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Got Credit Cards? PCI Compliance for Small and Medium Companies

Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

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Page 1: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

Got Credit Cards?PCI Compliance for Small and Medium Companies

Page 2: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

IntroductionAdam Taylor

• Vice President of Development at Essent Corporation

• Promotional Product Industry Specialist

• Working with Suppliers and Distributors for 15 years

• 2018 PPAI Technology Committee Appointee

Page 3: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

The Big Questions to Ask

• What is in scope?

• Is it in compliance?

Page 4: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

Table of Contents

• What is PCI and Why Should I Care?

• Scoping

• PCI Requirements

• How to Comply

Page 5: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

Abstract/Goals

• New to PCI• Background of what PCI is

and why it’s important• Ideas of where to go next

• Veterans to PCI• Bring PCI Back to the

forefront• Reinforce Continued

Diligence• Learn something New

Page 6: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

What is PCI Compliance?

• As an Industry we care about consumer product safety. PCI is about consumer safety of the payment card transaction

• Who does it impact?• All entities that store, process,

and/or transmit cardholder data

Page 7: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

Poll: Who has started on their PCI Compliance Journey?

Page 8: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

Poll: Who has completed it?

Page 9: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

PCI Compliance is a Never-Ending Journey

Page 10: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

PCI Compliance Journey

• It’s a never ending journey

• Make it part of your BAU culture

Page 11: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

In The News

94 Million Records Stolen in 2006/2007

http://www.computerworld.com/article/2539588/security0/tjx-violated-nine-of-12-pci-controls-at-time-of-breach--court-filings-say.html

Page 12: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

In The News

40 million credit and debit cards potentially compromised in 2013

https://www.nytimes.com/2014/09/20/business/ex-employees-say-home-depot-left-data-vulnerable.html

Page 13: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

In The News

Data Breach Compromises 56 Million Credit Cards in 2014

https://www.computerworld.com/article/2487425/cybercrime-hacking/target-breach-happened-because-of-a-basic-network-segmentation-error.html

Page 14: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

In The News

143 million accounts compromised in 2017

https://www.wired.com/story/equifax-breach-no-excuse/

Page 15: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

Audience Participation!

Page 16: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

Scenario Analysis & Scoping

Page 17: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

System Topology

• Identify how Payment Card information gets into your organization

• Take a close look at that system that the Payment Card was entered into

• How is it connected in the network?

• What is the internet firewall?• What else is it connected to?

Page 18: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

Audience Participation: Draw the way Payment Card data flows

through your ecosystem.

Page 19: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

Lets take a look at some system examples.

Page 20: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

Web Browser

3rd Party Website

Ecommerce Example #1

Database

Business Management

System

Payment Gateway Service

Page 21: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

Web Browser

3rd Party Website

Ecommerce Example #2

Database

Business Management

System

Payment Gateway Service

Page 22: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

On Premise BMS Processing

Database

Business Management

System

Payment Gateway Service

Page 23: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

3rd Party Cloud Based BMS Processing

Database

Business Management

System

Payment Gateway Service

Cloud BMS

Page 24: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

Reality Some of Us Face ...

Database

Business Management

System

Payment Gateway Service

Cloud BMS

Internet

Page 25: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

Reality Most of Us Face …

Page 26: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

Process Flow: Taking Payment Card Info by Phone• VOIP?

• Person answering phone takes the Payment Card info

• Person transfers to the Accounting Department and they repeat the process

Page 27: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

Process Flow: Entering Payment Card Info into Your System• Employee gets the Payment

Card Information from the Buyer

• Employee is logged into their computer

• Employee is on the network• Employee opens the System• Employee enters the data on

the system and it’s sent over the network to processor

Page 28: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

Process Flow:Brick and Mortar• End User walks to Kiosk

• End User hands card to Clerk

• Clerk enters Card into system

Or

• End User walks to Kiosk

• End User Inserts card into Terminal

Page 29: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

Breaking down the 12 PCI Requirements

Page 30: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

PCI Requirements: Firewall

Requirement #1

• Install and maintain a firewall configuration to protect cardholder data• ~22 requirements

Page 31: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

2017 non-compliance attributed to data breach

Source: SecurityMetrics' Payment Card Industry Forensic Investigation

Page 32: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

PCI Requirements: Passwords

• Requirement #2 - Do not use vendor-supplied defaults for system passwords and other security parameters• ~12 requirements

Page 33: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

2017 non-compliance attributed to data breach

Source: SecurityMetrics' Payment Card Industry Forensic Investigation

Page 34: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

PCI Requirements: Stored Data

• Requirement #3: Protect stored cardholder data• ~23 requirements

Page 35: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

2017 non-compliance attributed to data breach

Source: SecurityMetrics' Payment Card Industry Forensic Investigation

Page 36: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

PCI Requirements: Encryption

• Requirement #4: Encrypt transmission of cardholder data across open, public networks• ~4 requirements

Page 37: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

2017 non-compliance attributed to data breach

Source: SecurityMetrics' Payment Card Industry Forensic Investigation

Page 38: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

PCI Requirements: Antivirus

• Requirement #5: Protect all systems against malware and regularly update antivirus software or programs• ~6 requirements

Page 39: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

2017 non-compliance attributed to data breach

Source: SecurityMetrics' Payment Card Industry Forensic Investigation

Page 40: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

PCI Requirements: Security

• Requirement #6 - Develop and maintain secure systems and applications• ~29 requirements

Page 41: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

2017 non-compliance attributed to data breach

Source: SecurityMetrics' Payment Card Industry Forensic Investigation

Page 42: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

PCI Requirements: Access

• Requirement #7 - Restrict access to cardholder data by business need-to-know• ~10 requirements

Page 43: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

2017 non-compliance attributed to data breach

Source: SecurityMetrics' Payment Card Industry Forensic Investigation

Page 44: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

PCI Requirements: Access ID

• Requirement #8 - Identify and authenticate access to system components• ~25 requirements

Page 45: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

2017 non-compliance attributed to data breach

Source: SecurityMetrics' Payment Card Industry Forensic Investigation

Page 46: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

PCI Requirements: Physical Access

• Requirement #9 - Restrict physical access to cardholder data• ~27 requirements

Page 47: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

2017 non-compliance attributed to data breach

Source: SecurityMetrics' Payment Card Industry Forensic Investigation

Page 48: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

PCI Requirements: Monitor

• Requirement #10 - Track and monitor all access to network resources and cardholder data• ~34 requirements

Page 49: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

2017 non-compliance attributed to data breach

Source: SecurityMetrics' Payment Card Industry Forensic Investigation

Page 50: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

PCI Requirements: Testing

• Requirement #11 - Regularly test security systems and processes• ~17 requirements

Page 51: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

2017 non-compliance attributed to data breach

Source: SecurityMetrics' Payment Card Industry Forensic Investigation

Page 52: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

PCI Requirements: Policy

• Requirement #12 - Maintain a policy that addresses information security for all personnel• ~41 requirements

Page 53: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

2017 non-compliance attributed to data breach

Source: SecurityMetrics' Payment Card Industry Forensic Investigation

Page 54: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

PCI Requirements Summary

• Sweet only 12 requirements!• I can start this in Q4 after I get everything else done

• OMG ~250 requirements!• I’ll never get that done, I don’t have time for that! I’m

just not going to start!

Page 55: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

How to Comply: Prioritized Approach

https://www.pcisecuritystandards.org/document_library

Helps you identify and hit highest risk areas first for quick wins

• Phase 1 – 4%

• Phase 2 – 37%

• Phase 3 – 10%

• Phase 4 – 21%

• Phase 5 – 12%

• Phase 6 – 15%

Page 56: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

How to Comply: Merchant Levels

• Merchant Levels• Level One: Over 6m Payment Card transactions per year

• QSA required• Annual Report on Compliance (ROC) by Qualified Security Assessor (QSA) • Quarterly network scan by Approved Scanning Vendor (ASV) • Penetration Test • Internal Scan • Attestation of Compliance Form

• Level Two: 1m to 6m Payment Card transactions per year• Level Three: 20k to 1m Payment Card transactions per year• Level Four: Under 20k Payment Card transactions a year

• Annual SAQ• Quarterly network scan by ASV• Attestation of Compliance Form• Additional requirements depending on SAQ type (e.g. Penetration Test, Internal

Scan)

Page 57: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

How to Comply:The Self Assessment Questionnaire• SAQ

• Which is right for you?• Good news there’s a chart for that

Page 58: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

SAQ

Page 59: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

How to Comply: A 6-Step Process

ScopeDetermine which system components and networks are in scope for PCI DSS

Good news: You started this today!☺ 1

Page 60: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

How to Comply: A 6-Step Process

AssessExamine the compliance of system components in scope following the testing procedures for each PCI DSS requirement.

Use the Prioritized Approach 2

Page 61: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

How to Comply: A 6-Step Process

ReportAssessor and/or entity completes required documentation (e.g. Self-Assessment Questionnaire (SAQ) or Report on Compliance (ROC)), including documentation of all compensating controls

Know if you are eligible for SAQ, and what SAQ to do

3

Page 62: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

How to Comply: A 6-Step Process

AttestComplete the appropriate Attestation of Compliance (AOC)

Sign off on the SAQ 4

Page 63: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

How to Comply: A 6-Step Process

SubmitSubmit the SAQ, ROC, AOC and other requested supporting documentation such as ASV scan reports to the acquirer (for merchants) or to the payment brand/requestor (for service providers)

Send it out

5

Page 64: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

How to Comply: A 6-Step Process

RemediateIf required, perform remediation to address requirements that are not in place, and provide an updated report.

Repair and report 6

Page 65: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

Reference Links

• References• https://www.pcisecuritystandards.org/documents/PCIDSS_QR

Gv3_2.pdf?agreement=true&time=1506439109190

• https://www.pcisecuritystandards.org/documents/PCI_DSS_v3-2.pdf?agreement=true&time=1506629950439

• https://www.pcisecuritystandards.org/document_library

• Attach Prioritized Approach

• Attach Quick Guide

• PCI_DSS_V3-2

Page 66: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

The Big Questions to Ask

• What is in scope?

• Is it in compliance?

Page 67: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

Review

• What is PCI and Why Should I Care?

• Scoping

• PCI Requirements

• How to Comply

Page 68: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

Thank You!Connect on LinkedIn! http://linkedin.com/in/adam-taylor-a8510b2

Page 69: Got Credit Cards? - PPAI Expo Got Credit Cards - PCI... · Introduction Adam Taylor •Vice President of Development at Essent Corporation •Promotional Product Industry Specialist

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