PCI Boot Camp

1. PCI Boot Camp Presented by the PCI Compliance Task Force

2. moderator: Jeremy Rock President ● RockIT Group

3. Agenda • PCI Overview • Removing Card Data From Your Hotel • Best Practices • Questions & Answers

4. PCIOverview

5. Presenters: Mark Haley, CHTP Managing Partner● The Prism Partnership, LLC Jeff Henschel Director of IT● Benchmark Hospitality International Chuck Marratt Regional Director of IT● Benchmark Hospitality International

6. What is PCI? What Does PCI Compliance Entail?

7. Overview Objectives • What are: • The Payment Card Industry (PCI) Data Security Standard (DSS) and • The Payment Application Data Security Standard (PA-DSS)? • What are the components of a sound data security policy and PCI Compliance? • How do you get to PCI Compliance? • Vocabulary and Concepts for all of above

8. Overview • Why is Compliance So Important? • PCI & PCI Compliance Defined • Key Issues • Who is responsible for compliance? • What gets overlooked? • How do I plan my compliance journey? • Additional Resources • Questions

9. Why Is Compliance Important? • PCI Compliance is like insurance • Good business practice • You are vulnerable! • 55% of credit card fraud from hospitality • 85% of breaches against Level 4 merchants* • Potential impact of a breach • Customer Relations • Legal • Financial* Source: Unified Compliance Framework

10. Why is Compliance Important? • Because they are after us! • Hackers now specifically targeting hospitality • 38% of breaches in 2009 in hotels and resorts Source: Trustwave Spider Labs

11. 2010 Market Trends: Industries by Percent of Breaches *Statistics from 2011 Verizon Business Data Breach Investigation Report

12. 2010 Breach Trends: The Facts • 761 Breaches in 2010 (141 in 2009) • 89% of victims subject to PCI DSS had not achieved compliance • 86% of the breaches were discovered by a third party • 86% of the victims had evidence of the breach in their log files • 98% of all breached records came from servers • 96% of breaches were avoidable through simple or intermediate controls * All percentages are from the 2011 Verizon Business Data Breach Investigation

13. Why is Compliance Important? You don’t want to make the headlines!

14. Breakdown of Cost per Record

15. Costs of Non-Compliance • Costs of a Breach • Fines from issuing brands • Costs to address vulnerabilities • Costs of Level 1 audits in future • Lawsuits from card-issuing banks for card replacement costs • Loss of customer trust and goodwill • Loss of business • Tarnished reputation

16. Definition • Data security standards for all merchants accepting credit, debit or other cards to protect cardholder data • To ensure the integrity of the global payment card industry • Applies to ALL cardholder data • Electronic • Paper • Applies to ALL merchants

17. Definition- Roles • Key Players & Roles • Standards “owned” by PCI Security Standards Council • Enforcement reserved to the issuing brands

18. Lodging complexity - lifespan of a credit card number in a lodging environment

19. Definition - Details • Payment Card Industry (PCI) Data Security Standards (DSS) • 12 Major Requirements • Applies to everyone handling cardholder data • Merchants • Processors • Intermediaries • Self-Assessment Questionnaire (SAQ) for most merchants • Different forms of SAQ varying with merchant’s processing infrastructure

20. Definition - Details • Payment Application Data Security Standards (PA-DSS) • Formerly known as Payment Application Best Practices (PABP) • Applies to software vendors marketing products that handle cardholder data • Requires software vendors to invest in certification, costly to achieve and maintain • Merchants forbidden to use uncertified payment applications July 2010

21. Definition of Merchant Levels Merchant Level Description Source: http://usa.visa.com/merchants/risk_management/cisp_merchants.html#anchor_2

22. 12 Steps to PCI Compliance

23. Key Issues • Who is responsible? The Merchant

24. What Gets Overlooked? People Process

25. Where Companies Fail Their PCI Audit 2011 Global Security Report

26. Action Items • How do I plan my compliance journey? • Assign an Owner • Use your Acquirer • Use your Franchisor/Brand • Establish Documentation • Gather Inventories • Use your Software Vendors • Complete Self-Assessment Questionnaire (SAQ)

27. Action Items • How do I plan my compliance journey? (continued) • Determine if you need a Qualified Security Assessor (QSA) • Implement Vulnerability Scans from an Approved Scanning Vendor (ASV) • Address SAQ Deficiencies • Update your Documentation • Repeat!

28. Just Remember… • Data Security is an ongoing process. • Recognize the risks at all levels in your organization. • Understand what you can do to be proactive. • Determine what behaviors and processes may have to change.

29. Action Items • Budget for PCI • Not a One-Time Expense! • Initial costs may include: • Engage a QSA or other resources • System replacements • Staff costs for initial SAQ • On-going Costs Include: • Quarterly Penetration Scans • Annual SAQ exercise • Internal & External evaluations of technology in scope • Logging and Alert management • Anti-Virus subscriptions • Payment Application upgrades • Intrusion Detection Software • Resources and training to manage security measures

30. Action Items • Make sure you budget appropriately as PCI compliance is an ongoing expense to your organization. • Costs include but are not limited to items listed below: • Annual Penetration Scanning • External scans of technology in scope • Internal scans of technology in scope • Logging and Alert Management • Anti Virus upgrades/renewals • PMS/POS Annual Upgrades • Intrusion detection software • Resources and training to manage PCI and Security measures implemented.

31. Additional Resources • AH&LA publication, The Payment Card Industry Compliance Process for Lodging Establishmentshttp://ahla.com/technology • PCI Security Standards Councilhttp://pcisecuritystandards.org • Visahttp://www.visa.com/cisp • MasterCard http://www.mastercard.com/us/sdp/index.html

32. Removing Card Data From Your Hotel

33. Presenters: William Collins Executive Director – Vertical Market Strategy● Heartland Payment Systems Sue Zloth Group Manager, Product● Merchant Link, LLC Bob Lowe Director of Strategic Relationships● Shift4 Lyle Worthington, CHTP Chief Information Officer● Horseshoe Bay Resort

34. Where Does Card Data Exist?

35. Do You Really Need It? • Why do you have it in the first place? • Old Processes • You Think You Need It • Chargeback documentation • Balancing Risk and Convenience • Does the risk of having credit card data outweigh the convenience it creates?

36. Just Say No • Eliminate capturing/storing of Credit Card data unless it is absolutely necessary • Question/Challenge the need • Re-evaluate outdated processes • Card Imprinting • Credit Auth Forms • Accounting/Chargeback Reconciliation • Events/Catering • Develop contingency plans for one-offs scenarios • Off Line Authorizations • Special Guest Requests, etc. • Evaluate partner’s processes/systems • Ask, Expect, Inspect • Understand effect of introduction of new devices into your environment • Mobile/Tablets • Kiosks • Use technology to protect data you must capture

37. Using Technology PCI Approach: Protect What You “Must” Have(This used to be a straightforward statement.) • Protect Stored Data • Securely encrypt stored data • Encrypt transmissions of cardholder data across public networks • Restrict access to data on a “need-to-know” basis • Mask PAN by default, reveal to selected people on request • Over time, this gets more and more complex. Time for a technology rethink…?

38. The Challenge Imagine a princess in a castle… Securing her against attacks ofincreasing sophistication is difficult and expensive.

39. The Solution TAKE THE PRINCESS OUT OF THE CASTLE! • Purpose-Designed Solutions for Consideration • Encryption at Swipe or Keyed Entry • Tokenization

40. Technology Choices Encryption at Swipe or Key • Data is Swiped or Keyed into Encryption Device. • Transmit ONLY encrypted data through your environment. • Two Common Terms Used To Describe (Interchangeable) • End to End • Point To Point • Key To Encryption Solutions • Ensure POS/PMS has no ability to decrypt • Understand where Card Data gets decrypted • The farther down the path the better PCI is working on regulatory changes to recognize the use of this solution may reduce Merchants PCI Scope.

41. Technology Choices Tokenization • Replacing sensitive cardholder data (CHD) with a piece of data that references Card Data, stored elsewhere. • Vendors use different methods to generate Tokens • It should not be possible to reverse engineer a Token back to the actual card data. • Some solutions combine encryption at entry and tokenization; • Encryption used on data in transit • Tokenization used on data at rest Correct tokenization solutions remove the PMS from the scope of PCI DSS.

42. Technology Choices Your Action Plan • Review tokenization and Encryption at Source offerings that are supported by your software providers • Select technology solutions that reduce your PCI exposure by removing data from your applications • It’s better to not have data at all than to spend a lot of $$ trying to protect it

43. Cloud Computing Does It Solve The Problem? • Cloud Computing does not necessarily remove all scope from your property • Cards could still exist in your network • Some public cloud vendors openly state they can’t and won’t be PCI compliant. • Vendors may use other cloud vendors • For more information please attend the Cloud Computing Super Session Thursday at 9am

44. PCI Boot Camp: Best Practices

45. Presenters: JibranIlyas Senior Incident Response Consultant ● TrustWave/SpiderLabs Marty Stanton Vice President, Information Technology ● Destination Hotels & Resorts Jerry Trieber, CPA, CHAE, CFE, CFF Director of Field Accounting ● Crestline Hotels & Resorts

46. Best Practices: Types • The best practices we will discuss today fall into 3 distinct but interwoven areas: • Operations • Networks • Documentation

47. Best Practices: Operations • Operational best practices should be implemented at all hotels, restaurants, clubs, casinos, and other hospitality enterprises currently accepting credit cards as methods of payment. • Those best practices are….

48. Best Practices: Operations • Discontinue the imprinting of credit cards if still imprinting. • Review proper merchant bank retrieval request and chargeback information requirements: don’t keep documents containing complete credit card numbers for fear of losing a chargeback. • Discourage facsimile receipt of credit card authorizations:secure fax machines and their output. • Prohibit e-mail receipt of credit card numbers. • For all voice, facsimile, or other methods of card receipt, enter directly into the systemand destroy (shred) the paper.

49. Best Practices: Operations • Review Sales & Catering Department files for maintenance of documents containing credit card numbers. • Do not use Notes, Comments, or other unencrypted fields in Sales, Catering, and other electronic systems for credit card numbers. • Review who has access to view guests’complete credit numbers in both thePMS and POS. • Review if card data or computer passwords are written on a “sticky note” placed on computer monitors or are otherwise visible or unsecured.

50. Best Practices: Operations • Train users to log off their terminals and use tight auto-log off timeouts on payment applications if available. • Always consider proper storage, retention and disposal of paper and other sources of credit card numbers. • Select photocopiers and facsimiles with encrypted disk driveswith auto-delete capability (24 hours). • Control physical access to server rooms, Front Deskand any other areas where credit card numbersare stored or processed. Consider loggingand badging all visitors to these areas andrequirement to surveil all data centers byvideo.