Verizon 2011 PAYMENT CARD INDUSTRY COMPLIANCE REPORT
Is it any surprise that actual Payment Card Industry (PCI) Data Security Standard (DSS) assessments by Verizon’s team of Qualified Security Assessors (QSAs) shows growth of compliance is stagnant? Even worse, organizations that suffered data breaches were much less likely to be compliant than a normal population of PCI clients? About 20 percent of organizations passed less than half of the DSS requirements, while 60 percent scored above the 80 percent mark. For all those merchants sounding off about an annual PCI Compliance Fee, the evidence is clear that merchants still have a long ways to go. 100% PCI DSS compliance is the only acceptable statistic.
Organizations struggled most with the following PCI requirements:
- 3 (protect stored cardholder data)
- 10 (track and monitor access)
- 11 (regularly test systems and processes)
- 12 (maintain security policies)
The first two of these can easily be resolved with our hosted payment processing technology, CenPOS. If you’re going to store cardholder data, it needs to be encrypted. One of the major problems with this has been ready access to solutions for storing cardholder data for variable billing. Most gateways have a PCI Compliant solution to store encrypted card data for recurring billing, charging the same amount on a fixed schedule. However, CenPOS is unique to offer storing card data for billing a variable amount, token billing. Additionally, it is the only technology this writer is aware of that also includes interchange optimization, of major importance to companies trying to control credit card processing fees.
Requirement 10 (Tracking and Monitoring) is a major component of CenPOS. Every user has a unique login and management can micro manage permissions. Where others create a few tiered levels of permission such as cashier, finance, and administrator, CenPOS offers a plethora of options, plus management tracking and research tools.
- User Permissions: Control precise transaction types allowed, set maximum thresholds, set alerts based on responses, amounts and other criteria. Extensive Permissions enable maximum merchant protection from lower level employees, plus there are tools for secondary oversight at the admin level to mitigate risk of high level employee fraud.
- Tracking and Monitoring: The requirement calls for the tracking and monitoring of all access to network resources and cardholder data, the main objective is to maintain system logs and have procedures that ensure proper utilization, protection, and retention. According to the Verizon Report, this has historically been one of the most challenging, but is critical to forensic investigations if needed. CenPOS logs everything related to the payments process including user ID, time stamps and every other element of interaction with the system. Merchants must have their own internal logging system for their network.
Requirement 11 (Regular Testing) had the least compliance in the Verizon report. “Organizations continue to have difficulty meeting the sub-requirements regarding network vulnerability scanning (11.2), penetration testing (11.3), and file integrity monitoring (11.5).” Our recommendation is that merchants hire a qualified outside vendor to assist them with this requirement. We have no direct affiliation with such companies but know several with good reputations should you need a resource.
Requirement 12 (Security Policies) While the best laid written plans may exist, there is still the human factor. Weaknesses identified include poorly written policies, including so long that they are stuffed in a desk never to be read again, and those that are too vague. Note that the requirements are directly related to the services in scope of the organization’s PCI DSS. The more the merchant reduces their scope, the more the burden is on their service provider instead of their internal personnel. CenPOS reduces the merchant scope in several ways, including but not limited to:
- Web payments on a hosted pay page, not the merchants web page
- Electronic Bill Presentment and Payment- same as above.
- Storing all card data, encrypted, on CenPOS servers, eliminating file drawer and merchant stored data
Learn more about how CenPOS can help you with PCI DSS Compliance.