Payment Card Industry Data Security Standards ISACA January 8, 2013

Cheryl Becker IT Auditor at Cintas Corporation Internal Audit Department Internal Security Assessor (ISA) Certification September 2010 Annual re-certification Currently responsible for SOX IT and PCI testing as well various Corporate audits Board of Governors, IIA Cincinnati Chapter

What is PCI DSS? The PCI DSS represents a common set of industry tools and measurements to help ensure the safe handling of sensitive information. The standard provides an actionable framework for developing a robust account data security process - including preventing, detecting and reacting to security incidents. Applies to any entity that stores, processes and/or transmits CHD.

History Lesson PCI is not government legislation.  It is an industry regulation.  The major Card Brands (Visa, MC, Discover, Amex) decided to create regulations which were initially agreed upon by the Card Brands in 2004. PCI DSS version 1 is dated December 2004. On June 30, 2005, the regulations took effect. The PCI Security Standards Council came into existence in 2006. 

PCI Security Standards Council The Council became responsible for the development, management, education and awareness of the PCI Data Security Standards. Each of the Card Brands (Visa, MC, Discover, Amex, JCB) have their own compliance programs in accordance with their own security risk management policies as well as their own definitions of the “levels” and their own penalizing/fining procedures for companies who have a breach.

Merchant Levels Overview 4 Little credit card business Some Card Brands do not have this level Annual Compliance Validation 3 Less than a million credit card transactions Annual Self-Assessment

Merchant Levels Overview 2 Millions (1+ to <6) credit card transactions All Card Brands have this level Must internally audit with a PCI certified Internal Security Assessor (ISA) using PCI DSS 1 Many millions (2.5+ to 6+) credit card transactions Must audit either using a PCI certified external Qualified Security Assessor (QSA) OR Internal Audit with ISA certification using PCI DSS

PCI ISA Training Program The PCI SSC Sponsor Company Internal Security Assessor Program is a PCI DSS training and qualification program for eligible internal audit security professionals. The course helps participants improve their organization's understanding of PCI DSS and validate and maintain ongoing compliance through: Enhancing the quality, reliability, and consistency of internal PCI DSS self-assessments Supporting the consistent and proper application of PCI DSS measures and controls Effectively facilitating interactions with QSAs https://www.pcisecuritystandards.org/index.php

PCI DSS Versioning Version 2.0 as of October 2010 Version will be on a three year basis The PCI documentation (end result) has changed every year

PCI DSS Six Goals Build and Maintain a Secure Network Protect Card Holder Data Maintain a Vulnerability Management Program Implement Strong Access Control Measures Regularly Monitor and Test Networks Maintain an Information Security Policy

12 Requirements 1) Install and Maintain a firewall configuration to protect Card Holder Data (CHD) Firewall and Router configuration standards Review Network Diagram Firewall and Router connections are restricted (inbound/outbound traffic) No direct internet connection to CHD (DMZ) 2) Do not use vendor supplied defaults Attempt to sign on with defaults Hardening standards and system configuration Non-console admin access is encrypted

12 Requirements 3) Protect stored CHD 4) Encrypt transmission of CHD Retention Policy and Procedures Quarterly process for deleting stored CHD Sample incoming transactions, logs, history files, trace files, database schemas and content Do not store full track, CVV or PIN Render PAN unreadable (mask/truncate) Encryption and key management 4) Encrypt transmission of CHD Verify encryption and encryption strength Verify wireless is industry best practice (no WEP)

12 Requirements 5) Use and regularly update Antivirus software All system have AV AV is current, actively running and logging 6) Develop and maintain secure systems and applications Patch management – current within one month ID new security vulnerabilities with risk rating Custom code is reviewed prior to release Change management process Developers are trained in secure coding techniques

12 Requirements 7) Restrict access to CHD by need-to-know Review access policies Confirm access rights for privileged users Confirm access controls are in place Confirm access controls default with “deny-all” 8) Assign a unique ID to each user Verify all users have a unique ID Verify authentication with ID/PW combination Verify two-factor authentication for remote access Verify terminated users are deleted Inspect configurations for PW controls

12 Requirements 9) Restrict physical access to CHD Access to computer rooms and data centers Video cameras are in place and video is secure Network jacks are secure – not in visitor area Process for assigning badges Storage locations are secure (offsite media) 10) Track and monitor all access to network resources Review audit trails – actions, time, date, user, etc. Time server updates and distribution Process to review security logs

12 Requirements 11) Regularly test security systems Test for wireless access points Internal and external network vulnerability scans Internal and external penetration testing annually File integrity monitoring tools are used 12) Maintain security policies Policies are reviewed at least annually Explicit approval is required for access Auto disconnect for inactivity-internal and remote Security awareness program is in place Incident Response Plan

PCI DSS Tests ~260 tests PCI DSS gives both the requirement and the test Every test has to have an answer Every bullet within each test must have an answer If the requirement is not in place, a target date and comments must be made If there are compensating controls, a Compensating Control Worksheet must be completed

PCI Documentation Attestation of Compliance Executive Summary Score Report on Compliance Test Procedures Score Sheet Report on Compliance

Attestation of Compliance This is the document that is submitted to the appropriate companies Scanning vendor Merchant (i.e. Bank) Card Brand Company (i.e. Amex) Signed by ISA/QSA and Officers of the Company Brief overview of Company and Cardholder Data Environment Not a website copy/paste My summation of the company (business, DC, locs)

Attestation of Compliance Brief overview of how the company stores, processes and/or transmits cardholder data Terminals Applications Third parties State if we are compliant All 12 Requirements are listed stating “in place” or “not in place” and “special” like N/A At the bottom explain special – N/A may be ‘not a service provider’

Compensating Control Worksheet Within the Attestation of Compliance The “special” column is where to state if it is a compensating control “NOTE: Only companies that have undertaken a risk analysis and have legitimate technological or documented business constraints can consider the use of compensating controls to achieve compliance” Ex: cannot do 7 character pw on mainframe

Executive Summary Score Report on Compliance Detailed overview of CHDE – explain the flow from ‘swipe’ Phone orders Online orders Monthly charges Any other way CHD is processed Network diagram prepared by ISA/QSA Validate and explain scope – flat vs. segment Validate myself

Executive Summary Score Report on Compliance Explain the environment Personnel Payment channels IT Environment Locations Explain sampling method Exclusions and why they were excluded Wholly-owned Entities International locations Wireless Environment

Executive Summary Score Report on Compliance Service providers Third-party applications Individuals interviewed with titles List of documentation reviewed My contact information Quarterly scan information Findings and observations

Test Procedures Score Sheet Report on Compliance How each control was tested Observation – configuration or process Sampling Interview with whom Document reviews

Lessons Learned Give yourself enough time to complete the final reports Answer all of the points in each test Know your scope Inventory the environment Use a firewall to segment If you are getting your QSA/ISA, complete the training and study Users/coworkers/employees do not understand IT security (i.e. email)

Cheryl Becker IT Auditor Cintas Corporation beckerc@cintas.com