On June 14, 2011, the PCI Security Standards Council’s Virtualization Special Interest Group published its “Information Supplement: PCI DSS Virtualization Guidelines”(the “Guidelines”) to Version 2.0 of the PCI Data Security Standard (“PCI DSS”). The Guidelines provide context for the application of the PCI DSS to cloud and other virtual environments, and offer at least three critical reminders:
- the PCI DSS applies to cloud environments without exception;
- critical analysis of the application of the PCI DSS to rapidly evolving cloud offerings is essential to compliance; and
- cloud providers must be prepared to document and contract for necessary controls.
