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. Card Brands (Visa, MasterCard, AmEx, etc) Settlement Acquiring Bank / Merchant Bank Issuer Cardholder / Member / Patron Merchant Processor Webfood MMID NetCardManager GET Funds Merchant / University Payment Gateway Tsys / Vital Processing Global Payments Chase Paymentech Evalon / Nova Fifth Third Processing RBS Lynk First Tennessee (FHMS) Heartland Payments First Data Bank of America / NPC Stored Value Systems Little & Co. Mercury Payment Systems CS Gold or Odyssey PCS Service Provider / CBORD Micros Merchant Link 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 PCI DSS Goal Requirement Build and Maintain a Secure Network 1. Install and maintain a firewall configuration to protect cardholder data 2. Do not use vendor-supplied defaults for system passwords and other security parameters Protect Cardholder Data 3. Protect stored cardholder data 4. Encrypt transmission of cardholder data across open, public networks Maintain a Vulnerability Management Program 5. Use and regularly update anti-virus software or programs 6. Develop and maintain secure systems and applications Implement Strong Access Control Measures 7. Restrict access to cardholder data by business need-to-know 8. Assign a unique ID to each person with computer access 9. Restrict physical access to cardholder data Regularly Monitor and Test Networks 10. Track and monitor all access to network resources and cardholder data 11. Regularly test security systems and processes Maintain an Information Security Policy 12. Maintain a policy that addresses information security for employees and contractors 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 Breach Liabilities • • • • 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 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 Micros Resources www.micros.com/ServicesAndSupport/InformationSecurity/ 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 Point-to-Point Encryption (P2PE) • • • Card data is encrypted at the reader and transmitted in encrypted format POS server never “sees” protected card data P2PE can reduce PCI scope 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 EMV Initiatives • 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. 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 Discussion Thank You! Scott Jerabek [email protected] 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.