Payment Card Acceptance PCI Compliance for Local Governments 2012
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ecommerce & Credit Card Processing Risks associated with cc processing What is PCI? Why is it important? What do we have to do?
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Payment Card Acceptance PCI Compliance for Local Governments 2012
- 2. eCommerce & Credit Card Processing • Risks associated with cc processing • What is PCI? • Why is it important? • What do we have to do? 06-Feb-12 © 2012 Maze & Associates 2
- 3. The Problem Albert Gonzalez, 28 With accomplices, he was involved in data breaches of most of the major data breaches: Heartland, Hannaford Bros., 7-Eleven, T.J. Maxx, Marshalls, BJ’s Wholesale Club, OfficeMax, Barnes & Noble, Sports Authority, Dave & Busters, Boston Market, Forever 21, DSW and others. 06-Feb-12 © 2012 Maze & Associates 5
- 4. Who is behind data breaches? • 70% from external agents • 48% caused by insiders • 11% implicated business partners • 27% involved multiple parties Source: 06-Feb-12 © 2012 Maze & Associates 6
- 5. Risks • Fraud • Theft • Fines (bank and card brands) • Credit monitoring fees for customers • Litigation costs • Reputation 06-Feb-12 © 2012 Maze & Associates 7
- 6. Players • Acquirer (Merchant Bank) – Bankcard association member that initiates and maintains relationships with merchants that accept payment cards • Hosting Provider – Offer various services to merchants and other service providers. • Merchant – Provides goods and services for compensation • Cardholder – Customer to whom a card is issued or individual authorized to use the card Card Brand Acquirer Hosting Provider Merchant Cardholder 06-Feb-12 © 2012 Maze & Associates 13
- 7. Players • Card Brand – Issue fines – Determine compliance requirements • PCI Security Standards Council – Maintain standards for PCI – Administer ASV & QSA • Qualified Security Assessors – Certified to provide annual audits • Approved Scanning Vendor – Certified to provide quarterly scans Card Brands PCI SSC QSA ASV 06-Feb-12 © 2012 Maze & Associates 14
- 8. PCI Council Standards 06-Feb-12 © 2012 Maze & Associates 15
- 9. What does the PCI Council do? • Own and manage PCI DSS, including maintenance, revisions, interpretation and distribution • Define common audit requirements to validate compliance • Manage certification process for security assessors and network scanning vendors • Establish minimum qualification requirements • Maintain and publish a list of certified assessors and vendors 06-Feb-12 © 2012 Maze & Associates 16
- 10. Website https://www.pcisecuritystandards.org/ 06-Feb-12 © 2012 Maze & Associates 17
- 11. What are the Standards? • PCI DSS: PCI Data Security Standard – Overall standard, applies to all • PA DSS: Payment Application Data Security Standard – Supporting standard for payment applications • PTS (was PED): PIN Transaction Security Standard – Supporting standard for PIN entry devices – Supporting standard for unattended payment terminals (UPT) 06-Feb-12 © 2012 Maze & Associates 18
- 12. Who must comply? • With PCI DSS – Any organization that processes, stores or transmits credit card information. • With PA DSS – Payment application developers – Merchants will be required to use only compliant applications by July 2010. • With PTS – Manufactures of PIN entry devices – Merchants will be required to use only compliant hardware by July 2010. – MasterCard PTS to incorporate into PCI SSC April 30, 2010 06-Feb-12 © 2012 Maze & Associates 22
- 13. PCI Compliance • This includes: • Organizations who only use paper based processing • Organizations who outsource the credit card processing • Organizations that process credit cards in house 06-Feb-12 © 2012 Maze & Associates 23
- 14. What if we are a small organization? • “All merchants, whether small or large, need to be PCI compliant. • The payment brands have collectively adopted PCI DSS as the requirement for organizations that process, store or transmit payment cardholder data.” – PCI SSC 06-Feb-12 © 2012 Maze & Associates 25
- 15. Cost? • What happens when there is a data breach? – Depends if the merchant can reach safe harbor. 06-Feb-12 © 2012 Maze & Associates 27
- 16. What’s Safe Harbor? Incident Evaluation Safe Harbor $$$$$$ 06-Feb-12 © 2012 Maze & Associates 28
- 17. Safe Harbor Notes: • For a merchant to be considered compliant, any Service Providers that store, process or transmit credit card account data on behalf of the merchant must also be compliant. • The submission of compliance validation documentation alone does not provide the merchant with safe harbor status. 06-Feb-12 © 2012 Maze & Associates 29
- 18. Outside the Safe Harbor • Losses of cardholders • Losses of banks • Losses of card brands – Fines from the Card brands – Possible restrictions on process credit cards – Cost of forensic audit 06-Feb-12 © 2012 Maze & Associates 30
- 19. Fines Merchants may be subject to fines by the card associations if deemed non- compliant. For your convenience fine schedules for Visa and MasterCard are outlined below. http://www.firstnationalmerchants.com/ms/html/en/pci_compliance/pci_data_secur_stand.html 06-Feb-12 © 2012 Maze & Associates 31
- 20. Continuous Process • “PCI DSS compliance is much more than a “project” with a beginning and end – It’s an ongoing process of assessment, remediation and reporting” - PCI SSC Assess ReportRemediate 06-Feb-12 © 2012 Maze & Associates 37
- 21. Continuous Process • Many of the PCI requirements have specific time interval requirements • Create a schedule for time based requirements • Some organizations already have ‘maintenance calendars’ for these type of actions 06-Feb-12 © 2012 Maze & Associates 38
- 22. Common Findings • Clients think they are compliant – Because they do quarterly networks scans – Because they filled out the SAQ – Because they have too few transactions • Reality – Validation is not compliance – Compliance is an ongoing process – PCI DSS is required for all merchants, regardless of the number of transactions 06-Feb-12 © 2012 Maze & Associates 39
- 23. Common Findings • Payment card information on paper • No network segmentation • Logging Access • Shared Passwords • Verifying compliance of outsourced processing • No one is assigned responsibility • Not aware of PAN storage in application 06-Feb-12 © 2012 Maze & Associates 40
- 24. PCI Pitfalls • PCI will not make an organization’s network or data secure • PCI DSS focuses on one type of data: payment card transactions • The organization runs the risk of focusing on one class of data to the detriment of everything else 06-Feb-12 © 2012 Maze & Associates 41
- 25. Important • Senior management support • PCI knowledge • Support from merchant bank • PCI early in lifecycle – PCI reviewed when new applications or systems are purchased – Should included all PII (Personally Identifiable Information) 06-Feb-12 © 2012 Maze & Associates 42
- 26. Cardholder Data Data Element Storage Permitted Protection Required PCI DSS 3.4 Cardholder Data Primary Account Number (PAN) Yes Yes Yes Cardholder Name Yes Yes No Service Code Yes Yes No Expiration Date Yes Yes No Sensitive Authentication Data Full Magnetic Stripe Data No N/A N/A CVC2 / CVV2 / CID / CAV2 No N/A N/A PIN / PIN Block No N/A N/A 06-Feb-12 © 2012 Maze & Associates 61
- 27. Places to look for CHD • Electronic Image Files • SANS • Fax Servers • Scan Archive • Pinter Spool • Laser Fiche • Log Files • Audio Recording: customer service call recordings • Voicemail • Email Server/Archive • Backup Media • Copier Scanner Cache • Data bases Perform a search for CHD every 6 months 06-Feb-12 © 2012 Maze & Associates 62
- 28. Risk Mitigation • Teamwork – Finance department takes the lead (payment processing and associated controls) – IT department – technical expertise – Legal department – policy etc… – Associated departments – payment processing in support of other City functions (golf, parks & rec, classes, theater, licenses, PD, utilities, library etc…) 06-Feb-12 © 2012 Maze & Associates 68
- 29. Risk Mitigation • Start implementing the data security standard starting with policies • Start with high level polices – “The City shall not store PAN (Credit Card Numbers) electronically or physically. Employees shall be trained on PCI standard annually. Background checks will be performed on all staff with access to credit card information.” 06-Feb-12 © 2012 Maze & Associates 69
- 30. Policy Examples • “The City shall develop procedures to ensure that information security and privacy best practices are followed to include compliance with all laws or contractual requirements.” • “The City shall adopt information security and privacy procedures based on industry standards such as NIST and PCI security standards.” 06-Feb-12 © 2012 Maze & Associates 70
- 31. Risk Mitigation • The merchant is ultimately responsible – Not the hardware manufacturer’s responsibility – Not application vendor’s responsibility – Not the bank’s responsibility – Not the customer’s responsibility 06-Feb-12 © 2012 Maze & Associates 81
Hinweis der Redaktion
- The standard has approximately 194 controls in 12 sections. The 12 sections are group into 6 objectives. The 6 objectives are; build and maintain a secure network, protect cardholder data, maintain a vulnerability management program, implement strong access control measures, regularly monitor and test networks, maintain an information security policy.
- This includes organizations who only use paper based processing, organizations who outsource the credit card processing, to organizations that process credit cards in house.
- If there is a data breach, the card brands will perform a forensic audit to determine if the merchant was compliant at the time of the data breach. If the merchant is found not compliant at the time of the breach they will be liable for the full cost of the breach; the cost of the forensics, losses of cardholders, losses to the banks, losses to the card brand and in some states fines will be assessed. In addition, the merchant will be moved to the highest merchant level and will be required to meet the most stringent evidence requirements and their credit card processing fees will go up.
- http://usa.visa.com/merchants/risk_management/cisp_if_compromised.html
- NIST SP 800-37 Rev 1, § 2.1
- The standard has approximately 194 controls in 12 sections. The 12 sections are group into 6 objectives. The 6 objectives are; build and maintain a secure network, protect cardholder data, maintain a vulnerability management program, implement strong access control measures, regularly monitor and test networks, maintain an information security policy.