PCI Compliance
Introduction
Scott Jerabek
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Product Manager
The CBORD Group
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Founded in 1975
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Foodservice, Campus
Card and Security
solutions to College
and University and
Healthcare markets
CBORD Product Portfolio
College & University
Applications
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Card Systems
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Foodservice
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Housing
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Online Ordering
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Commerce
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Security
Agenda
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Introduction
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Payment Card Industry standards
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Credit card risks
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CBORD® products and PCI
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MICROS® point-of-sale
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Changes in PCI regulations
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Discussion
Payment Card Industry
Standards
Entities that store, process, or transmit cardholder data
PCI Data Security Standard (PCI-DSS)
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Covers merchants and service providers
Payment Application Data Security Standard
(PA-DSS)
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Covers third-party applications deployed on site
PCI Landscape
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CBORD® is a Service Provider and provides validated payment applications.
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MICROS provides validated payment applications.
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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?
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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
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Service provider responsible for off-site
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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
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Policies and procedures
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Ex: Password and remote access policies
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Ex: Quarterly vulnerability scans
Training
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Ex: Information security training for staff
Implementation
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Ex: Using firewalls to secure network resources
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Ex: Intrusion detection and anti-virus software
Annual compliance assessment and
remediation
PCI Scope
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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
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Move cardholder data processing off-site to
third parties
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Segment on-site systems that touch cardholder
data
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Limit number of personnel with full access to
cardholder data (personnel other than cashiers)
Credit Card Risks
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PCI DSS represents a minimum level of
security that should be applied to your
organization’s handling of credit cards.
A security breach will:
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Damage your reputation
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Cost significant time, effort, and dollars
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Negatively impact your customers
Breach Liabilities
Average cost to institution₁
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$202/breached patron record ($90 to $305)
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Average $6.6M in direct and indirect costs
TJX
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100 million credit card numbers
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Estimated cost to TJX range from $118M to $1.3B
Target
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One of the largest breaches in U.S. retail history
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Investigation is ongoing
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70 million credit card numbers
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Forrester Research
Breach Liabilities
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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
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CBORD supports your MICROS point-of-sale
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Support uses tools that allow you to maintain
compliance
Hosted products
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CBORD responsible for compliance (service
provider)
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Minimal PCI impact on your organization
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ManageMyID®/NetCardManager®
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Webfood® online ordering
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GET Funds
CBORD Products (cont.)
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Housing systems
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Website payment integration with third parties
Catering
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All credit card processing is hosted by CBORD
CBORD Hosting
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Layered Tech
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PCI compliant, SSAE 16 Type 2 compliant
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Physical and Virtual Machines
Validation Process
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CBORD uses Trustwave for validation
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Trustwave reviews our environment &
processes, performs monthly and yearly
scans
MICROS Point-of-Sale
MICROS information security resources
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MICROS PA-DSS validated versions
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Implementation guides and other
documentation
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MICROS security patch documentation
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Operating-system patch testing results
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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
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Refer to MICROS information security link for
versions
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MICROS implementation guide
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Password policies
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Database/transport encryption
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Auditing, purging, etc.
Vaulting used to move cardholder data off-site
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TransactionVault from MerchantLink
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Card data never stored in on-site MICROS database
Point-to-Point Encryption
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Merchantlink or Shift4 solutions utilize external readers
MICROS 9700/HMS
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Refer to MICROS information security link for
versions
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MICROS implementation guide
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Password policies
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Database/transport encryption
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Auditing, purging, etc.
Vaulting used to move cardholder data off-site
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Shift4
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Card data never stored in on-site MICROS database
Point-to-Point Encryption
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Shift4 solution utilizes external readers
MICROS Simphony
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Refer to MICROS information security link for versions
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MICROS implementation guide
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Password policies
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Database/transport encryption
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Auditing, purging, etc.
Vaulting used to move cardholder data off-site
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Merchantlink, Shift4, Elavon
Point-to-Point Encryption
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Merchantlink (Simphony 2.5, coming in 1.7), Shift4
Micros Resources
www.micros.com/ServicesAndSupport/InformationSecurity/
Grandfathering PA-DSS
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Acceptable for existing
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Acceptable for new deployments
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New criteria:
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Adding credit cards (new)
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Adding Merchant ID (new)
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Add revenue center (existing)
Where are we headed?
PA-DSS and PCI-DSS 3.0
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Effective January 1, 2014
PCI-DSS 2.0 remains active until
December 31, 2014
PCI-DSS 3.0
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Updates include:
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Penetration testing must follow an industry
accepted methodology
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In Scope component inventory
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Evaluate malware threats for systems not
commonly affected by malware
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Protect POS terminals from tampering and
substitution
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Maintain information about which PCI
requirements are managed by service providers
vs. merchant
Point-to-Point Encryption (P2PE)
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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
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Micros 3700 – Available now with
Merchantlink Transaction Shield
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Micros 9700 – Available now with Shift4
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Micros Simphony –
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Simphony 2.5 MR4 (Merchantlink Transaction
Shield)
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Simphony 1.7 (Q1 2014) (Merchantlink)
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Shift4 is testing on both platforms & waiting
for a few Micros bug fixes
EMV Initiatives
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Visa has issued incentives to drive smart
card adoption (EMV)
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Both Issuers and Acquirers impacted
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Carrots: Relief from PCI-DSS
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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
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https://www.pcisecuritystandards.org
Quick Reference Guide
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https://www.pcisecuritystandards.org/pdfs/pci_ssc_quick_guide.pdf
Prioritized Approach for Beginners
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https://www.pcisecuritystandards.org/documents/Prioritized_Approach_V2.0.pdf
Ten Common PCI Myths
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https://www.pcisecuritystandards.org/pdfs/pciscc_ten_common_myths.pdf
Validated Service Providers
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http://usa.visa.com/download/merchants/cisp-list-of-pcidss-compliant-service-providers.pdf
Validated Payment Applications
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https://www.pcisecuritystandards.org/security_standards/vpa/vpa_approval_list.html
Discussion
Thank You!
Scott Jerabek
smj@cbord.com
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:
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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.”
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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.
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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.
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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.
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Indirect costs (for high-profile breaches) often include:
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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.
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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.
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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.