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Presented by the PCI Compliance Task Force

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1 Presented by the PCI Compliance Task Force
PCI Boot Camp Presented by the PCI Compliance Task Force

2 moderator: Jeremy Rock President ● RockIT Group

3 Agenda PCI Overview Removing Card Data From Your Hotel Best Practices
Questions & Answers

4 PCI Overview

5 Presenters: Mark Haley, CHTP Jeff Henschel Chuck Marratt
Managing Partner● The Prism Partnership, LLC Jeff Henschel Director of IT● Benchmark Hospitality International Chuck Marratt Regional Director of IT● Benchmark Hospitality International

6 What Does PCI Compliance Entail?
What is PCI? What Does PCI Compliance Entail?

7 Overview Objectives What are:
The Payment Card Industry (PCI) Data Security Standard (DSS) and The Payment Application Data Security Standard (PA-DSS)? What are the components of a sound data security policy and PCI Compliance? How do you get to PCI Compliance? Vocabulary and Concepts for all of above Today we want to answer these questions We aren’t going to talk about 128-bit vs. 256-bit encryption.

8 Overview Why is Compliance So Important? PCI & PCI Compliance Defined
Key Issues Who is responsible for compliance? What gets overlooked? How do I plan my compliance journey? Additional Resources Questions Is this what you expected to cover today?

9 Why Is Compliance Important?
PCI Compliance is like insurance Good business practice You are vulnerable! 55% of credit card fraud from hospitality 85% of breaches against Level 4 merchants* Potential impact of a breach Customer Relations Legal Financial * Source: Unified Compliance Framework Penalties for non-compliance can be very steep…more on that later U of Delaware research shows that consumer are likely to stop patronizing a hotel or hotel brand in the event of a breach ASK: Anyone here ever had a card compromised in a breach? Actually defrauded? How did that make you feel?

10 Why is Compliance Important?
Because they are after us! Hackers now specifically targeting hospitality 38% of breaches in 2009 in hotels and resorts Source: Trustwave Spider Labs 83 of 218 breaches investigated by SpiderLabs in hotels 1 initial penetration led to multiples Typically: Weak remote access controls Routers and firewalls unconfigured Default passwords left in place Also note: Hotels very unlikely to have conducted audits/tests prior to a breach Industry initiatives

11 2010 Market Trends: Industries by Percent of Breaches
*Statistics from 2011 Verizon Business Data Breach Investigation Report

12 2010 Breach Trends: The Facts
761 Breaches in 2010 (141 in 2009) 89% of victims subject to PCI DSS had not achieved compliance 86% of the breaches were discovered by a third party 86% of the victims had evidence of the breach in their log files 98% of all breached records came from servers 96% of breaches were avoidable through simple or intermediate controls * All percentages are from the 2011 Verizon Business Data Breach Investigation

13 Why is Compliance Important?
You don’t want to make the headlines!

14 Breakdown of Cost per Record

15 Costs of Non-Compliance
Costs of a Breach Fines from issuing brands Costs to address vulnerabilities Costs of Level 1 audits in future Lawsuits from card-issuing banks for card replacement costs Loss of customer trust and goodwill Loss of business Tarnished reputation MARK Fine schedules vary by brand: Visa $5K - $25K/mo; AEXP, $50K and up The brand fines the acquirer, who then passes it on to the hotel. The cash just disappears. Your merchant agreement gives them this power to take your money. Compromised merchants will be designated L1 Card replacement $35/ea

16 Definition Data security standards for all merchants accepting credit, debit or other cards to protect cardholder data To ensure the integrity of the global payment card industry Applies to ALL cardholder data Electronic Paper Applies to ALL merchants So, your paper authorization forms are also covered by PCI Including the PDFs you attach to the corporate account record in your PMS

17 Definition- Roles Key Players & Roles
Standards “owned” by PCI Security Standards Council Enforcement reserved to the issuing brands SSC formed by the brands in September 2006 SSC controls the standards, certifies QSA/ASV vendors, maintains list of certified Payment Applications The merchants pay for all of this. That would be you.

18 Lodging complexity - lifespan of a credit card number in a lodging environment

19 Definition - Details Payment Card Industry (PCI) Data Security Standards (DSS) 12 Major Requirements Applies to everyone handling cardholder data Merchants Processors Intermediaries Self-Assessment Questionnaire (SAQ) for most merchants Different forms of SAQ varying with merchant’s processing infrastructure Mark PCI is GLOBAL, not just North America 4 forms of SAQ; Most hotels will use SAQ D The standards, SAQs and other useful references at Has your firm completed a SAQ?

20 Definition - Details Payment Application Data Security Standards (PA-DSS) Formerly known as Payment Application Best Practices (PABP) Applies to software vendors marketing products that handle cardholder data Requires software vendors to invest in certification, costly to achieve and maintain Merchants forbidden to use uncertified payment applications July 2010 MARK PABP was a Visa program, transitioned to SSC Note that the brands work through others, typically the acquiring banks, rather than directly with merchants

21 Definition of Merchant Levels
Merchant Level Description 1 Over 6,000,000 Visa transactions per year for any merchant-regardless of acceptance channel-processing. Any merchant that Visa, at its sole discretion, determines should meet the Level 1 merchant requirements to minimize risk to the Visa system. 2 1,000,000 to 6,000,000 Visa transactions per year, applies to any merchant-regardless of acceptance channel-processing. 3 20,000 to 1,000,000 Visa e-commerce transactions per year. 4 20,000 or fewer Visa e-commerce transactions per year, and all other merchants-regardless of acceptance channel-processing up to 1,000,000 Visa transactions per year. Mark Most individual hotels are Level 4 merchants Major brands are Level 1s If you can aggregate, you must aggregate your transaction volume DSS applies to all merchant levels equally. The difference is higher levels must use a QSA, lower levels may use the SAQ and self-report Verification deadline for L4 at discretion of acquirer Source:

22 12 Steps to PCI Compliance
CONTROL OBJECTIVES COMPLIANCE REQUIREMENTS 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 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 Mark 12 major requirements addressing 6 broad control objectives. >200 specific sub-requirements under the major requirements Note that most of the requirements are on-going processes, not one-time activities or events. The major requirements all seem common-sense and reasonable, but some of the sub-requirements can approach absurdity in some applications. Note great latitude of QSA in interpreting requirements

23 Key Issues Who is responsible? The Merchant

24 What Gets Overlooked? People Process MARK
PAPER: Folios, POS Receipts, Reports, Manual Vouchers AND REG CARDS; All require masking, secure storage if not. Better to forego card imprints on reg cards and to rely on the swipe flag in PMS to prove card-present PEOPLE: Need to establish a culture of privacy, PCI is part of that broader privacy obligation. People in the hotel company need to embrace that culture and changer behavior accordingly. Take password security seriously. Don’t put card numbers where they don’t belong. Consider Delphi CC Safeguard. PROCESS: Not a one-time event. Must become a way of doing business. PCI and privacy are a business issue, not an IT issue.

25 Where Companies Fail Their PCI Audit
2011 Global Security Report

26 Action Items How do I plan my compliance journey? Assign an Owner
Use your Acquirer Use your Franchisor/Brand Establish Documentation Gather Inventories Use your Software Vendors Complete Self-Assessment Questionnaire (SAQ) May 6 & 7, 2010

27 Action Items How do I plan my compliance journey? (continued)
Determine if you need a Qualified Security Assessor (QSA) Implement Vulnerability Scans from an Approved Scanning Vendor (ASV) Address SAQ Deficiencies Update your Documentation Repeat!

28 Just Remember… Data Security is an ongoing process.
Recognize the risks at all levels in your organization. Understand what you can do to be proactive. Determine what behaviors and processes may have to change.

29 Action Items Budget for PCI Not a One-Time Expense!
Initial costs may include: Engage a QSA or other resources System replacements Staff costs for initial SAQ On-going Costs Include: Quarterly Penetration Scans Annual SAQ exercise Internal & External evaluations of technology in scope Logging and Alert management Anti-Virus subscriptions Payment Application upgrades Intrusion Detection Software Resources and training to manage security measures

30 Action Items Make sure you budget appropriately as PCI compliance is an ongoing expense to your organization. Costs include but are not limited to items listed below: Annual Penetration Scanning External scans of technology in scope Internal scans of technology in scope Logging and Alert Management Anti Virus upgrades/renewals PMS/POS Annual Upgrades Intrusion detection software Resources and training to manage PCI and Security measures implemented.

31 Additional Resources AH&LA publication, The Payment Card Industry Compliance Process for Lodging Establishments PCI Security Standards Council Visa MasterCard KELLY

32 Removing Card Data From Your Hotel

33 Presenters: William Collins Sue Zloth Bob Lowe Lyle Worthington, CHTP
Executive Director – Vertical Market Strategy● Heartland Payment Systems Sue Zloth Group Manager, Product● Merchant Link, LLC Bob Lowe Director of Strategic Relationships● Shift4 Lyle Worthington, CHTP Chief Information Officer● Horseshoe Bay Resort

34 Where Does Card Data Exist?

35 Do You Really Need It? Why do you have it in the first place?
Old Processes You Think You Need It Chargeback documentation Balancing Risk and Convenience Does the risk of having credit card data outweigh the convenience it creates?

36 Just Say No Eliminate capturing/storing of Credit Card data unless it is absolutely necessary Question/Challenge the need Re-evaluate outdated processes Card Imprinting Credit Auth Forms Accounting/Chargeback Reconciliation Events/Catering Develop contingency plans for one-offs scenarios Off Line Authorizations Special Guest Requests, etc. Evaluate partner’s processes/systems Ask, Expect, Inspect Understand effect of introduction of new devices into your environment Mobile/Tablets Kiosks Use technology to protect data you must capture

37 Using Technology PCI Approach: Protect What You “Must” Have (This used to be a straightforward statement.) Protect Stored Data Securely encrypt stored data Encrypt transmissions of cardholder data across public networks Restrict access to data on a “need-to-know” basis Mask PAN by default, reveal to selected people on request Over time, this gets more and more complex. Time for a technology rethink…?

38 The Challenge Imagine a princess in a castle…
Securing her against attacks of increasing sophistication is difficult and expensive.

Purpose-Designed Solutions for Consideration Encryption at Swipe or Keyed Entry Tokenization

40 Technology Choices Encryption at Swipe or Key
Data is Swiped or Keyed into Encryption Device. Transmit ONLY encrypted data through your environment. Two Common Terms Used To Describe (Interchangeable) End to End Point To Point Key To Encryption Solutions Ensure POS/PMS has no ability to decrypt Understand where Card Data gets decrypted The farther down the path the better PCI is working on regulatory changes to recognize the use of this solution may reduce Merchants PCI Scope. POS/PMS Gateway Processor Card Brands Issuers Describe using the graphic how Point to Point and End to End are really interchangeable. Point to Point could be from PMS to Issuer (those are the points in which data is encrypted, or End to End could mean

41 Technology Choices Tokenization
Replacing sensitive cardholder data (CHD) with a piece of data that references Card Data, stored elsewhere. Vendors use different methods to generate Tokens It should not be possible to reverse engineer a Token back to the actual card data. Some solutions combine encryption at entry and tokenization; Encryption used on data in transit Tokenization used on data at rest Correct tokenization solutions remove the PMS from the scope of PCI DSS.

42 Technology Choices Your Action Plan
Review tokenization and Encryption at Source offerings that are supported by your software providers Select technology solutions that reduce your PCI exposure by removing data from your applications It’s better to not have data at all than to spend a lot of $$ trying to protect it

43 Cloud Computing Does It Solve The Problem?
Cloud Computing does not necessarily remove all scope from your property Cards could still exist in your network Some public cloud vendors openly state they can’t and won’t be PCI compliant. Vendors may use other cloud vendors For more information please attend the Cloud Computing Super Session Thursday at 9am Additional notes on bullets above if presenter wishes to add more information… Cloud Computing does not necessarily remove all scope from your property Cards could still exist in your network Handled by associates, swiped on your hardware (potentially), transmitted through your network Call/Voice Recording software at Front Desk, Reservations if card numbers are spoken out loud. High resolution security cameras capturing images of cards Skimmers installed on card swipes Internal Theft Public Cloud vendors openly state they can’t and won’t be PCI compliant. Primary reason – they won’t open their doors to auditors, expose the architecture of their cloud, or prove true segmentation of customers/data. One public cloud company claims PCI compliance, however they accomplished that by redirecting customers away from their cloud for the credit card transaction, then redirected the customer back in to their cloud when it was completed. They are not able to claim PCI compliance for anything processed in their cloud. Be cautious of claims like this and the potential cost to develop those types of interfaces. Vendors may use other Cloud Vendors Not every vendor offering their software “in the cloud” is an expert on security/fault tolerance Vendors may deploy their software to a public cloud or outside hosting company. Are all vendors involved compliant? Where does your data actually live?

44 PCI Boot Camp: Best Practices

45 Presenters: Jibran Ilyas Marty Stanton
Senior Incident Response Consultant ● TrustWave/SpiderLabs Marty Stanton Vice President, Information Technology ● Destination Hotels & Resorts Jerry Trieber, CPA, CHAE, CFE, CFF Director of Field Accounting ● Crestline Hotels & Resorts

46 Best Practices: Types The best practices we will discuss today fall into 3 distinct but interwoven areas: Operations Networks Documentation

47 Best Practices: Operations
Operational best practices should be implemented at all hotels, restaurants, clubs, casinos, and other hospitality enterprises currently accepting credit cards as methods of payment. Those best practices are….

48 Best Practices: Operations
Discontinue the imprinting of credit cards if still imprinting. Review proper merchant bank retrieval request and chargeback information requirements: don’t keep documents containing complete credit card numbers for fear of losing a chargeback. Discourage facsimile receipt of credit card authorizations: secure fax machines and their output. Prohibit receipt of credit card numbers. For all voice, facsimile, or other methods of card receipt, enter directly into the system and destroy (shred) the paper.

49 Best Practices: Operations
Review Sales & Catering Department files for maintenance of documents containing credit card numbers. Do not use Notes, Comments, or other unencrypted fields in Sales, Catering, and other electronic systems for credit card numbers. Review who has access to view guests’ complete credit numbers in both the PMS and POS. Review if card data or computer passwords are written on a “sticky note” placed on computer monitors or are otherwise visible or unsecured.

50 Best Practices: Operations
Train users to log off their terminals and use tight auto-log off timeouts on payment applications if available. Always consider proper storage, retention and disposal of paper and other sources of credit card numbers. Select photocopiers and facsimiles with encrypted disk drives with auto-delete capability (24 hours). Control physical access to server rooms, Front Desk and any other areas where credit card numbers are stored or processed. Consider logging and badging all visitors to these areas and requirement to surveil all data centers by video.

51 Best Practices: Operations
Conduct training on PCI Compliance! Training on PCI Compliance should include: Making training materials consumer-friendly. Annual training certification signed by all employees. Making training certification a part of the “Acceptable Use Policy.” Awareness of phishing, spear-phishing, pharming, and “vendor impostors.”

52 Best Practices: Networks
Best practices regarding networks fall into 3 categories: Passwords; Remote Access; and Operations.

53 Best Practices: Network Passwords
All default passwords should be changed before connecting a device to the network. Devices to be reviewed include: Payment application servers; Other servers; Routers; and Firewalls.

54 Best Practices: Network Passwords
The SSID names for wireless networks should also be changed: how many networks named “Linksys Router” have you observed when looking for wi-fi “hot spots!?” Be mindful of the definition of a “strong password” for PCI purposes, as it differs from that for non-PCI purposes! Passwords for all users of payment applications should be unique: No shared passwords! Create unique passwords for vendors! Use tools and policies to expire passwords, force strong passwords, and do not allow re-use of prior passwords!

55 Best Practices: Network Remote Access
PCI Compliance requires that remote access privileges be closely controlled and monitored. Regarding vendors: Access should be “on-request” from the property and not from the vendor. The property must initiate the remote access connection. Logging should be embedded in the access tool used. Default ports should be changed. Remote access should be added to vendor agreements and contracts. Hotel personnel trained to authenticate callers purporting to be vendors requesting access for support – very important!

56 Best Practices: Network Remote Access
Regarding employees: Access should be “on-request” from the employee, approved by the department head/EC member, with a valid reason for access. Access should be granted only to those applications needed by the employee and not to the entire network, depending upon where payment applications reside. Default ports should be changed. A remote access program with strong authentication and logging should be used!

57 Best Practices: Network Operations
Maintain separation of guest and employee networks. Insure that there are anti-virus subscriptions on all computers and that they are current! See that security patches are applied regularly! Be alert for skimmers and keystroke loggers! Be alert for rogue software, PCs, and wireless or USB devices! Use a laptop or smartphone to scan for rogue devices.

58 Best Practices: Network Documentation
PCI Compliance requires significant levels of documen- tation, including 4 different types of self-assessment questionnaires (SAQs), dependent upon a property’s “merchant level” classification. SAQ D is the most common type of SAQ. The PCI Compliance Roundtable is examining new user-friendly types of the SAQs, including the SAQ D.

59 Best Practices: Network Documentation
Other types of PCI Compliance-based documentation that should be prepared include: Acceptable Use Policy; Backups and Disaster Recovery; Incident Response Plans; Merchant level deter- mination letters from acquirers; Proof of PCI PA-DSS Compliance letters from payment applications used; and Network vulnerability scan reports.

60 Best Practices: Network Documentation
An sample user-friendly SAQ-D is here:

61 Questions

62 In order to help us create/provide a better HITEC
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