Screenshot of PCI Rapid Comply by First Data home page
You’ve completed the online forms at PCI Rapid comply, what’s next? By now you already know that PCI is not a quarterly or annual event.
First, If you received notice of noncompliance, print the web page shown above and send to your merchant processor relationship manager to stop recurring non-compliance fees, if applicable.
Next, go to MY DOCUMENTS and download everything. These are starter documents to help you with compliance, but you’ll need to modify and add some information.
For example, on the incident response form, you’ll need to add the responsible names and contact information.
The security policy should be reviewed and disseminated to all employees that touch payments, and are involved in network security. I recommend HR manage the confirmed receipt as part of employee performance reviews. You may want to create a test to validate employee understanding, and record the date and time of completion to prove compliance.
- The Risk Management Guide has a number of blanks to fill in. If you have retail transactions, you’ll need to create a monitoring and inspection program, which includes serial numbers and locations of all equipment.
- Enter network administrator and payment administration on the access control guide. If you’re a CenPOS user, most of this requirement is managed with CenPOS Roles & user management.
- Maintaining and monitoring your program is a critical component of PCI 3.0. If you don’t currently have a compliance officer, create accountability by assigning someone to ensure monitoring is completed on schedule.
About PCI Rapid Comply: PCI Rapid Comply is a First Data service available to all their merchants. First Data merchants can use this or a third party service of their choice.
About 3D Merchant Services author Christine Speedy: Offers payment gateway and cloud solutions to reduce scope and PCI Compliance burden. No new merchant account is required, however merchant services are available upon request. PCI Rapid Comply is available to merchant clients on select processor platforms, at no additional fee.
October 30, 2014. In order for an organization to comply with PCI DSS Requirement 12.6, a formal security awareness program must be in place. There are many aspects to consider when meeting this requirement to develop or revitalize such a program. The best practices included in this information supplement are intended to be a starting point for organizations without a program in place,or as a minimum benchmark for those with existing programs that require revisions. Best Practices for Implementing Security Awareness Program v1.0, 25 pg PDF recommended for IT and PCI compliance leaders.
One of the biggest risks to an organization’s information security is often not a weakness in the technology control environment. Rather it is the action or inaction by employees and other personnel that can lead to security incidents.
The free guidance will help merchants establish security standards in their business.
Merchants who submit annual SAQ’s can continue to validate compliance with 2.0 SAQs until January 1, 2015. If merchants annual validation occurs in December,they’re not mandated to validate with version 3.0 until December 2015.
Are you ready? Every merchant is impacted by the update, which are considerable. The PCI DSS Quick Reference Guide is 40 pages so there will be no attempt to duplicate it here. Here’s some issues merchants mostly likely need to address:
- Maintain an inventory of system components that are in scope for PCI DSS and also further, protect devices from tampering. Merchants have to identify all software, hardware, networks, what it’s used for, why it’s needed. This is a difficult task for larger retail operations where equipment is regularly moved and replaced. To comply, there must be a plan to regularly inspect equipment with serial number verification.
- Ensure that related security policies and operational procedures are documented, in use, and known to all affected parties. Even if in place, rarely is the case where every employee is fully informed. Adding a component to HR employee reviews is the simplest way to initiate a system.
- Render PAN unreadable anywhere it is stored- the card number must be unreadable per 3.4.
- The CAV2/CVC2/CVV2/CID can never ever be stored. OK, this one is old, but it’s still abused so it’s being repeated again. It’s NOT OK to store if ‘for a while’.
- Control physical access for on-site personnel; access authorized and based on individual job function and revoked immediately upon termination.The vast majority of companies have little control over employee access by job function. Their equipment or software simply has too many limitations. Merchants need to micro manage what employees can do, and document each employees interaction ( who processed what transaction etc.)
Goals of the PCI Data Security Standard
- Build and maintain a secure network
- Protect cardholder data
- Maintain a vulnerability management program
- Implement strong access control measures
- Regularly monitor and test networks
- Maintain an information security policy
PCI: IS AN ongoing 3-step process
- Assess – identifying cardholder data, taking an inventory of your IT assets and business processes for payment card processing, and analyzing them for vulnerabilities.
- Remediate – fixing vulnerabilities and not storing cardholder data unless you need it.
- Report – compiling and submitting required reports to the acquiring bank and card brands you do business with.
I’ve identified a significant reason why business to business merchants using ERP’s will fail a PCI Compliance stress test. Whether you’re a consultant engaged to implement or extend an ERP, or you’re responsible for your company’s PCI Compliance, chances are even a non-hacker like me can find vulnerabilities in your security. Why? The PCI Payment Card Industry (PCI) Data Security Standards are the foundation of any security plan, but ‘real world’ and ‘written policies’ are not always aligned, leaving businesses wide open to a potential data breach.
Regardless of security efforts, it’s impossible to overcome product limitations or inefficiencies that result in employees using alternative ‘non-pci compliant’ procedures for accounts receivable. Ah, but you say someone should have known and planned better. That may be true, but there is also sometimes a disconnect between internal policies, software selection, and perceived practical necessities to conduct business efficiently. Case in point, I’ve called on many companies that forbid storing card data anywhere (per CTO and or CFO policy), however, departments have a number of practical processes that violate the policy, ‘in order to comply with other departmental requirements’. If all parties fully understood the requirements for security and business needs, there’s always a PCI Compliant solution.
What are 3 top ERP related PCI failures?
- Need for written approval to store card data and use for variable recurring billing. This is frequently on a credit card authorization form the merchant desires to keep on file.
- Business does not use the merchant services portion of the accounts receivable module due to ERP specific processor partner requirement (price, banking relationship interference or other reason given not to implement)
- Personnel collecting credit cards do not have access to the system to store credit card data (problem with user access, financial control, or personnel restriction limitations; inefficient to use in sales process)
Surprised? It’s not the ERP specifically that is cited as cause for failure, it’s procedures and flexibilities not being met that cause employees to bypass established security procedures.
How can merchants prevent employees from violating PCI Compliance guidelines?
- Follow the money. Identify all personnel involved in the sales, billing and collections process. Interview staff starting with salesmen and through to how payment data is collected, invoicing, payment processing, and collections for delinquent accounts. Always ask questions about processes that you know are not allowed or that need to be fixed.
- Implement appropriate agnostic cloud payment technology for all facets of billing and collections.
How long do you think it will take for an outsider like me to prove your business is NOT PCI compliant?
Take the FREE test and call 954-942-0483.
For businesses that are still storing cardholder data on paper, are you really PCI Compliant? Meeting requirement 9, Restricting physical access to cardholder data, is a lot harder than you may think. Here are some key questions you may face in the event of an audit, which is required in the event of a data breach.
- Do you have a secure storage area exclusively for sensitive payment data?
- Can you show an audit trail of everyone who accessed the secure area where the card data is stored, with date and time?
- Is that area restricted to only those personnel who need access to that information?
- Do you have a log to maintain a physical audit trail of visitor information and activity in any area that payments are processed, including visitor name and company, and the onsite personnel authorizing physical access?
- Do you have a visitor badge system that expires for all visitors authorized to enter areas where cardholder data is processed or maintained?
- Do you have an audit trail for the documents- created, removed from storage, and returned to storage, with names and dates?
Let’s face it, the requirements for PCI compliance are so cumbersome what merchant would want to store card data on paper? The argument that PCI Compliance paperwork takes more time for online solutions than with desktop terminals may be true, but the daily operational efficiencies and security gained far outweigh any extra paperwork.