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Riding the wave from PCI DSS Ver 2.0 to 3.0. Ed Hudson, Systemwide Director, Information Security Gina Curry, Director, Student Financial Services Center & University Bursar, CSU Sacramento . Summary Of Changes. Effective January 2014 Change Types Clarification Additional Guidance
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Riding the wave from PCI DSS Ver 2.0 to 3.0 Ed Hudson, Systemwide Director, Information Security Gina Curry, Director, Student Financial Services Center & University Bursar, CSU Sacramento
Summary Of Changes • Effective January 2014 • Change Types • Clarification • Additional Guidance • Evolving Requirement (20)
5 Key Areas • Penetration Testing • Inventorying of System Components • Vendor Relationships • AntiMalware • Physical Access and Point of Sale (POS)
Penetration Testing (11.3) • Penetration testing must follow “Industry Accepted Methodology” • Best Practice until June 30, 2015 • Why is this an issue?
Inventorying System Components (2.4) • “Maintain an inventory of system components that are in scope for PCI DSS • All hardware (Virtual or Physical) • Software (Commercial or custom) • Applications (off the shelf, external or internal) • Requires that assessors “verify a list of hardware and software components including a description of function • Authorized Wireless AP (11.1.1)
Vendor Relationships (12.8.5 & 12.9) • Requires explicit documentation • Which PCI requirements are managed by you, or by a vendor and which vendors (Matrix) • Matrix • Contractual requirements
AntiMalware(5.1.2) • Requires campuses to “identify and evaluate evolving malware threats for systems not commonly affected • Requires specific authorization from management to disable or alter antivirus and that is time limited
Physical Access and POS (9.3) • Control access for onsite personnel • Access be authorized and based on job function • Revoked immediately upon termination • Protect devices from tampering/substitution (9.9) • Consider non standard POS • Food Trucks, carts etc • Inventory and regular checking/inspection and policy
Building a plan • Partner on ownership • Engage senior executives • Plan • Communicate
Case Study: Sacramento State • Partner – SFSC partnered with the campus ISO • Plan – ISO and SFSC implemented required training, document gathering and periodic review • Developed tracking process • Engaged Administration • Imposed “penalties” for non-compliance (“Shut ‘er Down)
Case Study: Sacramento State • ICSUAM –Section 3102.05 http://www.calstate.edu/icsuam/sections/3000/3102.05.shtml • Write a Campus Policy to support the ICSUAM http://www.csus.edu/umanual/admin/ADM-0117.html
Case Study: Sacramento State • Report goes at least annually to Vice President for Administration and Business Affairs and the Vice President & Chief Information Officer • To date, 3 departments were “shut down” until they could come into reasonable compliance
Case Study: Sacramento State • You are welcome to copy our templates for your use • There is also a sample training presentation available • http://www.csus.edu/irt/is/pci/presentations/index.html