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  1. 1. PCI DSS & PII Shanmugavel Sankaran FixNix InfoSec Solutions Pvt Ltd
  2. 2. Session Etiquette •  Please turn off all cell phones. •  Please keep side conversations to a minimum. •  If you must leave during the presentation, please do so as quietly as possible. 2
  3. 3. 3 What is PCI? "   The Payment Card Industry Data Security Standard (PCI DSS) was created jointly in 2004 by four major credit-card companies: Visa, MasterCard, Discover and American Express. "   PCI DSS is a widely accepted set of policies and procedures intended to optimize the security of credit, debit and cash card transactions and protect cardholders against misuse of their personal information. "   Adherence to the PCI DSS aides in securing cardholder payment data that is stored, processed or transmitted by merchants and processors. "   PCI DSS specifies requirements entailing many security technologies and business processes, and reflects most of the best practices for securing sensitive information. "   PCI DSS is rapidly becoming the recognized standard for securing all organizational data, not just credit card information, and is currently being considered as the basis of legislation by several states. •  (Source: PCI Security Standards Council)
  4. 4. 4 What Is Cardholder Data? Cardholder data is any Personally Identifiable Information (PII) associated with the cardholder §  Card Holder Data §  Primary Account Number (PAN) with: §  Expiration date or §  Card holder name §  Sensitive Authentication Data §  CVV or CVC (Card Verification Values) §  Track 1 and Track 2 Data (magnetic stripe)
  5. 5. Who Must Comply? "   PCI data security requirements apply to all merchants and service providers that store, process or transmit any cardholder data. All organizations with access to cardholder information must meet the data security standards. "   However, the way in which organizations validate their compliance differs based on whether they are merchants or service providers and on specific validation requirements defined by each credit card brand. Each of the five major credit card companies has its own set of validation requirements. "   Information regarding service provider levels and validation requirements can be obtained from each individual credit card company’s Web site. "   The security requirements apply to all system components, network components, servers or applications included in, or connected to, the processing of cardholder data. 5
  6. 6. What is PCI? •  Payment Card Industry Data Security Standard •  PCI Scope includes: –  Storing, processing and transmitting of cardholder data AND any connected system •  Continuous program – not a one time project! 6
  7. 7. PCI Version 2.0 •  Has changed the way we do business •  Costs have increased •  Documentation, Documentation! 7
  8. 8. What’s New in PCI 2.0? •  Scoping? •  Wireless Networks •  Storing Hashed Data •  Self-Assessment Questionnaire C-VT 8
  9. 9. PCI Security Standards Council •  Global Forum •  PCIDSS, PA-DSS, PCI PTS •  Approve QSAs, ASVs •  Develop and publish PCI documentation including SAQs •  Training 9
  10. 10. Payment Brands, Acquirers and Processors •  Payment Brands –  Track compliance and enforce standards –  Determine event response –  Define merchant levels •  Acquirers and Processors –  Set merchant level –  Determine compliance –  Approve compensating controls 10
  11. 11. Updates from Feedback on the PCI Standards •  Request change to existing requirement/testing procedure (34%) •  Request clarification (27%) •  Request for additional guidance (19%) •  Feedback only – no change requested (12%) •  Request for new requirement/testing procedure (7%) PCI SSC Press Release Dated 9/5/12 "PCI Security Standards Council Releases Summary of Feedback on PCI Standards" 11
  12. 12. Following Topics Most Frequently mentioned Suggestions: •  PCI DSS Req 11.2 – Prescribing use of specific tools, requiring ASCs to perform internal scans and define “significant change” •  PCI DSS Scope of Assessment – Detailed guidance on scoping and segmentation •  PCI DSS Req 12.8 – Clarify terms “service provider” and “shared”, and provide more prescriptive requirements regarding written agreements that apply to service providers 12
  13. 13. Following Topics Most Frequently mentioned Suggestions (Con’t): •  PCI DSS SAQs – Suggestions for updating; either too complex or not detailed enough •  PCI DSS Req 3.4 – Further clarification and guidance since encryption and key management are complex requirements, and truncation/hashing and tokenization is not a convenient method to store and retrieve data •  PCI DSS Req 8.5 – Updating password requirements including expanding authentication beyond just passwords 13
  14. 14. PCI SCC Releases •  PCI Mobile Payment Acceptance Security Guidelines –  Offer software developers and mobile device manufacturers guidance on designing appropriate security controls to provide solutions for merchants to accept mobile payments securely PCI SSC Press Release Dated 9/13/12 14
  15. 15. PCI SSC Releases (Con’t) •  Point-to-Point Encryption (P2PE) Resources –  Program Guide and SAQ to support implementation of hardware-based P2PE solutions PCI SSC Press Release Dated 6/28/12 15
  16. 16. New PCI Professional Program (PCIP) •  PCI SSC’s 1st Individual Accreditation Program •  Designed to build greater level of PCI expertise across the industry •  Minimum 2 years IT or IT related experience and base level of knowledge and awareness in information technology, network security and architecture and payment industry participants PCI SSC Press Release Dated 9/6/12 16
  17. 17. PCI DSS Risk Assessment Guidelines The supplement outlines the relationship between PCI DSS and risk assessments, including various industry risk methodologies and key components of a risk assessment. Key components include developing a risk assessment team, building a risk assessment methodology, risks introduced by third parties, risk reporting and critical success factors. Key recommendations include: •  Formalized risk assessment methodology suited to the culture and requirements of the organization •  Continuous risk assessment •  Risk assessment cannot be used to avoid PCI DSS compliance PCI DSS Press Release Dated 11/16/12 17
  18. 18. Info Supplement – E-commerce Guidelines This supplement was released to provide guidance to merchants using electronic commerce (e-commerce) to sell goods and services in their quest to obtain PCI Compliance. •  Merchants may develop their own payment software, use a third-party software, or a combination. •  Merchants may use various technologies: payment processing applications, application-programming interfaces (APIs), inline frames (iFrames), or hosted payment pages. •  Merchants may maintain different levels of control and responsibility for managing the supporting IT infrastructure. PCI SSC Information Supplement Dated 1/2013 18
  19. 19. Info Supplement – E-commerce Guidelines (Con’t) Key Considerations: •  No option completely removes PCI DSS responsibilities. NOT even outsourcing! •  Payment applications should be PA-DSS compliant. Check them against the PCI SSC’s list of Validated Payment Applications. –  For in-house developed application, use PA-DSS as a best-practice. •  Documentation! Document relationships between the merchant and third parties in regards to PCI DSS! 19
  20. 20. PCI DSS Cloud Computing Guidelines •  The Guidelines and Information Supplement provides a overview of the cloud environment explaining common deployment and service models and how implementations may differ. •  Roles and responsibilities between the provider and customer across the different models are explained as well as guidance on how to determine and Document these responsibilities. •  PCI DSS considerations and compliance challenges are discussed including scoping, segmentation and validating compliance in the cloud environment. •  Other security considerations are explored on the business and IT side in using cloud technologies. PCI DSS Press Release Dated 2/7/13. 20
  21. 21. PCI Mobile Payment Acceptance Security Guidelines for Merchants as End-Users •  Document provides a high level introduction and overview of mobile payments and security risks of mobile devices. This “unique, complex and evolving mobile environment underscores the need for all parties in the payment chain to work together to ensure mobile acceptance solutions are deployed securely.” •  Key areas: –  Objectives and Guidance for the Security of a Payment Transaction –  Guidelines for Securing the Mobile Device –  Guidelines for Securing the Payment Acceptance Solution Appendices provided PCI DSS Press Release Dated 2/14/13. 21
  22. 22. Merchant Issues on Campus •  CDE – Cardholder Data Environment (where does the data reside – everywhere?) •  Call Centers – Voice Recording •  VOIP – Voice Over Internet Protocol •  Service Providers •  Remote Events 22
  23. 23. Merchant Issues on Campus (Con’t) •  Bookstores •  Medical practices •  Patient collections •  Conferences •  Pledge drives 23
  24. 24. Merchant Issues on Campus (Con’t) •  Food service •  Kiosks •  Paper forms •  Unrelated third parties –  Does this make you a service provider? Treasury Institute for Higher Education 2012 PCI Workshop - Walt Conway, QSA 403 Labs 24
  25. 25. What is PII? PII (Personally Identifiable Information) is any information about an individual that can be used to distinguish or trace an individual’s identity or can be linked to an individual. Examples: –  Name: full name, mother’s maiden name, alias –  Personal ID number: SS number, Passport, driver’s license or credit card numbers –  Medical, educational, financial and employment information 25
  26. 26. Personally Identifiable Information (PII) The escalation of security breaches involving personally identifiable information (PII) has contributed to the loss of millions of records over the past several years. Individual Harm Organizational Harm –  Identity theft - Loss of public trust –  Embarrassment - Legal liability –  Blackmail - Remediation cost ($$$) 26
  27. 27. Risk-Based Approach to Guarding the Security of PII If we guard our toothbrushes and diamonds with equal zeal, we will lose fewer toothbrushes and more diamonds. McGeorge Bundy fmr US National Security Advisor •  Identify all PII residing in the data environment •  Minimize the use, collection, and retention of PII •  Categorize PII by confidentiality impact level •  Apply appropriate safeguards based on confidentiality level •  Develop an incident response plan to handle PII breaches •  Exercise a coordinated effort in managing PII issues 27
  28. 28. Identify ALL PII Residing in Your Environment •  An organization cannot properly protect PII it does not know about! •  Be sure to consider your environment: –  Databases –  Shared network drives –  Backup tapes –  Contractor sites 28
  29. 29. Minimize PII Used, Collected and Stored •  The likelihood of harm caused by a breach involving PII is greatly reduced if an organization minimizes the amount of PII it uses, collects and stores. •  Best Practices: –  Review current holdings of PII and ensure they are accurate, relevant, timely and complete –  Reduce PII holdings to the minimum necessary for proper performance of business functions –  Develop a schedule for periodic review of PII holdings –  Establish a plan to eliminate the unnecessary collection and use of SSNs 29
  30. 30. Categorize PII by Confidentiality Impact Level •  All PII is not created equal. •  PII should be evaluated to determine its PII confidentiality impact level – low, moderate, or high –  The impact level indicates the potential harm that could result to the individuals and/or the organization if the PII were inappropriately accessed, used, or disclosed. 30
  31. 31. Develop an Incident Response Plan for PII Breaches •  Breaches involving PII are hazardous to both individuals and organizations •  Harm to individuals and organizations can be contained and minimized through the development of an effective IRP for breaches involving PII, including: –  Determining when and how individuals should be notified –  How a breach should be reported –  Whether to provide remedial services, like credit monitoring, to affected individuals 31
  32. 32. Encourage a Concerted Effort Regarding PII Issues •  Protecting the confidentiality of PII requires knowledge of information systems, information security, privacy as well as legal requirements. •  Organizations should encourage close coordination among their chief privacy officers, chief information officers, chief information security officers and legal counsel when making decisions related to PII policies 32
  33. 33. PCI Compliance – Trends and Tips §  Follow industry best practices for network and IT security §  Use tools and services geared toward PCI Compliance §  Align with a larger partner for credit card processing Joel Dubbin, CISSP.
  34. 34. PCI is not about securing sensitive data, it’s about eliminating data altogether. John Kindervag, Forrester Analyst and former QSA PCI Compliance – Trends and Tips
  35. 35. Virtualization §  Servers - Req 2.2.1 – One primary function per server §  Entire box in-scope? §  PCI DSS is technology neutral §  No guidance for QSAs PCI Compliance – Trends and Tips
  36. 36. Segmenta(on   §  Reduce  the  cardholder  data  landscape   §  Reduces  cost  of  remedia(on   §  Reduces  exposure   PCI Compliance – Trends and Tips
  37. 37. Outsourcing (Card data, Service Providers, Shared Hosting, Managed Services) §  Must third party be PCI certified? §  Who owns the liability? §  What entities does a PCI assessment cover? PCI Compliance – Trends and Tips
  38. 38. “PCI SWALLOWS ITS OWN TAIL” •  “I’m concerned that as long as the payment card industry is writing the standards, we’ll never see a more secure system,” (Rep. Bennie) Thompson said. “We in Congress must consider whether we can continue to rely on industry-created standards, particularly if they’re inadequate to address the ongoing threat.” • industry-swallows-its-own-tail PCI Compliance – Trends and Tips
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  45. 45. 45 •  PCI Security Standards Council- •  The SANS Institute- •  The National Institute of Standards and Technology- •  The Center for Internet Security- •  Approved QSA Listing- •  Approved ASV Listing- •  PCI KnowledgeBase •  PCI Auditor Community Site (Message Board) •  PCI DSS Compliance Demystified (Blog) Useful links
  46. 46. Questions? 46