PCI Compliance
Introduction• Scott Jerabek
Product Manager
• The CBORD Group
• Founded in 1975
• Foodservice, Campus Card and Security solutions to College and University and Healthcare markets
CBORD Product Portfolio
College & University Applications
• Card Systems
• Foodservice
• Housing
• Online Ordering
• Commerce
• Security
Agenda• Introduction
• Payment Card Industry standards
• Credit card risks
• CBORD® products and PCI
• MICROS® point-of-sale
• Changes in PCI regulations
• Discussion
Payment Card Industry Standards
Entities that store, process, or transmit cardholder data
• PCI Data Security Standard (PCI-DSS)
• Covers merchants and service providers
• Payment Application Data Security Standard (PA-DSS)
• Covers third-party applications deployed on site
PCI Landscape
• CBORD® is a Service Provider and provides validated payment applications.
• MICROS provides validated payment applications.
• MerchantLink , Elavon, and Shift4 are credit card gateway solutions for MICROS.
MerchantLink
IssuerAcquiring Bank / Merchant Bank
Merchant Processor
Service Provider / CBORD
Merchant / University
Cardholder / Member / Patron
WebfoodMMID
NetCardManagerGET Funds
Settlement
CS Gold orOdyssey PCS
Micros
Payment GatewayTsys / Vital ProcessingGlobal PaymentsChase PaymentechEvalon / NovaFifth Third ProcessingRBS LynkFirst Tennessee (FHMS)Heartland PaymentsFirst DataBank of America / NPCStored Value SystemsLittle & Co.Mercury Payment Systems
Card Brands (Visa, MasterCard, AmEx, etc)
Who Is Responsible for Compliance?
• On-site systems: the merchant
• Systems hosted 100% off-site: the service provider
• Hybrid systems with off-site and on-site components that handle cardholder data
• Service provider responsible for off-site
• Merchant responsible for on-site
Goal RequirementBuild and Maintain a Secure Network
1. Install and maintain a firewall configuration to protect cardholder data2. Do not use vendor-supplied defaults for system passwords and other security parameters
Protect Cardholder Data
3. Protect stored cardholder data4. Encrypt transmission of cardholder data across open, public networks
Maintain a VulnerabilityManagement Program
5. Use and regularly update anti-virus software or programs6. Develop and maintain secure systems and applications
Implement Strong AccessControl Measures
7. Restrict access to cardholder data by business need-to-know8. Assign a unique ID to each person with computer access9. Restrict physical access to cardholder data
Regularly Monitor and Test Networks
10. Track and monitor all access to network resources and cardholder data11. Regularly test security systems and processes
Maintain an InformationSecurity Policy
12. Maintain a policy that addresses information security foremployees and contractors
PCI DSS
Impact of Compliance• Policies and procedures
• Ex: Password and remote access policies
• Ex: Quarterly vulnerability scans
• Training
• Ex: Information security training for staff
• Implementation
• Ex: Using firewalls to secure network resources
• Ex: Intrusion detection and anti-virus software
• Annual compliance assessment and remediation
PCI Scope• Any network component, server, or application
that is included in or connected to the cardholder data environment
• Reducing scope reduces risk and cost of compliance
• Move cardholder data processing off-site to third parties
• Segment on-site systems that touch cardholder data
• Limit number of personnel with full access to cardholder data (personnel other than cashiers)
Credit Card Risks• PCI DSS represents a minimum level of
security that should be applied to your organization’s handling of credit cards.
• A security breach will:
• Damage your reputation
• Cost significant time, effort, and dollars
• Negatively impact your customers
Breach Liabilities• Average cost to institution₁
• $202/breached patron record ($90 to $305)
• Average $6.6M in direct and indirect costs
• TJX
• 100 million credit card numbers
• Estimated cost to TJX range from $118M to $1.3B
• Target
• One of the largest breaches in U.S. retail history
• Investigation is ongoing
• 70 million credit card numbers
1 Forrester Research
• Required forensic audit ($50k)
• Treated at Level 1 (no more self assessment)
• Fines up to $500k
• May not be able to continue to accept credit cards
Breach Liabilities
CBORD Products and Services• CBORD supports your MICROS point-of-sale
• Support uses tools that allow you to maintain compliance
• Hosted products
• CBORD responsible for compliance (service provider)
• Minimal PCI impact on your organization
• ManageMyID®/NetCardManager®
• Webfood® online ordering
• GET Funds
CBORD Products (cont.)
• Housing systems
• Website payment integration with third parties
• Catering
• All credit card processing is hosted by CBORD
CBORD Hosting• Layered Tech
• PCI compliant, SSAE 16 Type 2 compliant
• Physical and Virtual Machines
• Validation Process
• CBORD uses Trustwave for validation
• Trustwave reviews our environment & processes, performs monthly and yearly scans
MICROS Point-of-Sale• MICROS information security resources
• MICROS PA-DSS validated versions
• Implementation guides and other documentation
• MICROS security patch documentation
• Operating-system patch testing results• http://www.micros.com/ServicesAndSupport/InformationSecurity/
• Use network segmentation to separate MICROS from the rest of your network, including CS Gold® /Odyssey PCS ®
MICROS 3700/RES• Refer to MICROS information security link for
versions
• MICROS implementation guide
• Password policies
• Database/transport encryption
• Auditing, purging, etc.
• Vaulting used to move cardholder data off-site
• TransactionVault from MerchantLink
• Card data never stored in on-site MICROS database
• Point-to-Point Encryption
• Merchantlink or Shift4 solutions utilize external readers
MICROS 9700/HMS
• Refer to MICROS information security link for versions
• MICROS implementation guide • Password policies
• Database/transport encryption
• Auditing, purging, etc.
• Vaulting used to move cardholder data off-site• Shift4
• Card data never stored in on-site MICROS database
• Point-to-Point Encryption• Shift4 solution utilizes external readers
MICROS Simphony
• Refer to MICROS information security link for versions
• MICROS implementation guide
• Password policies
• Database/transport encryption
• Auditing, purging, etc.
• Vaulting used to move cardholder data off-site
• Merchantlink, Shift4, Elavon
• Point-to-Point Encryption
• Merchantlink (Simphony 2.5, coming in 1.7), Shift4
www.micros.com/ServicesAndSupport/InformationSecurity/
Micros Resources
Grandfathering PA-DSS• Acceptable for existing
• Acceptable for new deployments
• New criteria:
• Adding credit cards (new)
• Adding Merchant ID (new)
• Add revenue center (existing)
Where are we headed?
PA-DSS and PCI-DSS 3.0• Effective January 1, 2014
• PCI-DSS 2.0 remains active until December 31, 2014
PCI-DSS 3.0 • Updates include:
• Penetration testing must follow an industry accepted methodology
• In Scope component inventory
• Evaluate malware threats for systems not commonly affected by malware
• Protect POS terminals from tampering and substitution
• Maintain information about which PCI requirements are managed by service providers vs. merchant
• Card data is encrypted at the reader and transmitted in encrypted format
• POS server never “sees” protected card data
• P2PE can reduce PCI scope
Point-to-Point Encryption (P2PE)
P2PE roadmap - Micros• Micros 3700 – Available now with
Merchantlink Transaction Shield
• Micros 9700 – Available now with Shift4
• Micros Simphony –
• Simphony 2.5 MR4 (Merchantlink Transaction Shield)
• Simphony 1.7 (Q1 2014) (Merchantlink)
• Shift4 is testing on both platforms & waiting for a few Micros bug fixes
• Visa has issued incentives to drive smart card adoption (EMV)
• Both Issuers and Acquirers impacted
• Carrots: Relief from PCI-DSS
• Sticks: Liability Shift (October 2015)
Micros, Merchantlink, & Shift4 are all working on EMV though it is not yet available on any Micros platforms.
EMV Initiatives
Resources• PCI Security Standards Council
• https://www.pcisecuritystandards.org
• Quick Reference Guide
• https://www.pcisecuritystandards.org/pdfs/pci_ssc_quick_guide.pdf
• Prioritized Approach for Beginners• https://www.pcisecuritystandards.org/documents/Prioritized_Approach_V2.0.pdf
• Ten Common PCI Myths
• https://www.pcisecuritystandards.org/pdfs/pciscc_ten_common_myths.pdf
• Validated Service Providers• http://usa.visa.com/download/merchants/cisp-list-of-pcidss-compliant-service-providers.pdf
• Validated Payment Applications• https://www.pcisecuritystandards.org/security_standards/vpa/vpa_approval_list.html
Forrester Research• Breakdown of Individual Breach Costs
In order to account for the different variable costs that can be incurred during a data breach, a survey conducted by Forrester Research provided averages in five major cost categories:
• Discovery, Response and Notification on average run about $50 per record. This cost includes “outside legal fees, notification costs, increased call center costs, marketing and PR costs, and discounted product offers.”
• Lost employee productivity on average costs about $30 per record. Dealing with the bad press and legal responsibilities are the major distractions for employees after a breach.
• Additional regulatory fines. This cost can vary greatly from $0.00 to $10 million, as ChoicePoint found out when paying civil penalties to settle the Federal Trade Commission case. Also, Visa increased the fine for mismanaging sensitive customer data from $3.4 million in 2005 to $4.6 million in 2006.
• Opportunity costs average about $98 per record, but it significantly varies from industry to industry. Forrester estimates “10% - 20% of potential customers will be scared away by a security breach in a given year,” and Ponemon’s survey indicated that 74% of its respondents lost current customers due to the breach.
• Indirect costs (for high-profile breaches) often include:
• Restitution costs - ChoicePoint is the first security breach victim to have to pay restitution costs, wherein they agreed to establish a $5 million consumer restitution fund.
• Additional security and audit requirements - For example, “DSW’s settlement with the FTC in its 2005 data breach of more than 1.4 million records requires DSW to establish and maintain a comprehensive information security program that includes administrative, technical, and physical safeguards. It also requires DSW to obtain, every two years for 20 years, an audit from a qualified, independent, third-party professional to assure that its security program meets the standards of the order,” per Forrester Research.
• Other liabilities - Replacing credit cards is a substantial ‘other cost.’ For example, Sovereign Bank was hit twice by the BJ’s Wholesale Club breach, as the first set of 81,000 replacement cards was malfunctioned.
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