uncovers redundant platforms, security gaps, and opportunities to consolidate. Many institutions find that consolidating payment platforms and merchant accounts significantly reduces risk and workload. Where possible, adopt a centralized payment gateway or processor for the whole university, or a few approved solutions, rather than a patchwork of siloed systems. Fewer systems mean fewer points of failure and a smaller compliance scope. If a fully unified system isn’t feasible, at least establish a central treasury or IT oversight team that must approve any new payment technology (no more rogue implementations). Regularly review departmental processes to ensure they align with PCI standards. Networking best practices like segmenting cardholder data environments can further contain risk by isolating payment traffic from the rest of the campus network. Ultimately, the goal is to turn a chaotic “campus-as-merchant” model into a coordinated, secure payments ecosystem.

Challenge 2: Lack of Standardized Policies and Training

Another major hurdle is the absence of university-wide policies and training on payment security. In many colleges, each department developed its own way of handling card data (or possibly no formal process at all). Without a standard policy, one department might routinely email credit card numbers or keep paper forms on file, while another department diligently shreds and deletes such data – a dangerous inconsistency. Inconsistent training exacerbates this issue: if staff aren’t uniformly trained, their understanding of PCI procedures will vary, leading to mistakes and omissions.

Why it’s problematic: Human error is a leading cause of data breaches, and lack of training increases the likelihood of mistakes. For example, an untrained cashier might not realize that writing down a customer’s card details on a Post-it is a violation of PCI rules. Or a department administrator might not know that storing full card numbers in a spreadsheet is forbidden. Over time, these practices create serious compliance gaps. In higher ed, where turnover of student workers and staff is common, consistent training is even more critical – yesterday’s certified cashier might be replaced by a new hire who has never heard of PCI DSS. Without a baseline policy, departments may also view PCI compliance as optional or “someone else’s job.” This lack of shared responsibility and knowledge can lead to missed security steps, ultimately resulting in non-compliance or breaches.

Practical solutions: The foundation here is to establish a comprehensive PCI compliance policy that applies to all departments and campuses of the university. This policy should detail proper handling of cardholder data, forbidden practices (like emailing card numbers or storing unencrypted data), and required security measures (such as using encrypted devices). Many universities model their policies on PCI Security Standards Council guidelines and best practices from peers. Once the policy is in place, mandate regular training for every employee involved in processing or handling payment card data. For instance, require an annual PCI compliance training module – similar to how institutions require workplace safety or harassment trainings. The training should cover key do’s and don’ts: never email or write down card numbers, always use approved devices, restrict access to data on a need-to-know basis, etc. (e.g., only last 4 digits of a card can be stored). Make the training engaging with real-world examples in a university context (like a fictional scenario of a data breach in the bookstore due to improper handling). Standardize procedures by providing checklists and quick-reference guides to departments. Some schools post “PCI Compliance Tips” in offices – much like HR posters – to keep awareness high. Additionally, consider designating a PCI liaison in each department – a person responsible for ensuring their team follows the rules and for communicating with the central compliance team. Regular internal audits or self-assessment questionnaires can help verify that policies are understood and followed everywhere. With clear policies and ongoing training, universities create a culture of security that drastically reduces accidental non-compliance.

Challenge 3: Limited IT and Security Resources

University IT and security teams are often stretched thin. They must maintain complex networks, support thousands of users, and fend off myriad cyber threats – all under tight budget constraints. Ensuring PCI compliance on top of all that can feel overwhelming, especially if there isn’t a dedicated PCI compliance officer or team. Many higher ed institutions have limited staff expertise and budget for payment security, so PCI tasks are added to someone’s already full plate. As one industry webinar noted, finding the right mix of payments expertise, compliance knowledge, and higher ed experience is “no easy task” under budget limitations.

Why it’s problematic: PCI DSS compliance requires meticulous attention to detail – maintaining firewalls, updating antivirus, conducting audits, compiling documentation, and more. Without sufficient personnel or funding, critical compliance steps may be delayed or overlooked. For example, if the IT team is too busy, they might postpone applying security patches or conducting quarterly vulnerability scans – leaving systems exposed. Limited resources also mean the university may lack important tools or technology (like file monitoring systems or intrusion detection) that PCI standards recommend. Furthermore, the PCI DSS itself is regularly updated (e.g., moving from version 3.2.1 to 4.0 with new requirements), and keeping up with these changes demands time and knowledge. An overstretched team might not be aware of new obligations, leading to inadvertent non-compliance. In short, resource constraints make it difficult to sustain compliance year-round, not just during the annual audit.

Practical solutions: Building the business case for PCI compliance is key. University leaders need to understand that compliance is not just an IT cost, but vital insurance against data breaches (which can cost far more in fines, lawsuits, and reputational damage). To secure more budget or staff, translate PCI risks into business terms – for instance, highlight that the average data breach costs $3.92 million, and breaches involving third parties cost even more. Use this data to argue for investment in security tools or additional personnel. If hiring full-time staff isn’t feasible, consider leveraging third-party expertise. Many universities outsource PCI functions or partner with Qualified Security Assessors (QSAs) who can audit systems and recommend fixes. A QSA or consultant can provide an objective gap analysis, essentially augmenting limited in-house resources. Another approach is to reduce the scope of PCI compliance so there’s less to manage internally. This can be achieved by outsourcing payment processing to vendors who are PCI-compliant themselves (for example, using a cloud payment page or a managed payment service). By implementing PCI-validated point-to-point encryption (P2PE) for in-person payments, card data is encrypted at swipe/tap and never traverses campus networks in plaintext – drastically shrinking the environment that IT needs to secure. Likewise, tokenization services can offload storage of card numbers to a secure vault outside the university. Each of these techniques means fewer systems fall in PCI scope, easing the compliance burden. Finally, maximize the impact of the resources you do have: ensure that various departments (finance, IT, procurement) collaborate and align on compliance efforts rather than working in silos. A cross-functional PCI committee can share the load and knowledge. By combining internal advocacy for resources with smart use of technology and third parties, even resource-limited schools can maintain a strong PCI posture.