pci dss & pii

PCI DSS & PII

Emily CobleUNC 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 providedPCI 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 Organizational Harm– Identity theft - 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 Bundyfmr 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?