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PCI Compliance: The Gateway to Paradise. Agenda. Background What is PCI-DSS? Who must comply? Cost of non-compliance Digital Dozen Higher Education Challenges Centralize Compliance. Background. ???. Cardholder Information Security Program (CISP). Site Data Protection Program (SDP).
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PCI Compliance: The Gateway to Paradise
Agenda • Background • What is PCI-DSS? • Who must comply? • Cost of non-compliance • Digital Dozen • Higher Education Challenges • Centralize Compliance
Background ??? Cardholder Information Security Program (CISP) Site Data Protection Program (SDP) Confused Merchants Discover Information Security Compliance (DISC) Data Security Standard (DSS)
What is PCC-DSS? • Payment Card Industry Data Security Standard (PCI-DSS) • Card Associations founded an LLC https://www.pcisecuritystandards.org • One program now • Mission: Enhance payment account data security by fostering a broad adoption of PCI-DSS
What is PCC-DSS? Participating organizations provide feedback on evolution of PCI Policy decisions made by Executive Committee
Who Must Comply? “Payment Card Industry (PCI) Data security requirements apply to all Members, merchants, and service providers that store, process or transmit cardholder data.” *Payment Card Industry Data Security Standard
Cost of Non-Compliance In the event of the a breach the acquirer CAN make the merchant responsible for: • Any fines from PCI-Co • Up to $500,000 per incident • Cost to notify victims • Cost to replace cards (about $10/card) • Cost for any fraudulent transactions • Forensics from a QDSC • Level 1 certification from a QDSC
Cost of Non-Compliance • Example: 50,000 credit cards stolen • PCI Penalty - $100,000 per incident • $500,000 if you do not have a self-assessment • Card Replacement - $500,000 • Fraudulent Transaction – $61,750,000 • $1,235 - 2004 average fraudulent transaction • Bad Publicity – Priceless!
Higher Education Challenge • Higher education networks comprise an estimated 15% of the total advertised Internet address space* • Extremely “open” by tradition and culture • Highly connected networks to commercial internet, regional, national, and international research networks • Communities range from 1,000 to 200,000 people • Thousands of networked devices • Departments control local technology and act independently • Understaffed IT department * University of Indiana
Centralize Compliance • Get executive buy-in • Define a commerce committee • IT • Security • Internal Audit • Treasury • CFO
Centralize Compliance Define and publish credit card handling policy • Acceptable payment channels • Handling of PII (Personally Identifiable Information) • Requesting merchant IDs • Applicability to University employees, work study… • Background and credit checks for employees handling credit cards • Training and acknowledgement • Use of vendors
Centralize Compliance • Gap analysis • Review all existing merchants and their procedures • Identify “urgent improvements” • Operational remediation plan • Technical remediation plan • Compliance maintenance • Rules will change • Systems will change
Centralize Compliance Consider outsourcing • Get as many credit card numbers off campus as possible • Use a service provider to process credit card transactions • Approved scanning vendors • Approved hosting centers
Questions? David R. King President Nelnet Business Solutions dking@infinet-inc.com