University of the West of England, Bristol PDQ (Process Data Quickly) Management Policy and Procedure Version 0.1 0.2 0.3 0.4 Issue Date 18/11/2014 01/01/2015 26/01/2015 04/02/2015 Author Sue Bressington Sue Bressington Sue Bressington Sue Bressington Detail Initial draft Final draft Final document Update to include Merchant Account requirements Contents Executive Summary .......................................................................................................................................... 3 1 Background ..................................................................................................................................... 4 1.1 PDQ types and connection options .................................................................................................. 4 1.2 Scope ............................................................................................................................................... 4 1.3 Security requirements ..................................................................................................................... 4 2 Responsibilities ............................................................................................................................... 5 3 PDQ application process .................................................................................................................. 6 3.1 Application process for ordering a PDQ ........................................................................................... 6 3.1.1 Requesting a new PDQ terminal for your outlet or service .............................................................. 6 3.1.2 Requesting a temporary PDQ for an event ...................................................................................... 6 3.2 Removing a PDQ terminal from your outlet or service .................................................................... 6 3.2.1 Removing/de-commissioning a PDQ terminal from your outlet or service ...................................... 6 3.2.2 Returning a PDQ terminal ................................................................................................................ 6 3.2.3 Cancelling a merchant account ........................................................................................................ 6 3.3 Making changes to a PDQ terminal in your outlet or service ........................................................... 6 3.3.1 Replacing an old or faulty PDQ terminal .......................................................................................... 7 3.3.2 Moving a PDQ terminal to another location .................................................................................... 7 4 Decision-making and approval process for PDQ applications .......................................................... 7 4.1 Approval of new PDQ applications .................................................................................................. 7 4.2 Rejected PDQ applications .............................................................................................................. 7 5 PDQ Cost recharges – hire charges and transaction charges ............................................................ 7 6 PDQ Inventory ................................................................................................................................. 8 6.1 Annual audit of devices ................................................................................................................... 8 7 PDQ Training ................................................................................................................................... 8 7.1 PDQ use and security ....................................................................................................................... 8 8 Merchant Account (MID) control ..................................................................................................... 9 8.1 Barclaycard (Merchant Acquiring Bank) .......................................................................................... 9 8.2 American Express (AMEX) ............................................................................................................... 9 Finance Document Page 2 of 9 Executive Summary The University of the West of England has an obligation to protect confidential cardholder data through compliance with the Payment Card Industry Data Security Standards (PCI DSS), version 3.0. Therefore, the secure processing of card payment transactions using card terminals, is key to achieving compliance. Failure to comply with this policy could result in cardholder data becoming compromised, data security breaches, substantial fines, severe reputational damage and/or the loss of income, and/or the removal of PDQ machines. The purpose of this policy/procedure is to set out the University’s requirements with regards to the management and change control of all Card terminals (PDQ’s) in use, whilst considering its obligations under PCI DSS. It applies to all outlets and services within the University that process card payments via a PDQ. This policy should be compatible and read in conjunction with the financial UWE PCI DSS Policy, IT Security Policy, UWE Data Protection Policy and the processes and associated financial control framework. Note: wherever a statement in this policy refers to ‘Card’, the statement applies to credit, debit, charge, and procurement cards, unless specifically stated otherwise. Finance Document Page 3 of 9 1 Background 1.1 PDQ types and connection options Chip and PIN machines / devices are more commonly known as PDQ terminals (or PDQ’s). They are used to process debit or credit card payment transactions, face-to-face, where the customer is present. There are several types of PDQ terminal: The counter top machine is for use in point of sale transactions and uses a telephone or broadband connection Portable terminals use Bluetooth technology and are common in cafés, restaurants, bars or wherever a PDQ terminal is taken to the customer to carry out a transaction The mobile terminal uses a SIM card and GPRS to allow payments away from business premises PDQ’s may be connected to an IT network infrastructure by any of the following means: Shared phone line between your phone and your card machine(s). This option means you can't use both at the same time. Separate phone lines for each card machine and your phone. This provides a faster process than a shared line and won't prevent you receiving calls during transactions. However, sharing a line between two card machines means you won't be able to use both devices simultaneously Broadband offers an even faster connection and you don't need a dedicated phone line. Your card machine simply plugs into your router Mobile GPRS network connection allows your machine to work similar to a mobile phone. It has a SIM card and doesn't need a phone line or broadband connection, so you can use it on the go Online Payments are the University’s preferred method and best practice for taking payments. Customers are encouraged to make payment for goods and services themselves using the Online Store or the online payment facilities provided by the University. However, where the customer is present and able to enter their card directly into a card terminal, payment by PDQ is acceptable. Customers will be able to verify and authorise the transaction by entering their PIN. The full card number (PAN) is not displayed on the merchant or customer copy of the receipt. 1.2 Scope The main service areas to which this policy applies are: Outlets and services responsible for processing payment transactions using PDQ’s Finance - Income office I T Services Merchant acquirer (Barclaycard) 1.3 Security requirements It is imperative that adequate security measures for the device are deployed, not only whilst in use, but also whilst not in use, in order to deny unauthorized access, and to mitigate the risk of the device being tampered with. Note: Real-time fraudulent activity includes the act of device skimming. Skimming is the unauthorized capture and transfer of payment data to another source. This is a serious threat which can hit any merchant’s environment, and is used to steal payment data directly from the consumer’s payment card or from the merchant’s payment system infrastructure. Therefore, devices must be properly supervised when in use, and must not be removed from staff view. They must also be securely stored in a locked receptacle when not in use. Access to the locked receptacle should be restricted to appropriate staff, as determined by the outlet or service’s manager. Any confirmed or potential breaches of security should be dealt with in accordance with the Incident response plan as stated in the PCI DSS policy. Finance Document Page 4 of 9 Failure to observe this requirement may result in the theft of cardholder data, and money being taken from student/customer bank accounts. Therefore, a breach will be taken very seriously, and reported to the relevant Head of Service / Director of Finance and Planning for a decision on the action to be taken. 2 Responsibilities The key responsibilities in connection with the PDQ management policy are given below: The Director of Finance and Planning has ultimate responsibility for this policy. Finance Business Systems is responsible for: Maintaining the PDQ management policy in accordance with PCI DSS developments and policy The Head of Financial Services must ensure that: The controls over the management of PDQ’s are effective, relevant and secure, and regularly reviewed The Director of Finance and Planning is advised if an investigation of material non-compliance is required The Income Office Manager has overall responsibility for: Maintaining a comprehensive and complete inventory of all PDQ’s in use throughout the University Completing an annual audit of PDQ terminals in use throughout the University Ensuring that PDQ’s are only authorised and allocated in accordance with the PDQ application process as stated in this policy Ordering PDQ’s from Barclaycard Reporting all changes (including new allocations, removal of equipment, location changes, PDQ hardware updates) to the Treasury Manager Returning old/obsolete equipment to Barclaycard in a timely manner Cancelling obsolete merchant accounts in a timely manner, and ensuring that future charges are not made Retaining PDQ hire agreements Ensuring that the PDQ management policy is strictly adhered to The Treasury Manager has overall responsibility for: Maintaining relations with Barclaycard regarding PDQ’s Recharging transaction and hire costs to relevant cost centres on a regular basis and cross checking to agreed hire charges Outlet/Service Managers that use PDQ’s have overall responsibility for: Ensuring that all PDQ terminals are managed in accordance with this policy Reporting any changes to the Income Office Manager in a timely manner Regularly assessing whether continued use of a PDQ is financially viable Returning obsolete equipment to the Income Office Manager in a timely manner Removal of staff access upon leaving their employment or role Ensuring that all PDQ’s are adequately secure both when in use, and when not in use Ensuring that all staff required to use the PDQ are adequately trained Ensuring that all staff who process card payment transactions via PDQ understand this policy, and adhere to the guidelines within Co-operate with annual audit of PDQ terminals as and when requested Maintaining an up-to-date training log for PDQ users; user instructions and security Finance Document Page 5 of 9 3 PDQ application process 3.1 Application process for ordering a PDQ All requests for a new PDQ to be installed at an outlet or service area, be it temporary or permanent, must be made via a completed and authorized application form (see PDQ1). Note: Application forms must be authorized by the Outlet/Service Manager – this is the approval to apply. The final authorization (required by the Income Office Manager), is the approval (or rejection) to proceed with installing a PDQ terminal at that location, be it temporary or permanent. 3.1.1 Requesting a new PDQ terminal for your outlet or service If a new PDQ is required for an outlet or service, form PDQ1 should be completed, authorized by the outlet/service manager, and submitted to the Income Office. The Income Office Manager will then undertake a series of checks on the application, before authorization to proceed is considered. Checks include the completeness of information required, feasibility/financial viability and authorization to proceed with the application. However, financial viability will be balanced with customer satisfaction or lack of availability of alternative payment methods. Managers are required to consider how much the terminal will cost before deciding on whether to install one. 3.1.2 Requesting a temporary PDQ for an event If a PDQ is required for a one-off event, it may be hired for that event via the Income Office. Form PDQ1 should be completed, authorized by the Outlet/Service Manager, and submitted to the Income Office no later than 14 days prior to the event start date. The Income Office Manager will authorize the loan, and will also require the Outlet/Service Manager to ‘sign out’ the PDQ terminal, agree a date for its return, and ‘sign in’ the terminal upon return (using a Portable Card Terminal Loan log). The terminal should be returned on, or before the agreed date. During the hire period, the Outlet/Service Manager will be responsible for the safe use and security of the device. 3.2 Removing a PDQ terminal from your outlet or service All requests to remove an existing PDQ from an outlet or service area, must be made via a completed and authorized PDQ removal request form (see PDQ2). 3.2.1 Removing/de-commissioning a PDQ terminal from your outlet or service The Income Office Manager will review the removal request and ensure it is appropriately authorized by the relevant Outlet/Service Manager. Confirmation will be required as to why the terminal is being removed, and what other means of payment (if any) are on offer at the location. 3.2.2 Returning a PDQ terminal Once the authorisation to remove a device has been granted, Outlet/Service Managers should arrange for the PDQ to be returned to the Income Office as soon as possible, and no later than one week after the request has been approved. The Income Office Manager will then make the necessary arrangements with Barclaycard, as to whether the device is to be returned, or replaced with a device at another location, before physically carrying out the return/replacement in accordance with Barclaycard’s wishes. 3.2.3 Cancelling a merchant account Once the authorisation to remove a device has been granted, the Income Office Manager will make the necessary arrangements to cancel a merchant account with Barclaycard, and stop the associated charges being raised. 3.3 Making changes to a PDQ terminal in your outlet or service All requests to make changes to an existing PDQ at an outlet or service area (including equipment upgrades and moving terminal to another location), must be made via a completed and authorized PDQ change control form (see PDQ3). It is perfectly acceptable for Outlet/Service Managers to deal with Finance Document Page 6 of 9 Barclaycard directly when devices are faulty/need replacing, however it is essential that the changes made are reported to the Income Office Manager via the PDQ3 form, within 5 working days of the change. 3.3.1 Replacing an old or faulty PDQ terminal All requests to replace a PDQ terminal, whether faulty or not, should be recorded on the PDQ3 change control form, together with reasons for the request and the impact of not doing so. This form should also be completed to report changes made where Managers have dealt with Barclaycard directly. The Income Office Manager will review the change request and ensure it is appropriately authorized by the relevant Outlet/Service Manager, prior to contacting Barclaycard if applicable. The Income Office Manager should forward details of the replacement to the Treasury Manager, who will ensure that the merchant account charge records are accurate and up-to-date. 3.3.2 Moving a PDQ terminal to another location All requests to permanently move a PDQ terminal from one location to another, should be recorded on the PDQ3 change control form, together with reasons for the request and the impact of not doing so. The Income Office Manager will review the move request and ensure it is appropriately authorized by the relevant Outlet/Service Manager. Confirmation will be required as to why the terminal is being moved, and what other means of payment (if any) are on offer at the location. When satisfied that the request has been properly completed and authorized, the Income Office Manager will authorize the device to be permanently moved. The relevant Outlet/Service Manager will be notified of this decision, and provided with information on how to proceed. Note: This does not include temporary loan devices. 4 Decision-making and approval process for PDQ applications Applications for new PDQ’s will be reviewed by the Income Office manager, on an individual basis. Consideration will be given to the feasibility/financial viability of installing a device at the location, together with other key information (such as terminal type, connection type, Management approval etc). Whilst every effort will be made to provide the service requested, the Director of Finance and Planning reserves the right to refuse an application based upon the above approval criteria. 4.1 Approval of new PDQ applications As part of the approval process, Outlet/Service Managers will be required to accept the cost of hiring the device, and associated transaction charges to their cost centre. This information will be provided by the Treasury Manager, prior to the device being installed. Should Managers not agree to the charges against their cost centre, approval to install the PDQ device will be withdrawn. 4.2 Rejected PDQ applications The Income Office Manager will notify Outlet/Service Managers of rejected applications, providing the reason(s) for the rejection. Should this provide a problem, the Manager should contact the Income Office Manager to discuss further. 5 PDQ Cost recharges – hire charges and transaction charges PDQ hire charges range from around £17 to £30 (incl VAT) per month, depending on the type of device. Transaction charges are made by Barclaycard for every transaction processed. The rates per transaction are as follows: Finance Document Page 7 of 9 Debit card (Non-international) – a set transaction charge is applied for every transaction regardless of its value – this is set by Barclaycard and is approximately 15p; Debit card (International) - percentage of the value taken for each transaction; Credit card – percentage of the value taken for each transaction. The percentages charged for Credit Cards and International Debit Cards currently range between 1.09 and 1.75% with international, Premium and Commercial being the most expensive (1.75%). 6 PDQ Inventory The Income Office Manager will maintain a comprehensive and up-to-date PDQ inventory, which will be located on a shared directory S://FIN/Finance/Income Office/PDQ terminals All new PDQ’s allocated, removed, and changed will be recorded by the Income Manager within 5 working days of the change taking place. 6.1 Annual audit of devices The Income Office Manager will perform an annual audit on the inventory, by sending out a simple data request form to each outlet/service area recorded, to confirm that the details held are accurate. All outlets/service areas are required to respond within 5 working days, therefore a deadline for completion and submission of the form should be provided. Devices will be periodically inspected by the Income Office Manager, to confirm that the Terminal ID (TID) is as recorded. This is important to ensure that the official device has not been substituted with one that has been tampered with. Any incidents identified will be reported in accordance with the PCI DSS policy’s Incident Response procedure. 7 PDQ Training Outlet/Service Managers are responsible for ensuring that all staff required to use the PDQ terminal, are adequately trained. Users must also be aware of this policy, and the PCI DSS policy to ensure that the security of cardholder data is protected. 7.1 PDQ use and security Users should be trained in accordance with the manufacturer’s instructions on how to use the device. This should be undertaken prior to being allowed access to the device. All staff responsible for transacting card payments via a PDQ terminal must also be adequately trained in PCI DSS requirements and PDQ management requirements. Managers must maintain an up-to-date training log, of all training provided to staff, which should be available for inspection by the Director of Finance and Planning, and/or relevant staff upon request. This training must be provided during staff induction and refreshed on an annual basis. Training should include the following: • How/why to verify the identity of any third-party persons claiming to be repair or maintenance personnel, prior to granting them access to modify or troubleshoot devices; • The correct procedures for installing, replacing, or returning devices; • Reminder to be aware of suspicious behaviour around devices (for example, attempts by unknown persons to unplug or open devices); • How/where to report suspicious behaviour and indications of device tampering or substitution to appropriate personnel (for example, to a manager or security officer); Reminder to be aware of signs that a device might have been tampered with or substituted include unexpected attachments or cables plugged into the device, missing or changed security labels, broken or differently coloured casing, or changes to the serial number or other external markings. Managers should also ensure that there are adequate controls regarding the processing of refunds, and the security of the Supervisor’s card that allows refund transactions to be completed. Failure to observe this requirement may result in the theft of cardholder data, and money being taken from student/customer bank accounts. Therefore, a breach will be taken very seriously, and reported to the relevant Head of Service / Director of Finance and Planning for a decision on the action to be taken. Finance Document Page 8 of 9 8 Merchant Account (MID) control In order for the University to collect its income by debit/credit card, each PDQ must be associated with a Merchant ID (MID). Each device has its own Terminal ID (TID), which is associated with a MID. 8.1 Barclaycard (Merchant Acquiring Bank) The Income Office Manager is responsible for liaising with Barclaycard, to ensure that all device TID’s are correctly associated with a MID, and that the University is not paying for MID’s it is no longer using (there is a standard minimum charge for a MID). 8.2 American Express (AMEX) The Income Office Manager is also responsible for liaising with American Express to ensure that each Barclaycard MID is associated with an AMEX MID, to ensure that payment by American Express can also be offered. Finance Document Page 9 of 9