PCI DSS & PII
Emily Coble
UNC Chapel Hill
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.
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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!
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PCI Version 2.0
• Has changed the way we do business
• Costs have increased
• Documentation, Documentation!
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What’s New in PCI 2.0?
• Scoping?
• Wireless Networks
• Storing Hashed Data
• Self-Assessment Questionnaire C-VT
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PCI Security Standards Council
• Global Forum
• PCIDSS, PA-DSS, PCI PTS
• Approve QSAs, ASVs
• Develop and publish PCI documentation including SAQs
• Training
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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
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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"
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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
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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
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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
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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
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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
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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
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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
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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!
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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.
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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.
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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
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Merchant Issues on Campus (Con’t)
• Bookstores
• Medical practices
• Patient collections
• Conferences
• Pledge drives
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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
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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
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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
– Identity theft
Organizational Harm
- Loss of public trust
– Embarrassment
- Legal liability
– Blackmail
- Remediation cost ($$$)
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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
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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
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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
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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.
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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
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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
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Contact Information
• Emily A. Stout Coble, Cash Manager
• 919-962-1601
• emily_coble@unc.edu
• Jennifer L. Acton, Merchant Card Accountant
• 919-962-7792
• jenacton@unc.edu
• CERTIFI Committee
• certifi@unc.edu
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Questions?
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