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Payment Card Industry Data Security Standard IU Treasury Operations 5th Annual e-Business/Banking Seminar August 10 & 11, 2006 Tom Davis, CISSP, CISM, GCIA Chief IT Security Officer Office of the VP for Information Technology Agenda Protecting card data
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Payment Card IndustryData Security Standard IU Treasury Operations 5th Annual e-Business/Banking Seminar August 10 & 11, 2006 Tom Davis, CISSP, CISM, GCIA Chief IT Security Officer Office of the VP for Information Technology
Agenda • Protecting card data • Overview of the Payment Card Industry Data Security Standard (PCI DSS) • PCI DSS requirements • Merchant levels • PCI DSS compliance validation • Risks of non-compliance • IU and PCI DSS compliance • Questions
Protecting card data • Why it’s important • causes hardship for our customers • loss of customer confidence • required by PCI DSS • state laws on “disposal” and “notice” • impending federal legislation?
Credit card theft is big business! • Phishing attempts on the rise • to trick individuals into divulging financial info • Dramatic move by “hackers” to compromise machines for profit • keyboard monitoring software • Many chat channels devoted to underground trading of credit card #’s
Overview of PCI DSS • Prior to September 2004 • no standardization across card companies on credit card security requirements • difficult for merchants to become familiar with and adhere to competing standards from VISA, MasterCard, and others • As fraud losses increased, card industry realized the need for consistent and well defined security standards
Overview of PCI DSS • PCI DSS announced in September 2004 • collaboration between VISA and MasterCard • endorsed by other card companies as well • “… offers a single approach to safeguarding sensitive data for all card brands…”
Overview of PCI DSS • Applies to • all merchants that “store, process, or transmit cardholder data” • all payment (acceptance) channels, including brick-and-mortar, mail, telephone, e-commerce (Internet) • Includes 12 requirements, based on • administrative controls (policies, procedures, etc.) • physical security (locks, physical barriers, etc.) • technical security (passwords, encryption, etc.)
Card Security Programs • The following programs incorporate PCI DSS: • VISA • Cardholder Information Security Program (CISP) • MasterCard • Site Data Protection (SDP) Program • American Express • Data Security Requirements • Discover • Discover Information Security and Compliance (DISC) Program
PCI DSS requirements Each requirement has many sub-requirements! • Install and maintain a firewall configuration to protect data • Do not use vendor-supplied defaults for system passwords and other security parameters • Protect stored data
PCI DSS requirements • Encrypt transmission of cardholder data and sensitive information across public networks • Use and regularly update anti-virus software • Develop and maintain secure systems and applications • Restrict access to data by business need-to-know
PCI DSS requirements • Assign a unique ID to each person with computer access • Restrict physical access to cardholder data • Track and monitor all access to network resources and cardholder data • Regularly test security systems and processes • Maintain a policy that addresses information security
Merchant levels • Merchant levels are based on yearly transaction volume of merchant • Specific criteria for placement in merchant levels varies across card companies • All merchants, regardless of level, must adhere to PCI DSS requirements • Level into which merchant is placed determines PCI DSS compliance validation (and ultimately cost) • Let’s take a quick look at Visa’s levels…
Merchant levels - Visa • Level 1: • merchants, regardless of acceptance channel, processing over 6,000,000 Visa transactions • any merchant that has suffered a data compromise • any merchant so selected by Visa • any merchant identified by other card brand as level 1
Merchant levels - Visa • Level 2: • merchants, regardless of acceptance channel, processing 1,000,000 to 6,000,000 Visa transactions • Level 3: • any merchant processing 20,000 to 1,000,000 Visa e-commerce (Internet) transactions
Merchant levels - Visa • Level 4: • any merchant processing fewer than 20,000 Visa e-commerce (Internet) transactions • all other merchants, regardless of acceptance channel, processing up to 1,000,000 Visa transactions
PCI DSS compliance validation • Level 1 merchants • annual on-site assessment by approved assessor (generates a report on compliance) • quarterly network security scan by approved scan vendor • Level 2 and 3 merchants • self-assessment questionnaire • quarterly network security scan by approved scan vendor
PCI DSS compliance validation • Level 4 merchants • self-assessment questionnaire • if required by acquirer • quarterly network security scan by approved scan vendor • if required by acquirer
Risks of non-compliance • Endangering customer information • Exposure could lead to: • fines levied by acquiring banks • cost of replacing cards and perhaps covering fraudulent charges • loss of merchant status • elevations to Level 1 status (and resulting compliance validation costs)
IU and PCI DSS compliance • Joint effort across many units • Treasury, IT Security and Policy, Internal Audit, Legal Counsel, Purchasing, etc. • Review IU merchants • rank existing merchants based on perceived risk and begin compliance reviews • will most likely hold merchants to higher standard than dictated by PCI DSS • especially for level 4 merchants
IU and PCI DSS compliance • Contracts • review existing and new contracts with external agencies to ensure they are responsible for complying with PCI DSS • Education and awareness • this seminar!
Additional reading • http://usa.visa.com/business/accepting_visa/ops_risk_management/cisp.html • http://www.time.com/time/world/article/0,8599,1224273,00.html?cnn=yes • http://www.no1proxy.com/proxy-list.html • http://searchsecurity.techtarget.com/originalContent/0,289142,sid14_gci1146949,00.html • http://money.cnn.com/2006/05/11/technology/fastforward_fortune/index.htm
Payment Card IndustryData Security Standard IU Treasury Operations 5th Annual e-Business/Banking Seminar August 10 & 11, 2006 Tom Davis, CISSP, CISM, GCIA Chief IT Security Officer Office of the VP for Information Technology