We have had a few discussions among consultants as we progress further into this compliance for our Travel Agency clients. And very often (if not always), the matter always comes down to, “Can we just do an ASV scan and you certify us?”
We have touched this topic many times. ASV scans cannot certify you as PCI compliant. They are just one of the requirements. In fact for some of the SAQs (self Assessment questionnaire), ASV is not even needed.
We’ve gone through the famous SAQ A in our last post. This is basically where no card data is being entered in merchant environment and they basically forward everything over to the payment provider. There is no requirement for ASV. That doesn’t mean it makes it right though. Imagine this scenario: the developer makes a hopeless job at coding their web application. There are two ways SAQ A can be done: redirect or iframe. Let’s recap.
A redirect occurs when the merchant website sends a redirect instruction to the client browser when payment needs to be made. This instructs the client to connect directly to the payment gateway. This instruction could be a simple
The iframe is similar, whereby a ‘child’ window is called directly from the payment gateway and has a window in the main merchant site. Although everytime this occurs, I have nightmares of those old websites with scrolling words, flashing lights and like 5 – 10 frames running at once. Netscape days.
iFrames are simple as well, with the site you want to call embedded within the <iframe src> tags.
So, anyway, back to ASV scans on these merchant sites. Although its not required, if the web application itself is poorly constructed and is compromised, there could be a high possibility that the redirect process itself gets hacked and redirected to another site that looks like the real payment site. You can imagine what happens next. The solution here is to ensure even on the merchant site, this site is developed with good secure coding practices. If ASV is not required, it does not mean you don’t need to run any scans. We would recommend vulnerability scans to still run against it, whether ASV or not. In fact, any web facing system out there should be tested – because if you are out there, it’s open season – anyone can attack it, and it’s up to you to secure it.
Conclusion: No need for ASV, but recommended – if not ASV, at least some security scans.
Ah, the good old SAQ B. A lot of people misunderstand this for a good reason. Some of our retail clients, or F&B clients insists this is the correct one as they are using card terminals. However, they forget that most of them have their integrated POS systems – specifically because they need to charge an amount like food etc. So their POS systems sends these details to their EDC (Electronic data capture) terminals and the EDC accepts the DIP cards. What happens is that, these EDCs sends back the transaction data and in many cases, they still swipe our cards on the payment system. SAQ B doesn’t qualify here. SAQ B is specific for dialup EDCs directly to acquirer bank. For those using 3g/4g, then these can be considered as well. If you are using WIFI, or internal broadband link then you are out of luck. No SAQ.
Because of the direct point to point or cellular connectivity, ASV is not required (for a good reason!)
Conclusion: No Need ASV – IF you actually qualify for the SAQ that is.
Another difficult SAQ to be eligible for. It has very specific requirements – whereby a web-based browser connectivity to a virtual payment provider who is PCI compliant. I think it really applies more to hospitality or travel agencies. In this case, the question is often asked – what about my broadband IP accessing the net? Because for sure, when I connect to my virtual terminal provider, I am using the internet right, and not leased line or any point to point? So for sure, my broadband has an IP. Just type “whats my ip” in google and it will show. Most of them have dynamic IP addresses as well. In SAQ C-VT there is no requirement to ASV scan.
However, having a dynamic IP and no ASV scan in SAQ C-VT doesn’t mean you still can’t do it. Many routers/firewalls are poorly implemented or poorly patched. We would recommend to do an internal scan on the firewall interface to ensure vulnerabilities are identified. Again, it’s a matter of securing the internet exposed system.
Conclsuion: No Need ASV, but we recommend an internal security scan on the firewall to ensure the box is properly hardened.
So, there you have it. It’s critical to know your SAQs so you know the extent of what NEEDS to be done and what is BETTER to be done than not.
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