Published on:
March 12, 2021

The Ultimate Guide to LMS Compliance

A compliance LMS (learning management system) is an online training platform that has features that allow developers to carry out compliance-focused training programs. This blend of features makes it a robust system that can deliver training that is rigid in design and delivery.

Regardless of your industry, there are internal processes, government regulations, and procedures that your business is accountable for. LMS compliance means that your training solution is conformant with government accessibility, data security standards, among others. This offers more safeguards and features.

A compliance LMS (learning management system) is an online training platform that has features that allow developers to carry out compliance-focused training programs. This blend of features makes it a robust system that can deliver training that is rigid in design and delivery.

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LMS GDPR Compliance

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GDPR stands for General Data Protection Regulation. It refers to all data protection for individuals within the European Union (EU). This law applies to all companies that store and process data from users located in the EU.

The law has been valid from May 25th, 2018, and has the purpose of setting parameters that guarantee users’ data safety and increases the rights of personal privacy in all electronic matters. It is important to know all the global laws that govern data management both for those who control and process the information.

Non-compliance to GDPR may attract fines of up to 20 million Euros or 4% of a company’s annual profit.

As an LMS user, if some of your learners are located in the EU, your learning activities could be impacted. Therefore, all the data that is stored in your LMS needs to be compliant with this regulation.

What is Personal Data (GDPR-Related)

Personal data is defined as any information that relates to identified or identifiable natural persons. These entities are called data subjects. An identifiable person is any individual who can be identified directly or indirectly using identifiers such as names, identification numbers, location data, or online identifiers.

They can also be identified in reference to one or more factors relating to the physical, physiological, mental, genetic, social, cultural, or economic identity of that person.

Handling Personal Data Under GDPR

Concerning GDPR, a data subject is an identified or identifiable natural person, to whom personal data are related.

  • A ‘controller’ is a natural or legal person, public authority, agency, or other entity. The ‘controller’, alone or jointly with others, determines the means and purpose of processing the personal data.
  • The ‘processor’ is a natural or legal person, public authority, agency, or other entity which processes data on behalf of the ‘controller.’

The ‘controller’ needs to have an appropriate Data Processing Agreement with any third party it shares data with. The third-party, in this case, is a processor. Controllers and processors are also required to implement various technical and organizational measures (TOMs), including the following:

  1. The encryption of personal data and pseudonymization.
  2. Ongoing confidentiality, integrity, resilience, and availability of processing systems and services.
  3. A process for regularly testing, assessing, and evaluating the effectiveness of TOMs.
  4. Restore the availability and access to personal data promptly during times of physical or technical incidents.

Adopting these measures must be evaluated and should consider contexts that take into account the costs of implementation, the state of the art; the nature, scope, context, and purposes of processing, as well as the likelihood and severity for the rights and freedoms of natural persons.

GDPR also involves the concepts of ‘Privacy by Design’ and ‘Privacy by Default.’ Privacy by design states that organizations need to consider the privacy of individuals at the initial design stages and throughout the development of a product or service that involves processing personal data.

Privacy by default, on the other hand, holds that when a service or system involves choices for an individual on how much personal data they can share with others, the default setting should be designed to be the most privacy-friendly.

In addition, controllers must report any breaches of personal data to the respective supervisory authorities within 72 hours. If there is a high risk to the rights and freedoms of the data subjects, they must also notify the data subjects.

Individual Rights per GDPR

The controller must ensure that the data subject has granted their consent. Data subjects can’t be coerced to consent, or be unaware that they are consenting to any party processing their personal data.

GDPR is an expansion of the 1995 EU Data Protection Directive and enhances the standards for disclosures when requesting consent, which must be ‘freely-given, informed and unambiguous.’

The language used must also be ‘clear and plain’ and is ‘clearly distinguishable from other matters.’ Also, data controllers are required to provide evidence that their processes are compliant and followed in every case where data subjects are requested for their information.

The rights per GDPR are discussed below.

The right of access: Data subjects have the right to access their personal data and other supplementary information. They must also be aware of and verify the legality of the processing.

The right to restrict processing: This allows individuals to request the controller to restrict the processing of their data when some conditions apply.

The right to rectification: The data subject has the authority to request the rectification of inaccurate personal data that concerns them. The individual also has the right to have incomplete personal data completed, including by way of availing a supplementary statement.

The right to object: This allows the data subject to object to the processing of their personal data based on the performance of a task in the public interest, direct marketing, purposes of scientific and historical research and statistics, exercise of official authority, and other legitimate interests.

The right to data portability: This allows the data subject to access and reuse their personal data for their purposes across varying services. They are also permitted to copy, move, or transfer personal data securely and without hindrance to usability, from one IT environment to another.

The right to erasure: This is also referred to as the ‘right to be forgotten.’ It is a principle that defines how an individual can request for their personal data to be deleted or removed. This happens when there is no compelling reason for a business to continue processing that information.

The right not to be subject to automated individual decision-making: Such decisions include those that result in legal or significant effects. This right allows the data subject to prohibit any processing activity that is wholly automated and leads to decisions that significantly impact individuals. Such processing can only be allowed if it can be justified based on one out of three bases spelled out as exceptions under Article 22(2), which talks about ‘the performance of a contract, authorized under law, or explicit consent.’

LMS 508 Accessibility Compliance

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The accessibility standards of Section 508 of the Rehabilitation Act can be a source of anxiety, confusion, and frustration for instructional designers. If such issues are not handled from the onset, the process of developing all-inclusive online courses can be affected.

However, designing and developing elearning courses that are accessible to everyone does not have to be such an arduous task. Section 508 mostly applies to Federal agencies but the principles of equally-accessible and inclusive content for everyone, including those with disabilities also apply to private sector groups, professional associations, and other organizations.

What is 508 Accessibility Compliance?

Section 508 of the Workforce Rehabilitation Act is a law that requires Federal agencies and their contractors to make their electronic and information technology accessible to people with disabilities. It defines the minimum acceptable standards such as the use of text labels and descriptors for graphics and certain format elements.

Under this Act, Federal agencies must ensure that their electronic and information technology allows the following:

  • Disabled Federal employees to be granted access to information and data that is similar to that accessed by those who are not disabled. The only exception would be if such access would impose an undue burden.
  • Disabled members of the public who are seeking services from Federal agencies to be granted access to information and data comparable to that being provided to non-disabled members of the public.

This section also addresses the usability of image maps, style sheets, multimedia presentations, applets and plug-ins, scripting languages, and electronic forms. Section 508 eliminates information technology barriers and makes new opportunities for people with disabilities. This encourages the development of technologies that will help to achieve these goals.

For instance, people with certain types of disabilities are unable to use traditional websites on elearning platforms. This is quite a challenge considering the following statistics:

  • There are over 285 million people globally who are visually-impaired.
  • 10% of the global population is affected by hearing loss.
  • People with movement-related disorders account for about one and nine percent of the population.
  • 15% of the population in the US has learning-related disabilities.

Consequently, since June 2001, Section 508 required that all content created using federal funds be 508 compliant. Also, some industry best practices recommend that even those organizations not receiving federal money make sure that their training is 508 compliant.

Undoubtedly, creating elearning courses that meet accessibility requirements may be a bit intimidating. This is especially true if you have not worked for a Federal agency or elearning vendor contracted to provide deliverables that adhere to 508 technical and accessibility standards.

Besides the legal requirements, you also need to consider the limitations and barriers of people with vision, hearing, and other impairments as well as the software and peripheral devices these individuals use to access online learning content.

Importantly, there is no all-inclusive solution or software package that can address these concerns automatically. The tools specifically designed to determine compliance are not as reliable when it comes to evaluating your efforts. However, it doesn’t mean that 508 compliance is impossible to achieve.

Accessibility

In the elearning industry, accessibility is generally voluntary and is slightly broader than what Section 508 recommends. However, it is highly encouraged by educators. It is all about making content easy to use for everyone, including those with disabilities.

Accessible elearning courses allow diverse categories of users to access them comfortably and effectively. For instance, elearning content that is well thought out with clear language and colors benefits everyone.

The World Wide Web Consortium (W3C) launched the Web Accessibility Initiative in 1997 endorsed by the White House and W3C members, to promote the importance of accessible digital design.

This initiative provides the guidelines for accessibility and checklists that can be used to grade content. Notably, these guidelines are not elearning-specific since they were initially created for web developers. Nonetheless, the tools and standards developed by W3C provide a good guide for all digital developers including instructional designers and content creators.

Organizations that are committed to creating an inclusive workplace will take necessary measures to ensure that everyone feels welcome. Employees and students who have visual, auditory, mobility, and cognitive disabilities should have access to elearning content and be provided with tools that will help them achieve their learning outcomes.

An accessible LMS features inclusive experiences for different learner populations, including those living with disabilities. LMS accessibility isn’t a single feature. It is a combination of design principles for user experience (UX) and interoperability.

The user experience should accommodate the needs of learners with disabilities to generate consistent learner outcomes across the organization.

Characteristics of an Inclusive LMS

An accessible solution like Tovuti LMS supports WCAG 2.0 to promote success among employees, LMS administrators, and external learners. The Web Content Accessibility Guidelines (WCAG) is a framework that defines ways that software can incorporate inclusive experiences for people living with disabilities.

Four criteria can help learning and development (L&D) leaders to foster universally positive technology experiences for diverse categories of learners. These include:

  1. Perceivable: The content and user interface elements must be designed in ways that all users can perceive.
  2. Operable: The navigation and user interface components must be easy to operate.
  3. Understandable: The information presented and the user interface must be well-understood by the users.
  4. Robust: Learning content must be robust enough to be reliably interpreted by a wide range of assistive technologies.

LMS Accessibility Standards

These are standards and regulations that govern technology accessibility. They serve the primary purpose of making learning available to all learners regardless of their age, health, and different abilities and needs.

Importantly, you should find out if your training is subject to any laws and regulations. Such knowledge affects the development of courses and tools that you will choose which, in turn, helps you to make informed choices.

In elearning, there are three major standards:

  1. Section 508 of the Rehabilitation Act of 1973 (discussed in the section above).
  2. Web Content Accessibility Guidelines (WCAG)
  3. The Americans with Disabilities Act (ADA)

Web Content Accessibility Guidelines (WCAG)

WCAG is a comprehensive set of regulations that guide the development of elearning courses, apps, and websites. These guidelines were developed by the World Wide Consortium (W3C), the World Wide Web international regulator.

In terms of compliance, these regulations are only used as a reference for purposes of accessibility in certain projects. Hence, WCAG does not have an official mandate to require compliance for organizations. They are also used as a reference standard by the government.

The Americans with Disabilities Act (ADA)

ADA is a civil rights law that ensures that people living with disabilities have equal opportunities and the same rights as every other citizen. The primary purpose of this law is to make sure that people with disabilities have access to all areas of public life such as schools, jobs, and transport.

Private and public companies are regarded as ‘public accommodations’ and should, therefore, be conformant to this law. Public accommodation also includes schools, retails stores, hotels, banks, healthcare institutions, and theaters, and museums.

LMS Accessibility Features and Design

LMS accessibility offers a range of features and user experience design that accommodates different accessibility scenarios. These include:

  • Consistent User Interface (UI) and icons.
  • Accessible text editors.
  • Use of high-contrast colors.
  • Accessible multi-select lists.
  • Screen reader-accessible instruction information.
  • Accessible course content support.

Section 508 Compliance Tips and Considerations

Section 508’s basic rule states that you should strive to provide multiple ways of accessing content that does not depend on individual senses or abilities. Below are some general tips on how to design accessible content without compromising quality and creativity.

  1. Test Color Contrast and Template Themes

Do not rely on color coding as the only means of conveying information, prompting a response, indicating an action, or differentiating a visual element. Instead, you can create cool template designs, attractive graphic elements, and interesting activities for learners.

There are tools in the market that allow you to hex color codes for foreground and background elements to check color contrasts. This especially comes in handy for these three color blindness conditions; protanopia (insensitivity to red), deuteranopia (insensitivity to green), and tritanopia (insensitivity to blue).

Ensure that you test your color combinations early enough in the design process.

  1. Know Where Your Audience Falls on the 508 Continuum

It is important for instructional designers working in the private sector to acknowledge an informal 508-style compliance continuum. This is because strict compliance can be expensive and may not be the appropriate solution for your organization.

Ask yourself if some professional licenses lockout learners with particular disabilities from taking part in your online courses. For instance, military personnel are screened for a wide variety of abilities.

In another case, consider if your course will offer over-the-phone customer service training to deaf learners. In some instances, you should be able to prioritize accessibility demands to meet an intended audience’s needs.

For non-governmental organizations (NGOs), accessible and inclusive elearning depends on good preparation and thoughtful instructional design.

  1. Provide Voiceover Audio Transcripts

If you intend to include an explainer video for a topic, or a webinar audio recording, it is always best practice to provide a written transcript or synced closed-captions (CC) for hearing-impaired and deaf learners.

If you already have scripted voiceover content, you just have to keep the script up-to-date and provide it as transcript text. In case you are working with pre-recorded content, you should create a text-only page.

  1. Create Alt-Tags and Descriptions

You should provide text equivalents via alt-text (“alt”), long descriptions (“longdesc”), in-element content, among others for every non-text element. The same applies to images, graphics, buttons, and hyperlinks. For hyperlinks, avoid the use of generic terms such as ‘read more’, ‘click here’, or ‘for more information.’

It is pointless to make learners follow a link to determine its destination or meaning. Instead, take the raw URL and add alt-text to it so that users can figure out where the link sends them.

Additionally, graphs, charts, and tables can be problematic for a screen reader. The content becomes hard to read in a logical order and it is easy to get confused and lost in keyboard tabbing. As an alternative, a long description is useful in conveying content to learners with visual disabilities.

Moreover, Word, PDF, PowerPoint, .mp3, and .wmv files that you use as resources should be designed with accessibility in mind. For example, converting a Word document to a PDF file is not enough. You need to include tags on a PDF file using the ‘Add Tags to Document’ function on Adobe Acrobat Professional and then check for compliance using the ‘Full Check’ feature.

  1. Check Government Agency 508 Checklists

For additional tips, check resources and checklists provided by Federal agencies. Such checklists keep you on track and help you to identify important compliance elements to be considered during the design process.

For example, you can get accessibility checklists for Word documents, Excel spreadsheets, PowerPoint presentations, PDF files, HTML files, and multimedia files from the U.S. Department of Health and Human Services. To add, the U.S. General Services Administration has more additional guidance documents and tutorials covering these issues and much more.

LMS FERPA Compliance

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Privacy and security matters are highly-regarded to the extent that there are laws to enforce them. In the United States, the Family Education Rights and Privacy Act (FERPA), was formed to ensure that institutions take care of this aspect.

FERPA is a federal privacy law that gives parents and guardians certain protections relating to children’s education records including transcripts, report cards, class schedules, disciplinary records, and contact and family information.

In this regard, a parent has the right to review their child’s education records and, under limited circumstances, request for changes to the records. To protect a child’s privacy, the law states that written consent should be sought by other individuals (other than the parent/guardian) seeking disclosure of personally identifiable information from schools.

In elearning, to achieve LMS FERPA compliance, an LMS platform must have an interface and protocols that are reliable and safe with every version. FERPA protects data that is managed in educational environments and that involves the students and their families.

Such data includes specifications for the management and control of the access to information via roles or permissions that users, administrators, and instructors have to access and grant respectively to the data.

Hence, LMS FERPA compliance defines how information regarding students and their families is accessed and safeguarded. This is especially important for educational institutions that receive funds from the United States government.

This regulation comprises a set of laws that were formulated to protect the privacy and security of users’ information. Some of these regulations include HIPAA, Part 11, GDPR, among others.

The Health Insurance Portability Accountability Act of 1996 is a US federal statute that required the creation of national standards to protect personal and sensitive patient health information from being disclosed without the patient’s knowledge or consent.

Part 11, is a standard that defines the criteria under which electronic records and electronic signatures are considered trustworthy, reliable, and equivalent to paper records.

More about GDPR in a later section in this article.

According to the FERPA regulation, the user (learner) is the one responsible for the control of information that they want to share and make public in an LMS. To add, the regulation requires certain permissions to see information about a learner’s education.

It also requires their personal information, identity, and other information that they host on different platforms with which they can integrate with their LMS.

All shared information must go through an approval process previously signed in. This enables the data to be seen and used by the learning management system, administrator, instructor, and courses developer.

An LMS that is FERPA-compliant handles all the security of the transcripts, GPA (Grade Point Average) information, grades, evaluations, and social security number (SSN). FERPA compliance also controls all the student information that students need to share with other roles within an LMS such as administrators and instructors.

Students are free to grant such access or make changes without any prior authorization. Importantly, information regarding FERPA compliance should be shared by instructors and LMS platform providers. This enables the students to know their rights and privileges regarding what information they can freely share.

Data that is freely shared by users is known as directory information. It includes details such as the name, date of birth, mailing and permanent address, telephone numbers, email addresses, enrollment status, major field of study, participation in officially recognized activities and sports, weight, and height, dates of attendance and graduation, degrees and awards received, among other information.

Confidential information is not categorized together with directory information. It includes information such as the student’s ID, grades, GPA, class schedule, registration in courses, parents’ names and addresses, ethnicity and race, sex, social security number (SSN), among others.

When purchasing an LMS, look for a platform that can be adapted to comply with different protocols and regulations that are set by institutions and companies within the field of your training.

Why FERPA is Important

FERPA regulation applies to all students and takes effect the moment they are enrolled for an academic or other learning programs. It includes both currently enrolled and previously enrolled students.

FERPA explains why we don’t have public information about prominent figures’ academic information and performances. In cases where such information is publicly available, the individual must have given consent to the release of the information. It could also be a result of someone working in that institution leaking that individual’s academic information.

This regulation is a crucial piece of legislation for students since, in addition to basic academic information, some student records could contain private information. This includes medical information, a student’s prospects, and disciplinary information.

Below are some of the reasons FERPA is important.

  • Non-academic information is kept private. FERPA ensures that a student’s education record does not show specific medical records. However, it may include notes, communication, and other documentation of a student’s medical history, accommodations, or disability. Also included in such information are details about a student’s short-term and long-term medical conditions and details about pregnant students. They also have the right to keep this information private for personal reasons and also to prevent discrimination or harassment in case anyone accesses those records.
  • FERPA keeps students safe. It protects the students’ information even from the parents. The exception, in this case, is emergencies. This safeguards the students but also grants parents and guardians access to information in case something extreme happens. It is, for this reason, we get a lot of details when events such as campus accidents happen. Besides, discipline records are maintained as private. However, an exception applies to sexual assault cases so that all students are protected from harm.
  • It also provides students with ownership and choice. FERPA allows students to control who sees their records and at what times. This way, students are empowered to safeguard their records from erroneous requests and can authorize corrections. They can also file grievances if an institution violates their privacy rights. FERPA ensures that only a school official can view their records if they have 'legitimate educational interest.’ In turn, this gives the student recourse for unfortunate situations like abuse or retaliation.
  • It protects the integrity of students' records and data. If students’ information were available publicly especially through the internet, mining such data for malicious purposes would be easy. Such data would also be easy to manipulate. Keeping such records private means that only the institution has such data which makes it accurate and true. 
  • It provides value for the improvement of education. FERPA allows the release of student education records. Some requests can be made for and on behalf of an institution to develop, administer, or validate predictive tests, improve instruction, or administer student aid programs. This exception helps us to understand the implementation of educational programs which benefit everyone, while also protecting the student at an individual level. Similar to HIPAA, information is needed to conduct research and make progress while sustaining the progress of each individual as well.

Importantly, FERPA does not only apply to instructor-led training. It also governs similar principles in online learning. Additionally, it applies to learners of all ages, academic levels, or learners using other learning models.

LMS PCI Compliance

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Exactly what is PCI compliance? The Payment Card Industry Data Security Standards (PCI DSS) is an information security standard for organizations that handle branded credit and debit cards from major card schemes.

The PCI DSS is a set of requirements created to ensure that all companies that process, store, and transmit credit and debit card information do so in a secure environment. It was launched on 7th September 2006 to manage the PCI security standards. It was also mandated to improve account security throughout the transaction process.

The PCI standard is mandated by the card brand but is administered by the Payment Card Industry Security Standards Council. It was formed when American Express, Visa, MasterCard, JCB International, and Discover Financial Services merged their policies to create the PCI Security Standards Council (PCI SSC).

The PCI SSC manages and administers the PCI DSS. Surprisingly, the acquirers and payment brands are the ones responsible for enforcing compliance, not the PCI SSC.

In elearning, you should ensure PCI compliance for your learning management system (LMS) and other learning tools to keep them secure when dealing with credit and debit cards. By keeping these systems secure, it shows your vendors and customers that your business cares about their data and is on the frontline to fight any compromise to payment data. It also protects your organization from fraud losses.

PCI requires different levels of compliance that are based on the number and type of transactions your organization handles. There are other details to be considered such as the level of risk assessed by the payment brands. At the highest level, these compliance levels include the following:

  • Level 1: Over 6 million annual transactions.
  • Level 2: Between 1 and 6 million annual transactions.
  • Level 3: Between 20,000 and 1 million annual transactions.
  • Level 4: Less than 20,000 annual transactions.

Additionally, each card issuer must maintain its table of compliance levels. PCI compliance applies to anyone whose business involves transacting using credit and debit cards, regardless of the number of customers making purchases.

Non-compliance to PCI standards attracts hefty fines ranging from $5,000 to $100,000 per month. Notably, PCI is not a law, hence major card companies can choose whether to fine or not fine merchants for not adhering to certain PCI standards.

Also, PCI compliance is not a one-time thing. It is a continuous exercise that ensures a safe environment for your organization and customers.

PCI SSC Data Security Standards

To improve security in payment card data, the PCI Security Standards Council details comprehensive standards and supportive materials which include tools, specification frameworks, measurements, and support resources to help organizations maintain the security of their cardholders at all times.

The PCI SSC provides the necessary framework for creating a complete payment card data security process that includes prevention, detection, and necessary reaction to security threats.

The resources and tools available from PCI SSC include the following:

  • Self-Assessment Questionnaires to help businesses in validating their PCI DSS compliance.
  • PIN Transaction Security (PTS) requirements for manufacturers and device vendors and other approved PIN transaction devices.
  • Payment Application Data Security Standard (PA-DSS) and a list of validated applications to assist software developers to create secure payment applications.
  • Public resources. These include:
  1. Lists of Qualified Security Assessors (QSAs).
  2. Payment Application Qualified Security Assessors (PA-QSAs)
  3. Approved Scanning Vendors (ASVs)
  4. Internal Security Assessor (ISA) education program

PCI Compliance Security Standards

  1. Build and maintain a secure network: This is achieved by installing and maintaining a firewall configuration to protect cardholder data. You should only use vendor-supplied parameters such as system passwords.
  2. Protect cardholder data: This standard protects stored cardholder data and encrypts the transmission of cardholder information across public and open networks.
  3. Maintain a vulnerability management program: This standard develops and maintains secure systems and applications. For instance, it recommends that you regularly update your antivirus software.
  4. Implement strong access control measures: This restricts access to cardholder data on a business need-to-know basis. This can be achieved by assigning a unique ID to each person with access to a computer. It also restricts physical access to cardholder data.
  5. Maintain an information security policy: This helps to maintain a policy that takes care of information security.
  6. Regularly test and monitor networks: This standard tracks and monitors access to all cardholder data and network resources. It is recommended that you regularly test security processes and systems.

The 12 Requirements for PCI DSS Compliance

  1. The Use and Maintenance of Firewalls

Firewalls usually block any access by foreign or unknown parties that attempt to access protected data. Firewalls are prevention systems that act as the first line of defense against hackers. They are required for PCI DSS compliance since they scan all network traffic and are effective in preventing unauthorized access.

  1. Passwords Protection

Modems, routers, point-of-sale (POS) systems, and other third-party products usually come with generic passwords and security measures that are vulnerable to public access. Mostly, businesses fail to secure these vulnerabilities. 

Passwords are easily discovered through public information and can be used by malicious individuals to access protected customer data.

Passwords protection keeps a list of all software and devices that require passwords. Besides a device or password inventory, other basic configurations and precautions should also be recommended, such as frequent changing of passwords.

  1. Protect Cardholder Data

Another requirement is two-fold protection of cardholder data. Card data should be encrypted using specific algorithms. Such encryption is developed using encryption keys (which are also apparently encrypted for compliance purposes).

The regular scanning and maintenance of primary account numbers (PAN) are also required to ensure that no unencrypted data exists. Also, encryption, masking, hashing, and truncation are other methods used to protect cardholder data.

  1. Encrypting Transmitted Data

Cardholder data is transmitted over ordinary channels such as from a local store to a home office, and through payment processors. Data sent over these channels should be encrypted. To add, account numbers should never be sent to unknown locations.

The transmission of information over open and public networks should be encrypted. Strong encryption methods including the use of certifications and trusted keys reduce the risk of being targeted by malicious users.

  1. Use and Maintenance of Antivirus Software

The use of antivirus software is not a PCI DSS compliance issue. It is just good practice. However, the use of antivirus software is a must for all devices that store or interact with PAN. This software should be updated and patched regularly. Additionally, your POS vendor should provide measures where antivirus software cannot be directly installed.

Antivirus software is important since malware can find its way into an organization’s systems in numerous ways. These include regular internet usage, employee emails, storage devices, and mobile devices.

  1. Updated LMS Software

The same way firewalls and antivirus software are updated regularly, your learning management system or other elearning platforms should also be upgraded often. Most software products, including LMSs, include patches that contain lists of recently-discovered vulnerabilities and threats in their updates. Patches add another layer of security.

The regular update of your elearning platform is especially required for all software and apps installed on devices that interact with cardholder data.

  1. Restricted Data Access

Cardholder data is requested on a strictly need-to-know basis. Any third-parties such as executives and staff who don’t need access to this data should not be allowed to have it. Roles that need sensitive data should be well-documented and updated regularly as required by PCI DSS.

  1. Unique IDs for Access

Users who are authorized to handle cardholder data should have individual identification and credentials for access. For example, multiple employees with such authorized access should not all have the same set of username and password.

The creation of unique IDs leads to less vulnerability and quicker response times in the event of compromised data.

  1. Restricted Physical Access

All cardholders must be physically kept in secure locations. Data that is physically written and that which is typed and digitally stored should all be locked in a cabinet, drawer, or secure room. Access to such data should be limited as well as kept in logs any time-sensitive data is accessed, to remain compliant.

  1. Creation and Maintenance of Access Logs

Every activity that involves interactions with cardholder data and primary account numbers requires a log entry. Evidently, the most common non-compliance issue is improper record keeping and documentation of access to sensitive data.

How data flows in your organization and the number of times access is needed should be documented for compliance purposes. Logs of access to software products are also needed for accuracy.

Logging mechanisms should be put in place to track user activities. This ensures the prevention, detection, and minimization of the impacts of data compromises.

  1. Scan and Tests for Vulnerabilities

The above ten compliance standards involve various software products, physical locations, and possibly a few employees. There are a couple of things that could be compromised and malfunction, get outdated or suffer from human error.

Such threats are limited by fulfilling regular scans and vulnerability testing; both PCI DSS requirements. New threats and vulnerabilities are discovered every now and then. Scanning and testing for these vulnerabilities help to uncover possible threats to cardholder data.

  1. Document Policies

For compliance, an inventory of the software, equipment, and employees that have access to cardholder data needs to be documented. Also, the logs for such access should be documented. Moreover, the flow of information in your company, where it is stored, and how it is used after leaving the point of sale should also be documented.

Benefits of LMS PCI Compliance

At the very least, complying with LMS PCI compliance standards seems like a daunting task. Organizations find the various issues and standards a bit too much to handle. However, if you have the right tools, compliance should not be so complicated.

According to the PCI SSC, there are some major benefits of compliance. This is considering that failure to comply may result in serious consequences. Some of the benefits include:

  • Your systems will always be secure and your users will always trust you with sensitive card information. Trust leads to customer confidence and repeat business. In elearning, this means that learners will keep coming back and you will always get new ones.
  • PCI compliance is an ongoing process that helps to prevent security breaches and theft of payment card details in the present and the future. By complying with PCI standards, you are contributing to global card data security solutions.
  • It improves your reputation with payment brands and acquirers. These are the same partners you need for your business.
  • It also contributes to corporate security strategies.
  • If your LMS is PCI compliant, you will be better prepared to comply with other regulations including SOX, HIPAA, among others.
  • PCI compliance also leads to an improvement in IT infrastructure efficiency.

Danger of LMS PCI Non-Compliance

The PCI SSC also details the potential dangers of not complying with its standards by all industries, including elearning. You may have worked so hard to build your brand and secure customers. Therefore, taking chances with the security of their data should not be entertained.

When you comply with LMS PCI standards, you are protecting your users so that they continue to be loyal learners. On the flip side, if you don’t comply with these standards, the possible results include the following:

  • Vulnerabilities that may lead to compromised data. This will negatively impact your users and partners.
  • It will also severely damage your reputation and the ability to safely conduct business.
  • The breach of data could lead to loss of sales, customer relationships, and community standing. Besides, publicly-listed companies may experience declines in share prices.
  • An organization can also face lawsuits, canceled accounts, insurance claims, payment card issuer fines, and government fines.

As with other regulatory requirements, non-compliance to PCI standards can impose challenges to organizations that are not well-prepared to protect critical customer information. With the right software and services, protecting data is a manageable task.

Ensure that you deploy data loss prevention strategies that accurately classify data and appropriately use it so that you can sit back and relax, trusting that your cardholder data is secure.

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Author:
Kevin Kimani

Kevin Kimani is a technical writer for Tovuti. He is skilled in technical research and is always updating himself with the latest in information technology. He is also skilled in web content management and strategy. Kevin is passionate about space exploration and hopes to spot a UFO one day! He also likes to track the ISS and other man-made satellites. He also likes to spend time with his two lovely daughters and teach them tech stuff!

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