Maze & Associates PCI Compliance Tracker for Local Governments

Maze & AssociatesPCI Compliance Tracker for

Local Governments

Action Items

• Document how your organization stores, processes or transmits credit card information

• Determine your merchant level• Determine your validation requirements

– Contact your merchant banks and acquirers• Determine your SAQ validation type• Find an ASV for compliance network vulnerability

scans– Perform at least quarterly scans

• Annually fill out your SAQ– turn in and/or keep on file

10 Steps to Document Cardholder Environment

1. Determine Merchant Level (number of transactions)2. List all Merchant Banks and Acquirers3. List all outsourced processors, ASPs and third party

processors4. Document all Payment Applications5. Document all PEDs used (Point of Interaction)6. List all physical locations that CHD is processed,

stored or transmitted7. List all electronic storage of CHD8. Document electronic transmission9. Document policies that address PCI requirements10. Implement applicable PCI DSS controls

Step 1: Determine Merchant Level

• List the number of all credit card transactions for all Merchant Banks and Acquirers

• List by card brand as well• Determine your merchant level based on

total annual credit card transactions• Number is based on the aggregate

number of transactions for a DBANote: Merchant levels are defined by the Card Brands and determined by the Acquirer based on transaction volume.

Step 2: Document Acquirers• List all Acquirers, Merchant Banks and/or

Acquiring Banks • Included card brands when they act as

acquirer, e.g. Amex, Discover, JCB • Would never be Visa or MasterCard• They determine your merchant level and

reporting requirements

Step 2: Document Acquirers

• Contact Information– Address– Phone Number

• Incident Response Team• Website– Monitor for changes in requirements

• Any notes or document conversations you have with them

Step 3: Determine Service Providers

• A Service Provider is an business or entity that is directly involved in the processing, storage, transmission, and switching of transaction data and/or card holder data (CHD)

• Any service provider that has control or could have a security impact on CHD

Example of Service Providers

• Transaction Processors• Customer Service• Call Centers• Payment Gateways• Credit Reporting • External Sales

• Remittance Processing• Card Embossing

Companies• Information security

providers• Offsite Data Storage

Providers

Manage Service Providers

• Maintain a list of service providers• Maintain agreements that hold service

providers responsible for security of CHD– Include reporting and breach notification

• Have a process to validate new service providers before they become service providers

• Have a program to monitor service provider compliance at least annually

Step 4: Document Payment Applications

• List all payment applications• Document the business use of the

applications• Determine if the application is compliant• Determine if the application stores CHD• Check PCI website for list of approved

applications

Action Items• Contact the vendor, make sure payment

applications are PA DSS complaint or will be.

• Contact your PIN device supplier, make sure you have compliant PIN Entry Devices.

https://www.pcisecuritystandards.org/security_standards/ped/pedapprovallist.htmlhttps://www.pcisecuritystandards.org/security_standards/vpa/

Payment Applications• In house

applications– SDLC controls– Code reviews – Application

firewalls– OWASP

Step 5: Document PED • List all Points of Interaction (POI)– List all PIN Entry Devices (PED)– List all Point of Interaction devices– List all Unattended Payment Terminals (UPT)– List all Point of Sale (POS) devices

• Document compliance for those devices currently required to be PCI compliant

PED

• PIN Entry Device– Scope of the standard increasing• PIN Transaction Security (PTS)

– Will include • UPT (Unattended Payment Terminals)• POI (Point of Interaction)• POS (Point of Sale Devices)

– Standard addresses the vendors who make devices

– Merchants must use approved devices

Step 6: Physical CHD• List all physical locations that PAN is processed,

stored or transmitted– Paper, – Receipts, – Imprints, – Carbon Copies– Locations of backup media

• Document Retention Period – Justify with business need

• Document Destruction Policy

Step 7: Electronic Data Storage• List all electronic storage of CHD• Document business reason for storing

and retention period• Requirements in PCI DSS– Encryption– Access Controls and Audit logs– Never permitted to store full track data

Cardholder DataData Element Storage

PermittedProtectionRequired

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

SensitiveAuthentication

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

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

Unknown Storage

• Fax Machine and Copy Machines may store CHD

http://www.youtube.com/watch?v=iC38D5am7go

Step 8: Document Data Transmission

• Not only do you need to know where you data is stored but you also need to know where it travels

• Create a Data Flow diagram– Diagram with CHD flow superimposed over

network diagram• Evaluate flow every 6 months or more often if

there has been a change• Helps to determine the PCI scope and aids in

determining network segmentation

Document Data Flow

• With a network diagram document the flow of credit card information (transmission)

• Locate any places the information might be stored along the data path (storage)

Step 9: Create Needed Policies

• What policies do you currently have that address PCI related issues

• Create needed policies• See section 12 of the PCI DSS• You will need to create additional subordinate

policies, procedures or administrative directives for specific PCI control requirements

• Every PCI DSS control should be documented in some policy, procedure, administrative directive, SOP or schedule

Step 10: Document PCI DSS

PCI DSS

The Payment Card Industry Data Security Standard 6 Objectives (Goals) 12 Sections (Requirements) 194 Controls

PCI DSS

PII Policy

• If you already have a policy for handling confidential information or personally identifiable information add credit card information to confidential information or PII.

PCI DSS

• 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.”

PCI DSS

• Use the prioritized approach to implement the most important controls first.

Document Compliance

• Determine if all PEDs are PCI compliant• Determine if all payment applications are

PCI compliant• Determine if all 3rd party processors and 3rd

parties are PCI compliant• Obtain documentation from each• Annually renew documentation from 3rd

parties • Annually check payment application and

PED list