Global Payments Not Certified PCI-DSS Compliant – Breach Costs Reach $94M

Highlights from the  Global Payments quarterly report  released January 8 2013, reveals that costs related to the 2012 data breach have reached 93.9 million and additional material costs will be incurred in 2013.  The company is still working on PCI DSS certification. pdf The company has not yet been put back on the list of PCI DSS compliant service providers, however, the impact on revenue has been “immaterial”. 

“As a result of this event, certain card networks removed us from their list of PCI DSS compliant service providers. Our removal from certain networks’ lists of PCI DSS compliant service providers could mean that certain existing customers and other third parties may cease using, referring or selling our products and services. Also, prospective customers and other third parties may choose to delay or choose not to consider us for their processing needs. In addition, the card networks could refuse to allow us to process through their networks. To date, the impact on revenue that we can confirm related to our removal from the lists has been immaterial. Also the impact on revenue of customers or other third parties who have failed to renew, terminated negotiations, or informed us they are not considering us at all, where we can confirm it is related to our removal from the lists, has been immaterial.    We continue to process transactions worldwide through all of the card networks. We hired a Qualified Security Assessor, or QSA, to conduct an independent review of the PCI DSS compliance of our systems. Our work to remediate our systems and processes is substantially complete. Our QSA is currently evaluating our remediation work. Once the QSA’s evaluation is complete we will work closely with the networks to return to the list of PCI DSS compliant service providers as quickly as possible. Our failure or a delay in returning to the list could have a material adverse effect on our business, financial condition, results of operations and cash flows.”

In addition to the credit card data breach, the “investigation also revealed potential unauthorized access to servers containing personal information collected from merchants who applied for processing services.” Merchant account applications contain sensitive information for identity theft thieves, including business owner social security numbers and home addresses.

Another potential financial blow is the class action suit related to the ‘intrusion’, as Global Payments has identified the breach. “We have not recorded a loss accrual related to this matter because we have not determined that a loss is probable.”

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iPad Mobile payments- important security notice

With a proliferation of newcomers to the market, merchants need to be aware of potential mobile payments security problems. The PCI Security Standards Council recently released new standards for developers as well as guidelines for merchants. One important aspect to ask questions about, is ‘store and forward‘.

If the mobile application enables you to accept credit cards when you cannot connect to the internet, clearly the data resides on the device, which creates a potential security risk.  This issue is addressed in a new Best Practice for Mobile Payments Developers released by the PCI Security Standards Council. Who can access the card information, pending presentment to your processor for an authorization? In what format does that data reside? If the user cannot access, is it possible other malware could access the data?

Editor’s note: Our CenPOS iPad mobile app does not support store on device and forward for presentment later. Merchants must have access to an internet connection. There are multiple options should you need to store payment data with that live connection:

  1. Zero dollar auth- validate the card only, and store data for later billing.
  2. Auth- Get an authorization for a specific sale, but don’t charge yet; store data for later billing.
  3. Repeat sale- Process transaction now, and store payment information for future billing.

In each case above, the credit card information is encrypted and replaced by a random alpha-numeric character, or ‘token’.   The encrypted payment information can never be seen again.
Accepting Mobile Payments with a Smartphone or Tablet  (PDF download from PCI Security Standards Council)

For additional information about mobile payments solutions, please contact Christine.

What is a Visa compliant credit card authorization form?

Do you accept fax order forms from your customers? Are you a business to business company needing to store credit card data on file for recurring billing of variable amounts? The typical fax authorization form does not meet Visa requirements.

Card Acceptance Guidelines for Visa Merchants (2012) PDF download from

You won’t find a “fax authorization form” in the guidelines, however, there is much information about receipt requirements.

Transaction Receipt Requirements are referenced on page 495 and Recurring Transactions starts on pg 585. The guidelines vary depending on whether your recurring billing order is from an ecommerce or other method.

Sample of a receipt for a sale from a stored card transaction:

recurring sale receipt compliant

A fax order form for a one time purchase should comply with the  standard receipt requirements. The invoice detail is generally accepted on  a separate page for B2B; the invoice number should be on the receipt.

A recurring billing order form should comply with the recurring rules and standard receipt requirements.

Chargeback prevention tips for business to business, card not present:

  • Deliver a receipt via email to the cardholder immediately upon charging the card. If there is going to be a dispute, resolve the issue quickly.
  • Send an invoice detail.
  • Use EBPP.  If you send an electronic invoice to the cardholder and they click and pay, it’s pretty hard to dispute someone else ordered the items.
  • Bill to and ship to addresses should match unless you have something in writing from the cardholder that they authorize shipping to another address.
  • Get a signed recurring billing authorization form if you’re storing card data.
  • Make sure your receipts have ‘recurring’ or ‘repeat sale’ for recurring billing.
Sample of stored card data authorization to pay form, replacing a fax form.

Fax authorization form compliant

There are too many variables to address all the options for a compliant fax authorization form in this article. For PCI DSS compliance, we recommend you replace all traditional forms with exposed credit card or check data with one that references tokens, an alpha numeric string that replaces the card data and is useless outside your payment processing system, even if stolen.

CenPOS is a universal payment processing platform that provides efficiencies for merchants and their customers, reduces PCI DSS compliance burden, and many other benefits.


CenPOS is sold through direct agents and resellers. There is also a referral program. Click here to become a CenPOS agent, reseller, or referral partner.  Click here to become a customer or call the hotline at the top of this web page.



Legal billing and payment technology increases cash flow

Here’s a sneak preview of two innovations that will improve your EBITDA in 2012 with very little effort by your legal staff. The first improves billable time data capture and the second enhances payment acceptance with a flexible PCI Compliant solution, while mitigating risk.

Capture more billable time with a new innovative mobile time tracker that enables you to capture and assign billable time by matter code and client. A key feature is the pop-up on incoming calls; when you hang up, you can immediately assign the call to a client for billing and even enter notes. The length of call is prefilled for you. This data is all accessible back in the office via a web based dashboard.

legal expense record on mobile device

Expense record on mobile device. Assign and submit billable/ reimbursable expenses on the go.

Our  innovative payment gateway works with your existing payment processors, creating numerous efficiencies, increasing cash flow, and reducing the cost of payment acceptance. Partners will have unprecedented access to client billing and payment data based on permissions granted. Clients will have new ways to receive invoices and make payments. Finance staff will have tools to automate processes and control payment processing costs. You’re in control of the most flexible, scalable payment solution available today.

virtual terminal and web payment page for law firm

Image shows example of a custom secure payment page on a law firm web site. When clients select a location, the system automatically routes the transaction to the correct merchant account and related bank account for deposit. Fully configurable for your specific needs, clients can store multiple payment methods and save time for future payments. Future proof and PCI Compliant.

We’ve been too busy bringing clients on board to create comprehensive marketing materials; technology is ready for immediate implementation. Payment Modules include: virtual terminal, batch upload, Electronic Bill Presentment & Payment (EBPP), Dashboard Reporting, report writer, shopping cart and pay page.

Legal Payment Brochure (pdf Download) . This one page document will be updated in the future.

Join clients listed in the 2011 U.S. News – Best Lawyers ‘Best Law Firm’ Rankings. Contact us now to find out why they chose our technology.



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.

encrypt cardholder data token billing variable amount

Tokens are issed for stored card data, worthless if stolen.

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.