We are in the process of contracting with a company to provide order fulfillment services over the Internet. The service provider will be taking orders along with credit card information then ship and bill the customer directly. We are a privately owned company and my question is. Is the company I work for under any compliance regulations or liability of personal credit card information the service provider will be handling?
Software/Hardware used:
ASKED:
February 8, 2006 10:09 AM
UPDATED:
February 20, 2006 7:55 AM
Hi
Your 3rd Party definately needs to be SOX compliant.
Bigjess,
To certain degree you may need to comply with PCI/CISP but I don’t believe that you need to comply with SOX as you are not a public company. Nevertheless, I would suggest exploring the possibly of obtaining as Type II SAS70 report from your service provider so you can assess the effectiveness of their controls.
Carlo
1.) PCI/DSS certification would provide the best assurance of appropriate credit card processing, but get evidendce of all 3 (PCI, SAS 70 Type II and SOX.) The due diligence standard is to ask for all and see what they provide. Ask for a network vulnerability/pen test if they can’t provide the PCI certification.
2.) The above will provide some broad general controls assurance and some network assurance but , don’t start processing unless they can provide a web application vulnerability assessment (WebInspect or similar). Port 80 is always open for business, it is critical the app behind this port is safe (OWASP).
2.) Don’t forget a contract with liability and indemnification clauses in your favor and strong SLA’s.