Understanding PCI DSS Requirements for Higher Education Institutions

Requirement 7: Restrict Access to Cardholder Data by Need-to-Know

Plain English: Limit access to sensitive card data to only those people who need it to do their jobs. Not everyone should have free reign to view or use cardholder information. This is about implementing “least privilege” – each user or system gets the minimum access required, no more. If someone doesn’t absolutely require access to card data, they shouldn’t have it.

Higher Ed Application: In a university, many different staff and student workers might be involved in payment processes, but not all of them need full access to cardholder details. For example, a cashier at the dining hall or bookstore swiping a card doesn’t need to see the full 16-digit card number or the card’s security code – the system can mask those details. Only certain roles (perhaps a financial manager or a system administrator) might need the ability to see full card numbers, and even then only in specific cases. Universities should carefully define roles and permissions in their payment systems. The bursar’s office, for instance, may have some staff who can process refunds – to do that they might need to access stored card info or tokenized data. Those staff should have user accounts that grant that specific ability, while other bursar staff who only take payments in person might have accounts that cannot retrieve stored card data at all.

Another example: The alumni relations department might have a donor database that includes some payment information for recurring donations. Only the alumni donation processor team and perhaps a supervisor should be able to see or export that information, and even then, it might be partially masked. IT administrators who support systems should also have limited access – e.g., an IT person might have server admin rights but not the permission to query sensitive cardholder tables unless necessary. Achieving this requires working with software capabilities (most payment systems have user roles) or implementing additional data access controls. It’s also important to regularly review who has access. In a university, staff and student workers come and go or change roles, so a periodic audit (say, every semester) of accounts with card-data access is a good practice. Decentralized departments must coordinate on this principle. The central IT security or compliance team can enforce policies that each merchant department documents who has access to what, and ensures removal of access when someone leaves. By keeping access tightly restricted, the university greatly reduces the risk of internal breaches or accidental exposure. If a faculty member in the biology department has no need to handle credit cards, they should never be granted access to the museum’s gift shop payment system, for example. This sounds obvious, but without oversight, access tends to creep open over time. Requirement 7 essentially forces higher ed institutions to be intentional and sparing with card data access permissions – a key part of protecting that data.

Requirement 8: Identify and Authenticate Users – No Shared Logins

Plain English: Make sure every user has a unique ID and credentials, and verify their identity before allowing access to systems. This means no generic or shared accounts, and use strong authentication methods (passwords, multi-factor authentication, etc.) to ensure the person accessing is who they claim to be. In short: know exactly who is doing what in your system by giving each person a unique login (and secure authentication).

Higher Ed Application: Universities often employ rotating staff, student workers, and volunteers in roles that handle payments (like student cashiers at events or front-desk staff in various offices). It can be tempting to use a single shared login for convenience (for example, one account named “Cashier” that everyone in the bookstore uses on the point-of-sale). PCI DSS prohibits this – each user must have their own unique login ID for any system that touches card data. So the bookstore should create accounts like “cashier_john” and “cashier_jane” rather than everyone using “store_register1.” Unique IDs create accountability and enable proper tracking (later in Requirement 10, we’ll see logging – you want logs to show exactly which user did a transaction or accessed data).

Additionally, strong authentication is critical. Passwords should meet PCI’s complexity and rotation guidelines (e.g. a mix of characters, changed periodically) to prevent guessing or brute force attacks. In the higher ed context, it’s wise to integrate payment system logins with the university’s single sign-on or directory services if possible, so that you can leverage existing security (like campus password policies or 2-factor authentication). Speaking of multi-factor authentication (MFA): PCI DSS v4.0 places a stronger emphasis on MFA, especially for administrators and remote access​

Source: arrowpayments.com

Universities should ensure that any user with access to the cardholder data environment from outside a secure network (for instance, someone logging in remotely to the financial system) uses MFA – typically a password plus a second factor like a mobile app code or hardware token. Even internally, adding MFA for highly privileged accounts (like the server admin who manages the payment database) is increasingly considered a best practice. This is particularly relevant on campus where multiple users often access the same systems and there’s a higher risk of credential sharing or theft if not properly controlled​.

For example, a student employee in the recreation center should log in with their own username and a strong password to access the payment terminal, and if they need elevated privileges, perhaps they must use an MFA device given by the university. When that student graduates or leaves the job, their account should be promptly revoked.

The overarching goal is that the university can identify every individual who interacts with cardholder data systems. By eliminating shared accounts and using robust authentication, if something does go wrong – say a suspicious refund or data query – the institution can trace it to a specific user account rather than a generic login that obscures who was responsible. It also prevents unauthorized use; if “Alice” doesn’t know “Bob’s” password, she can’t accidentally or deliberately use an account she shouldn’t. In summary, higher ed must foster a culture of individual accountability for system access: one person, one account, with strong security around that account.

Requirement 9: Restrict Physical Access to Cardholder Data

Plain English: Physically secure any devices, paper, or systems that contain card data. This means controlling who can get to the computers, servers, filing cabinets, or terminals where cardholder information might be present. Just as you wouldn’t leave a cash register unattended and open, you shouldn’t leave credit card data accessible to anyone walking by. Lock doors, use badges or keys, secure payment terminals, and maintain control over how and where card data is physically handled.

Higher Ed Application: Universities must consider physical security in many contexts – from card readers to printouts. For example, think of a payment terminal at a campus coffee shop or bookstore. It should be secured to the counter to prevent someone from tampering with it or walking off with it. Periodically, staff should inspect these devices for signs of tampering (like skimmers attached). After business hours, those devices (especially mobile ones) should be stored in a locked drawer or office. Now consider offices that handle paperwork containing card data: perhaps the athletics department has paper forms for season ticket purchases, or the continuing education program has registration forms with credit card sections. Such forms should be locked in file cabinets accessible only to authorized staff, and ideally shredded as soon as they’re processed. University mailrooms that handle inbound mail with payment info must have safeguards so that mail is secured until opened by the proper staff.

Data centers and server rooms on campus that store or process cardholder data must also have strict physical access control. This could mean badge access systems that only IT staff or authorized personnel can use, visitors logs, and video surveillance for areas with servers that hold payment information (like the main finance database server). Smaller scale: a bursar’s office computer that is used for processing credit card refunds should not be left logged in and unattended where a passerby could hop on it. Even at the workstation level, ensure screens lock automatically and any printed reports with card data aren’t left on desks. Many universities have campus-wide ID card access systems – leverage those to limit entry to offices handling payments. For instance, only treasury or cashier’s office staff should be able to enter the vault or room where the daily batch of credit card receipts is stored. The key is to prevent unauthorized people from physically accessing anything that could contain card data.

Physical access also extends to media and backups: if you have backup tapes or external drives with cardholder data (perhaps old archives of transactions), those need to be encrypted and locked up, or kept off-site with a secure provider. In a higher ed environment, it’s common to have student employees or interns helping out – ensure that if they are not authorized to handle card data, they’re not left unsupervised in areas where they might inadvertently see it. A practical example: The alumni office runs a phonathon for donations; they print out lists of last year’s donors including partial credit card numbers to reference for updates. Those printouts should be collected at the end of the night and securely shredded – and during the event, only staff involved in the phonathon should be in that room. By enforcing simple physical security measures like door locks, cabinet locks, device tamper seals, and visitor procedures, universities can greatly reduce the risk of old-fashioned theft or accidental exposure of card information. After all, not all data breaches are digital – an unlocked cabinet or an unattended card reader can be just as dangerous.

Requirement 10: Track and Monitor All Access to Card Data and Networks

Plain English: Log everything (within reason) that touches cardholder data or critical systems, and monitor those logs for suspicious activity. This means keeping audit trails of user access, changes, and transactions on payment systems and network resources. If something goes wrong, you should be able to trace who did what, when. Think of it like having a security camera and alarm system for your data – you record activity and review it to catch anomalies.

Higher Ed Application: In a university setting, the IT infrastructure can be sprawling, but any system within the scope of card processing needs robust logging. For instance, if an administrator logs into the campus online payment portal to update a setting, that login event should be recorded. If a cashier reprints a receipt that shows part of a card number, that action should be logged. Databases that store cardholder data should have logs of who queried or retrieved that data. Each department’s payment system might generate its own logs – part of compliance is ensuring those logs are being collected and reviewed. Many universities centralize log management using a SIEM (Security Information and Event Management) system. That can be very useful: logs from the bookstore’s POS, the bursar’s payment gateway, the alumni donation site, etc., can all feed into one place where the security team can monitor for red flags.

What are red flags in this context? For example, multiple failed login attempts on a payment system user account could indicate someone trying to guess a password (and should trigger an alert). Or an account logging in at odd hours or from an unusual location (say, a cashier account used at 3 AM from an off-campus IP) could signal a compromise. The university should define what events are important to monitor – likely things like: access to cardholder data files, creation of new accounts or elevation of privileges on payment systems, changes to firewall or security settings, etc. Then, have a process to review these logs daily or in real-time. This might fall to a central IT security operations team or a designated PCI compliance officer. In smaller departments, it could even be a manual review of logs if automated systems aren’t in place (though automation is highly recommended given the volume of events).

When logs are properly kept, they become invaluable in incident response. Consider a scenario: the campus notices irregular transactions on cards used at the bookstore. With good logs, the security team can quickly check if there were any unauthorized access events on the bookstore’s payment system or if a particular user account was performing strange operations. Without logs, you’d be flying blind. PCI DSS requires not just logging, but also that the logs are secure (so they can’t be easily erased by an attacker) and retained for a certain period (at least a year, with 3 months easily accessible). Universities should ensure that log data, which can be quite large, is being archived – often using inexpensive cloud storage or university data centers.

In summary, monitoring access in higher ed’s cardholder environments means having an “eye” on all systems at all times. It’s a lot to manage manually, so leveraging logging tools is key. But even policy-wise, making sure every application and device is configured to produce logs (and not left at default where logging might be off) is important. It ties back to Requirement 8’s unique IDs: those logs are useful only if we know which individual user is behind an action. Many campuses conduct periodic log reviews as part of their compliance routines, often uncovering small policy violations (like a user trying to access something they shouldn’t) that can be corrected before they become big issues. Logging and monitoring might not prevent an incident by itself, but it ensures that if something happens, you detect it quickly and can take action, minimizing damage.