NC Financial Systems Conference 2010

PCI Compliance & Credit Card Processing

What Does It Mean & How Do We Get There?

Agenda

1. PCI / PA-DSS / PTS1. PCI / PA-DSS / PTS

2. Changes & Deadlines2. Changes & Deadlines

3. Watch Out For……3. Watch Out For……

4. University Strategies4. University Strategies

Payment Card Industry EvolutionFocus on Application & PIN Transactions

PAPTS

Focus on Application & PIN Transactions

PAPTS

Focus on Merchant

PCI

Focus on Merchant

PCIFocus on Banks, Processors, Gateways

CISPPED

Focus on Banks, Processors, Gateways

CISPPED

Phase 1Phase 1 Phase 2Phase 2 Phase 3Phase 3

Who?

TrustWave or other

ASV

You

TouchNet CashNetNelNet

3rd PartyApps

Who are the major players?

University Compliance

PCI SecurityStandards

Council

Why PCI?

We are all merchantsAgreed to complyAgreed to fines and feesNo one can relieve us of our obligations

PCI-DSSApplies to all merchantsRequires an annual self-assessment for each method of paymentRequires quarterly network scan by approved scanning vendor (ASV)

https://www.pcisecuritystandards.org

PCI – Getting Started

https://www.pcisecuritystandards.org/pdfs/pcissc_getting_started_with_pcidss.pdf

PCI Standard Requirements

https://www.pcisecuritystandards.org/pdfs/pcissc_getting_started_with_pcidss.pdf

PCI

PA-DSS

• Applies to software vendors and others who develop and sell payment applications

• Applies to storing, processing and transmitting data

• In house payment applications that are not sold to a 3rd party are not subject to PA-DSS but must still be secured in accordance with PCI-DSS

Vendor – responsible for certification processMerchant – verify application is listed by the PCI_Security Standards Council as a PA-DSS certified payment application (specific to its release number)

https://www.pcisecuritystandards.org/security_standards/vpa

PA-DSS Process

• Review end-to-end functions• All input and output

Where stored, who has access to PC, where data goes• Error Conditions

Cached information, notifications• Interfaces/Connections to Other Systems• Data Flow• Encryption Mechanisms• Authentication Mechanisms

Validated Payment Applications

PTS

• Formerly PCI PED• Set of security requirements focused on

characteristics and management of devices used in the protection of cardholder PINs and other payment processing related activities Requirements are for manufacturers to follow in the design, manufacture and transport of a device to the entity that implements it

• Merchants should only use PIN entry devices that are tested and approved by the PCI SSC

https://www.pcisecuritystandards.org/security_standards/ped/pedapprovallist.html

Approved PIN Transaction Security

Why Comply?

We are all merchantsAgreed to complyAgreed to fines and feesNo one can relieve us of our obligations

Why Are You Vulnerable?Business vs Faculty vs VendorHistorical Data that Hasn’t Gone AwayPeople trying to “be helpful”Bad Business Practice

Phone Payments Alumni ListsMailing Lists

What you don’t know CAN hurt you……

Cost of Not Complying

•Recarding•Fines from Bank, Visa and card companies

• Insurance Costs•Cost to University’s Image

www.adamdodge.com/esi

Changes & Deadlines

NOW – PCI-DSS compliance – should be performing self-auditsJuly 1, 2010 – PA-DSS & PTSMore Changes Coming !!!

Lifecycle Process for Changes to PCI DSS

What To Do

• Embrace PCI DSS Objectives as a Reality of Doing Business• Educate Campus Merchants about PCI Security Standards

• Find the Needles, not the Haystacks• Start in Business Office• Expand to the Campus

• Enforce PCI Requirements Campus-Wide• Have a Procedure• Understand the Risks

• Leverage a Strategy that Minimizes the Number of Systems on Campus which Touch Sensitive Payment Data• Architect Big, Implement Small

• Replace Out-Dated POS equipment with PTS-Compliant Devices

• Download PCI Security Council Quick Reference Guide - https://www.pcisecuritystandards.org/pdfs/pci_ssc_quick_guide.pdf

• Become familiar with NC OSC PCI Security Compliance Program website

http://www.osc.nc.gov/programs/risk_mitigation_pci.html

OSC PCI Compliance WebsiteUnderstanding PCI Data Security

• PCI Security Standards Overview• Understanding PCI Data Security Pr

esentation • Applicability of PCI Data Security St

andard (PCI DSS) to Card Capture Methods

• Policy for Security Incident Plan• PCI Related Memorandums• Common Payment Services - Repor

t of Compliance

PCI Data Security Resources • State E-Commerce Program• PCI Security Standards Council, LLC• PCI Data Security Standard (v. 1.2)• PCI Self-Assessment Questionnaire

(v. 1.2)• PCI Penetration Testing Requirement

11.3• VISA's Cardholder Information Secur

ity Program (CISP)• MasterCard's Site Data Protection Pr

ogram (SDP)• Glossary of Terms • List of Compliant Service Providers• Payment Application Data Security St

andard• Visa's List of Validated Payment Appl

ications • PCI Council's List of Validated Paym

ent Applications• Sample Addendum for Requirement

12.8• TrustWave

TrustKeeper Validation Service • Compliance with PCI Data Secur

ity Standards• Validation of PCI Compliance Re

quirements• Trustwave Validation Enrollment• Trustkeeper Portal Login• Responding to Notice of Non-Co

mpliance• PCI Validation for Service Provid

ers

OSC PCI Compliance Website

Things to Look For

“Rogue” DepartmentsMiscellaneous RevenueMailers with credit card information mailed back to universityReceipting – type of payments should be monitored

Point of Sale (POS)Analog lineMake sure model does not retain card information; should be

truncatedWeb-Based Applications

Processor – FirstData, VisaNet, Nashville, etc.Payment Gateway – CPS, PayPoint Gateway, 3rd party with OSC

approval3rd party applications – PCI certificate of compliancy

if using 3rd party credit card, ensure they remit on daily basis

The Clock is Ticking…

PCI References

• PCI Council: https://www.pcisecuritystandards.org/index.shtml

• OSC PCI: http://www.osc.nc.gov/programs/risk_mitigation_pci.html

 • Useful Info:

http://www.pciknowledgebase.com/

 

Cost of Non-Compliance

• Did you know: – A breach with any one merchant on our

campus could mean that ALL credit card transactions for the University may cease. • We each have ONE chain number for each

campus • Each chain has all our merchants attached to it. • The cut off comes at the chain level – not the

merchant

Cost of Non-Compliance

In 2008 millions personal credit card records of Americans were compromised.

Cost of Non-Compliance

If your credit card processing system is breached/compromised

• Your credit card system is stopped• You pay fines • You pay for forensics audit (from $10,000-$100,000)• You lose the right to process credit cards until

compliance is achieved and verified. • You pay for replacement cost of cards that were

compromised (about $200 per card)• You pay more fines based on if any of the credit cards

were used fraudulently (up to $500,000 per incident)

What ECU is Doing

• Currently all Credit Card Transactions, except athletics are using Touchnet

• Athletics use Paciolan System• Students use Bill Payment Suite

– Statements – Banner Balances – Banner payment/charge history

What ECU is Doing

Touchnet U-PAY Sites

• Parking & Traffic (T2)• Alumni (Imodules)• Continuing Education (AceWare)• Housing (CBORD)• Orientation (In-house written) • On-Line Giving (In-house written)

What ECU is Doing

Touchnet Payment Point – Graduate School Applications (Banner)

Touchnet

eCheck – In process of implementing

Convenience Fees – In process of implementing (along with stopping the use of VISA credit cards)

What ECU is Doing

Touchnet U-Store (works as a “shopping cart type application)

Evaluating for small campus divisions that would like to do credit card processing:

Library – Membership, special events

College of Education – camp fees

College of Business – tests/ events

What ECU is Doing

Security Department Changes that are coming to ECU

• Locking down any PC that does credit card transactions (athletics & box office & staff computers) – No adobe– No administrative privileges– No software updates– No profile changes– Static IP for credit card processing only – Staff doing credit card processing with other tasks will have two

computers – one dedicated to Credit Card processing

What ECU is Doing

• No electronic storage of Credit Card numbers is allowed

• Financial Services is responsible for credit card compliance – IT advices.

• Paper copies with credit card numbers are securely locked up and only kept during the time that the card number is needed. It is destroyed when not needed anymore.

• All credit card requests go through IT, Cash Management Director and Finance

What UNCW is Doing

• No electronic storage of Credit Card numbers is allowed

• Controller’s Office is responsible for credit card compliance – IT advices.

• Paper copies with credit card numbers are securely locked up and only kept during the time that the card number is needed. It is destroyed when not needed anymore.

• All credit card requests go through Controller’s Office, Director of Student Accounts/Cashier’s Office and Financial Systems

What UNCW is Doing

• Currently all new Credit Card Transactionsare using Touchnet

• Students use Bill Payment Suite – Statements – Banner Balances – Banner payment/charge history – eRefunds

What UNCW is Doing

Touchnet U-PAY Sites• Athletics (JumpTV & In-house written)• Graduate School (Apply Yourself)• Public Service (AceWare)• Housing (In-house written)• Orientation (In-house written) • Annual Giving (RuffaloCody)• Alumni Association (In-house written)• Creative Writing Ecotone (One Cow Standing)• Admissions (AdmissionsPro)• Box Office (eTix)

What UNCW is Doing

Touchnet Payment Point – Registrar Office Reenrollment Fees (Banner)

Touchnet

PayPath –Implementing July 1, 2010

Convenience Fees – In process of implementing (along with stopping the use of VISA credit cards) for student payments only

University Strategies

Round Table Discussion of How Universities are Handling PCI Compliance and e-Commerce

Back-to-Basics List for PCI Compliance (All of these items are doable, but require focused effort and attention to detail.)

• Identify all campus merchants and pay points

• Verify all payment software is PA-DSS certified

• Verify PIN data collection devices are PTS compliant

• Verify that any hosting centers in use are PCI DSS certified

• Complete and submit annual compliance reports

• Perform regular PCI training for campus merchants

• Scan campus computers for unprotected card data

How and What are WE Doing?