Regulatory Compliance, Governance and Security:

merchants

Sep 28 2009   10:09PM GMT

PCI DSS Compliance for Service Providers | A Growing Trend



Posted by: Charles Denyer
PCI DSS, payment card industry data security standards, merchants, service providers, data centers, managed services, payment gatteways, charles denyer

PCI DSS compliance for service providers is growing at quite an astonishing rate, to say the least. One of the biggest contributors is that of data centers, co-location facilities, and other types of organizations providing managed services. In short, they are quickly being identified as “in scope” and in the loop in regards to storing, processing or transmitting cardholder data. Compliance for many of these service providers is not as explicit as it is for merchants; this due in large part to the unique service offerings provided by each respective service provider themselves.

Listed below are some common examples of Service Providers that are now being requested to become Payment Card Industry Data Security Standards (PCI DSS) compliant:

Transaction Processors
Payment Gateways
Web Hosting companies
Data Centers
Managed Service providers.

And the major payment brands have varying terms for what they actually call a service provider. Some are called a “Third Party Processor”, a “Data Storage Entity”, or a “Payment Service Provider”.

Two things to remember: First, compliance for service providers will continue to grow, and rapidly. Second, storing, processing, or transmitting data in any type of capacity will immediately place you under the category of a merchant or a service provider.

Visit the official PCI DSS Resource Guide to learn more about PCI compliance.

Aug 29 2009   1:31PM GMT

PCI DSS Compliance | Watch out for the “Road Blocks”



Posted by: Charles Denyer
pci dss compliance, qualified security assessor, qsa, charles denyer, merchants, service providers, two factor authentication, web application firewall, software code review, intrusion detection system, report on compliance, ROC

PCI DSS Compliance, especially on-site reviews conducted by a Qualified Security Assessor (QSA), can take an immense amount of time in completing and receiving one’s Report on Compliance (ROC).
What most merchants and service providers fail to recognize is that there are numerous issues that could potentially cause “roadblocks” on the way to achieving PCI DSS compliance.

As a QSA, I’ve listed some examples of common items that require remediation prior to achieving compliance. These items are considered major “roadblocks” because of either the time, money and investment needed to incorporate them into the cardholder data environment:

1. Two-factor authentication
2. Web application firewall and/or software code reviews.
3. Intrusion Detection Systems (IDS)
4. Documented Policies and Procedures specifically related to PCI DSS compliance.

These four items are typically what catch merchants and service organizations off-guard. Be prepared, be proactive; find a quality, competent QSA to help with all your PCI DSS compliance needs.


Aug 23 2009   5:01PM GMT

PCI DSS Compliance | Why it is Working and Will Continue to be Enforced



Posted by: Charles Denyer
payment card industry data security standards, PCI DSS, charles denyer, 130 million cards, data security breach, merchants, service providers

PCI DSS compliance has taken a lot of shots lately, much of it unfair. Sure, there have been a number of high profile data and security breaches, such as the recent compromise of 130 million payment (credit and debit) cards.

These stories create great front page news and to be fair, they need to be covered to report on the growing security issues facing businesses today. With that said, the Payment Card Industry Data Security Standards, commonly known as PCI DSS to many, has proven to be a highly effective and sustainable compliance initiative for protecting cardholder data. I’ve probably got some critics already by making such a bold statement, but keep in mind that the number of organizations that have successfully become compliant and have NOT suffered a data breach is very impressive indeed. Sure, the bad apples always cause the problems, making front page news and questioning the validity of PCI DSS. It’s hard in today’s society to have absolutes on almost any variable, compliance being one of them.

An ounce of prevention can go a long way, and that’s exactly what many merchants and service providers have done by implementing PCI DSS standards and becoming compliant.

Visit the official PCI DSS Resource Guide to learn more.


Aug 23 2009   4:42PM GMT

PCI DSS Compliance for Merchants | A Self-Assessment could be a thing of the Past



Posted by: Charles Denyer
PCI DSS, self assessment, payment card industry data security standards, merchants, self assessment questionnaires, charles denyer, mastercard, payment processors, gateways, qualified security assessor, qsa, pci self assess

PCI DSS Compliance for merchants is a hot topic indeed as witnessed by the large and ever growing number of businesses having to comply with PCI DSS. And to be fair, the vast majority can “self-assess” for compliance by answering a series of questions from a specified “Self Assessment Questionnaire” (SAQ) document obtained at www.pcisecuritystandards.org.

But lurking beneath are a number of variables, issues and hot topics possibly resulting in many more merchants having to undertake an actual dreaded on-site PCI DSS assessment by a Qualified Security Assessor (QSA) instead of simply filling out a Self-Assessment Questionnaire.

For one, the Self Assessment Questionnaires are starting to become seen as nothing more than a check the box answer, with little or no efforts taken by the merchants to truly secure their cardholder data environment. Unfortunately, many merchants have come to symbolize the phrase “self assess” as a meaningless document which is nothing more than a burden to their businesses. Merchants beware, as the major payment brands, acquirers and other interested parties (i.e., state legislative bodies) are seeking to change this. MasterCard recently made changes to their Merchant level requirements, which to say the least, could potentially impact a large number of merchants. Add to the fact the payment processors, gateways and customers alike are now starting to ask more and more about PCI compliance from organizations they do business with.

If you want to learn more about PCI DSS compliance, visit the official PCI Resource Guide.


Aug 3 2009   7:25PM GMT

SAS 70 Audits and PCI DSS Assessments | What you NEED to Know



Posted by: Charles Denyer
PCI DSS, SAS 70, sas70, type i, type II, payment card industry data security standards, merchants, service providers, service organizations, pci dsss level 1 assessments

SAS 70 audits and PCI DSS Assessments are on everybody’s radar screen today, or though it seems. Particularly, SAS 70 Type II Audits and Payment Card Industry Data Security Standards (PCI DSS) Level I assessments.

And why? Because many service organizations, merchants, and service providers are being asked to become compliant with either a SAS 70 audit, a PCI DSS Assessment or both, for purposes of today’s regulatory compliance initiatives. Take note, Nevada just passed provisions of PCI into law, joining Minnesota as another state that is taking security and privacy to a new level.

I’ve put together a comprehensive white paper on SAS 70 Type II audits and PCI DSS Level 1 assessments that is definitely good reading material if your organization has to become compliant with either of these.

Visit the official SAS 70 Resource Guide to learn more about Type I and Type II audits
Visit the official PCI DSS Resource Guide to learn more about PCI DSS Assessments.


Jun 20 2009   3:31AM GMT

PCI COMPLIANCE



Posted by: Charles Denyer
pci compliance, merchants, level 1, PCI DSS, payment card industry data security standards (PCI DSS), payment card industry security standards council, charles denyer

Payment Card Industry Data Security Standards (PCI DSS) compliance means many different things to many people. And after all, it should, based on the complexities of truly understanding what the phrase “PCI Compliance” or being “PCI compliant” really means.

For an ounce of clarity, remember this. All merchants that fall into Level 1 of the transaction volume parameters for PCI will have to undertake an on-site PCI DSS assessment by a Qualified Security Assessor; somebody who has gone through the training and certification process by the Payment Card Industry Security Standards Council (PCI SSC).

“Most” other levels (and i stress most, because there are exceptions) can conduct their own self-assessment for PCI compliance. The world “self” is misleading because most organizations trying to comply will need assistance from a PCI QSA.

To learn more about PCI DSS, visit pciassessment.org.


Jun 19 2009   10:00PM GMT

PCI DSS Level 1 Compliance for Merchants and Service Providers | Helpful Tips



Posted by: Charles Denyer
charles denyer, PCI DSS, service providers, merchants, pci qsa, PCI DSS Level 1 compliance for merchants and service providers, 12 requirements

PCI DSS Level 1 Compliance for Merchants and Service Providers can be a daunting task, but there are a number of proactive steps to take to help mitigate and hopefully eliminate cost and time overruns.

There’s quite a bit you can do to help prepare your organization for PCI DSS Level 1 compliance, so let’s start with some of the basics and move forward in subsequent blogs.

First and foremost, READ the PCI DSS standard, from front to back. Sure, it will take some time, but you will be able to much better grasp and understand the dynamics of PCI compliance. There are 12 main requirements, each one is quite specific in their demands, so break them up and spend time truly digesting what each Requirement means.

Second, conduct a PCI DSS Readiness Assessment (either internally or preferably with a PCI QSA). Why? You need to be able to generate a gap analysis to see where your weaknesses are and what steps you will need to take to correct them. So, that’s just a start. I’ll be writing more in later blogs, so stay tuned.

To learn more about PCI compliance, visit pciassessment.org


Apr 30 2009   1:46PM GMT

PCI DSS Compliance | Getting Started on PCI DSS Compliance for Merchants



Posted by: Charles Denyer
pci dss compliance, charles denyer, pci qsa, merchants, service levels, transaction volume, pci assessment

PCI DSS compliance is having a profound impact on businesses today. In short, the Payment Card Industry Data Security Standards (PCI DSS) is mandatory for any business involved in the processing, storage, or transmission of transaction data or cardholder data. As a result, this compliance requirement “should” be affecting millions of U.S. businesses. I say “should” because the lack of enforcement is resulting in a large number of organizations not complying with the PCI DSS standards. That could change as merchant processors and payment gateways are forced to have all their merchants comply with the standards. As a PCI-QSA assessor who conducts PCI DSS assessments, i’m starting to field many calls from merchants who have been contacted by their third party payment processor telling them they need to be PCI compliant.

I honestly think most merchants want to and will comply with PCI, but the “who, what, where, and why” of PCI DSS compliance can be quite vague at times. So, to be fair to merchants, some eduction is needed on this topic.

Thus, first and foremost, you will need to identify your transaction volume, that is, the number of transactions you undertake on a yearly basis for payment cards. This will help you identify what “level” of compliance you fall into. This handy reference guide for transaction volume will help you with this.

Once you’ve identified what “level” of compliance you fall into, you can then contact a PCI DSS specialist for helping assist in your compliance matters.


Apr 20 2009   1:03PM GMT

Payment Card Industry Data Security Standard | Learn about PCI DSS



Posted by: Charles Denyer
Payment Card Industry Data Security Standard, charles denyer, PCI DSS, visa, mastercard, american express, amex, discover, jcb, service providers, merchants, pci ssc, pci dss self assessment

The Payment Card Industry Data Security Standard, commonly known as PCI DSS, is a far reaching compliance initiative put forth in a collaborative fashion by the major payment brands (VISA, MasterCard, American Express, Discover, and JCB). These compliance initiatives are overseen and guided by the Payment Card Industry Security Standards Council (PCI SSC).

Thus, if you need to become PCI DSS compliant, there are a number of valuable resources to look at. But first and foremost, you need to understand what Level you fall into for PCI DSS compliance. For merchants, you can be categorized anywhere from a Level 1 to a Level 4. Level 1 audit require an on site PCI DSS assessment, while other Levels you can conduct a PCI DSS Self Assessment. These are general rules, however. Compelling business requirements would require some Level 2, 3, and 4 providers to possibly have an on site audit conducted. Also, there are varying requirements depending on your transaction level between the major payment brands. Find out what your transaction level is, first and foremost.

Additionally, there are also requirements for service providers, thus you will need to identify your transaction level also.


Mar 26 2009   1:34PM GMT

Compliance with PCI DSS | Expert Advice from a PCI QSA



Posted by: Charles Denyer
compliance with pci dss, charles denyer, qsa, qualified security assessor, service providers, merchants, pci dss self assessment, payment card industry, PCI DSS

Compliance with PCI DSS can be daunting and a challenge indeed. However, simply breaking down the PCI DSS requirements and looking at it in a thought manner will help alleviate your concerns. As a Payment Card Industry Qualified Security Assessor (PCI QSA), i’m often asked the who, what, when, where, and why of compliance with PCI DSS.

So, with that said, here is some important advice in truly understanding compliance.

1. You need to find out if you are identified as a merchant or a service providers in the eyes of PCI compliance. Contact a PCI QSA for advice on this issue if you are not sure of your answer.

2. Once you have accomplished this, you need to identify what “Level” of compliance is mandated for your organization. This can be done by calculating the total number of transactions your organization undertook or will undertake in a full year’s time. Take note, that for merchants, most organizations will fall into Levels 2,3, and 4, which can allow you to conduct a PCI DSS self-assessment (with oversight and guidance from a PCI-QSA is what i highly recommend). Level 1 merchants will have to undergo an actual on-site PCI DSS assessment by a QSA. As for service providers, most of you will also have to undergo an on-site PCI DSS assessment. Again, find your level based on your transaction volume.

3. If you can self-assess, then visit pcisecuritystandards.org and obtain the self assessment questionnaires. There are five (5) of them, so read carefully as to which one is for you. If you have to have an actual on-site PCI DSS assessment done, then contact a firm who can conduct this for you.