Tag: pci compliance

PCI-DSS Cheatsheet

As we approach the end of the decade, we are approaching 16 years since PCI-DSS was first introduced back in 2004. 16 years. That’s probably a full dog lifetime. I would imagine the guys back in 2004 would have thought: “Let’s just get version 1 out this year. I’m sure our next generation of brilliant minds will figure everything out by 2020.”

So now we are a few ticking days away from 2020 and yet, at the end of the line, I am still answering calls that are increasing as the days go by: What is PCI-DSS and how do we get it?

Most of these callers are generally calling because our names are listed pretty high on the internet when someone types in PCI-DSS Malaysia. Apart from that, a majority of these callers are calling because we were reference by one of our clients. We have faced different variations of callers coming in: Some requests us to provide them with a PCI-DSS ‘license’ in order to operate for their clients. Some requires a ‘certificate’, some are literally clueless as to what it is but their banks have mercilessly dumped this whole requirement to them.

Step 1: Who’s Asking?

First of all, take a deep breath, here is a simple cheatsheet. Whoever is asking you to be PCI-DSS, take note of it. Here are the Usual Suspects:

Bank – Very likely you are connecting to them doing some sort of payment processing like a payment facilitator, a TPA etc. Or you could be a service provider and your client just happens to be a bank, which brings us to

Customer – your customer for some reason is dealing with credit/debit cards, either directly or indirectly, and they require you to do PCI-DSS because you are servicing them or they have outsourced to you, like BPO, Data Center, hosting, call center, or even network transit

Internal – One of your internal managers have read up about PCI-DSS and decided that your company will sound very cool if you are PCI-DSS certified. Now, in this case, you could or could not be PCI. Because PCI is a contractual obligation dealing with credit/debit cards badged with Visa, Amex, Mastercard, JCB, Diners/Discover – if you don’t deal with this or have any clients dealing with it but your company just wants to get any standard out there – my suggestion wold be to go for something like ISMS (ISO27001) as that’s a better guideline rather than a contractual standard like PCI-DSS. If you still insist – well, you could still go through the SAQ but a lot of it will be not applicable to you since you are Non-CDE for everything.

Those 3 are mainly the motivations behind PCI-DSS. Why is it important to determine who is asking, is because of the next step:

Step 2: Determine your Level

Now there are guidelines out there for which level you should be at. If a service provider, then anything over 300,000 volume of card processing will bump you into level 1. For merchant, anything over 6 million for level 1 and anything over 1 million for level 2. I can’t count the times people get mixed up with Service provider levels and merchant levels. Even banks. I have banks telling our payment gateway that they are Level 4 . There is no such thing. It’s either one or 2. For merchants there are level 1,2,3 and 4 but the volumes are different.

Now while the guidance is cool and all, at the end it’s your bank or customer determining your level. If your bank decides to only deal with you if you do a full certification and RoC with a QSA, then even if you are processing ZERO transactions, they have deemed you as level 1. You can then decide to either say OK, fine, or tell them you are taking your business elsewhere. In that case, they may decide not to play hardball. I don’t know. Same as your customer. Your customer may decide you need to be assessed by a QSA, so it’s best you determine this with whoever is asking you.

The secret sauce is this: Most of the time, your bank/customer won’t have a clue what they want. They will just say, Oh, be PCI compliant. In this case, approach them with some tact. Your mission, should you choose to accept it, should be to avoid level 1 certification as much as you can, if your volume is low. It’s not justifiable. Look, if you want to be assessed by a QSA, by all means, but at least, know that you have a choice if your volume is low, and your bank/customer isn’t fussy about it. Just tell them: “OK, I’ll be PCI-DSS compliant, and I will fill up the Self Assessment Questionnaire (SAQ) and our management will sign it off and send it over to you. Is this OK?” If yes, then great, do your own self assessment. You can save up some money.

Step 3: Determine your Controls

This is probably the trickiest part of PCI-DSS. You see, being level 1 or level 2, self assessed or third party assessed, SAQ or RoC does NOT make any difference on what controls you need to have in place. An example: Level 1 compliance may require you to do ASV scans for 3 external IPs and 20 Internal IP Penetration testing. Guess what? Even if you are doing an internal self signed SAQ, you are supposed to do the SAME THING. No difference. No “Oh, since I am level 2, I will do ASV scans for 1 IP and maybe take 5 Internal IP for Pentest instead of 20.” In theory, all controls are the same, the only difference is WHO assesses and attests these controls.

Now, of course, realistically, this is not happening. Like I always illustrate, some companies consider a firewall as a wall on fire and they sign themselves off as PCI-DSS. Hence the whole passing the buck, passing the risk thing about PCI that I won’t go into discussion here. But in theory at least, same controls apply. But how do you determine what applies to your business? Well, based on your business flows of course.

Determine above all whether you are storing credit card information. If you are not, roughly 35% of PCI-DSS is not applicable (I am plucking that % out of no where, so don’t quote me). But a big chunk isn’t applicable. Second, determine whether you even interact with credit card or not. Look into all your channels. It could be complex like a call center, or simple like a network transit. In most case if you can determine that you have no access to credit card PAN or don’t store, and don’t process, the controls that are applicable to you are minimal. You should STILL be PCI compliant, but minimal controls apply.

Step 4: Determine your vendors and outsourcers

We had a client who cancelled an ongoing PCI-DSS with us because they have deemed themselves PCI-DSS compliant because they are using a PCI-DSS software. I cannot count the number of times I have to correct them – NO. Just by using a software which is PA-DSS compliant or even PCI compliance (like Cloud) DOES NOT make you PCI-DSS compliant. Will it help? Sure it will, but can you piggy back on someone else’s compliance? No. You can’t. So either you go through PCI yourself, or stay non-compliant, but don’t say you are compliant when you are only using a software that is compliant. That’s like saying you are certified to fly a plane when you are a passenger of a plane flown by a certified pilot. Or something similar.

Get your vendors on board for PCI if possible. If they refuse you can still use them, but you now have to include their processes under YOUR PCI-DSS program. Why would you want to spend extra days getting your vendor compliant when there are OTHER vendors who already are compliant?

So there you have it:- When someone requests PCI compliant – first, review your options. There is no ONE way for PCI. Go with the least resistance – self signed SAQ if your volume allows it. That saves you a lot of time and money as opposed to getting a QSA to come in.

If you have any queries on PCI-DSS, drop us a note at pcidss@pkfmalaysia.com and we will attend to it right away! Merry Christmas!

IATA and PCI-DSS to Travel Agents: Data Channels

PCI

IATA has for a few years been championing the need for PCI-DSS to the travel agencies that are registered under them. More recently, they have been pushing compliance for PCI and even made a deadline at June 2017 for all agencies to be PCI compliant. Unsurprisingly like many well intentioned deadlines, it is now pushed further back to March 2018. Our prediction is that by November or December this year, we might see yet another delay in the deadline. But that doesn’t mean there’s any let up in compliance. Therefore, we’ve been reaching out to many of the agencies who were our clients previously and letting them know if they need help on their SAQ, they know where to find it. Us!

Now, just to summarise, being registered with IATA means a big deal to an agency. It simply means you can issue tickets. So how it works is that IATA is like a national ‘switch’. Whereby registered members can receive calls from clients, and based on pricing etc, select the airline and pricing and issue these tickets – either to other clients or in behalf of even other agencies. Firstly, there is credit card involved, of course. Secondly, IATA members can tap into the BSP – the IATA Billing and Settlement Plan. This is like a huge payment switch – whereby it handles all the payments to multiple airlines from the agencies, so that agencies don’t have to deal individually with airlines for settlement of the tickets. Which is good. Secondly – there is the GDS (the global distribution system). There are a few players in the market – Sabre is one of the biggest (used by Malaysian Airlines), others are like Amadeus, Patheo etc. We’ve so far encountered Sabre and Amadeus in our clients and both of these are PCI certified providers.

So, with this basic understanding of how agencies work, how does PCI apply?

First of all, unless IATA makes a statement otherwise, agencies DO NOT NEED a QSA to do a level 1 certification or sign off on SAQ, unless explicitly requested do. Since IATA is the processor for the agencies in this case, it’s their call. But it’s a big call, because level 4 merchants aren’t very large and they might not be able to get QSAs to help sign off their documents. We are working with one of the largest merchants at the moment and even they are not requested by their acquirer to get a sign off on SAQ from a QSA.

99.99% of agencies out there will fall under the Level 3 or Level 4 merchant band and we all know what that entails – SAQ, signed off by their executive – only if required should they get a QSA to participate. But it helps to have someone that knows about PCI or else you would be groping in the dark with the SAQ options.

What we see a lot are merchants automatically selecting SAQ D-MER when it comes to PCI. Again you don’t have to.  Depending on the number of channels you have you might be able to select C-VT, or B, or even A-EP, A. We call these specialised SAQs – remember, if you don’t meet any of these criteria, you drop into the SAQ D bucket.

What many people don’t know is that you can opt for a separate SAQ for each channel, instead of having one SAQ D to cover all. Both are possible, but its just that for SAQ D, you would be marking a fair bit N/A if you are say just doing POS and e-commerce.

Before we venture into the dark arts of SAQ selection, let’s explore probable channels that agencies have.

a) Through the website – this is not that common actually. Now with Expedia, Agoda and all these portals coming up, it’s easier for consumers to get the best price regardless. But for corporate trips etc, some of these websites might still prove useful. Most of these websites will either redirect to another payment gateway or might even link to a GDS. Either way, they generally do not host the site where credit card information is being entered. So in this case, SAQ A might work. If they have card information collected in their environment before sending it over to the payment gateway, then SAQ A-EP. Questions for A = 22, A-EP = 191. So please think it over as to why you want to collect card information on your site.

b) MOTO – or Mail Order Telephone Order. In most cases, there would be a call into the agency requesting booking. Now it’s important then how card data is now transmitted, processed and stored. The agent likely will not have any funky call system like Ameyo or Genesys, and may just rely on our good old PSTN phone line. Once call is received, the agent will request details , including card details and type it directly into a GDS system. In this case, as there is no recording on the line, it’s fine, and as long as the agent is using a hardened desktop/laptop with a virtual terminal into the GDS, you can rely on SAQ C-VT to cover this. Now, what is a virtual terminal? Basically, it’s a virtual POS. You just don’t need to buy the POS devices. All GDS offers this solution, whereby you log into the virtual terminal and just input the card information.

The tricky part here is that not all information is received on phone. Sometimes, clients will say, OK, let me send you a batch of credit card info in a text file via email. Or, hold on, I am shooting you an image via WhatsApp or Skype. Or, wait, let me fax you the form. Oops.

Now what happens is that other channels are being utilised. You have storage of credit card information. You are no longer eligible for C-VT. C-VT = 81 questions. D-Mer = 332 questions. So, if you can stop these practices, I would suggest, go ahead and stop it.

c) Walk-In – most agencies have outlet(s) and you can walk in, and pay off the counter. They will either key in the information as if you had called, into the virtual terminal – OR, they might have an actual POS machine for you so you can dip your card and make a card present transaction. In this case, it depends on how the POS machine is setup. It would be pretty similar then to a normal retailer transaction – like a grocery store or departmental store. We’ve already written this at length here: http://www.pkfavantedge.com/it-audit/the-saq-bs-and-how-they-apply-to-you/.

So there you have it. Remember the following

SAQ A = 22 questions (good!)

SAQ A-EP = 191 questions (not great!)

SAQ B = 41 questions (good!)

SAQ B-IP = 82 questions (not so great!)

SAQ C = 160 (not very good!)

SAQ C-VT = 81 (that’s ok!)

SAQ D- MER(SP) = 332 or 359 questions (bye bye weekends!)

So there you have it. If you are an agency or a retailer and you need any help at all to clarify this PCI-DSS requirement, drop us an email at pcidss@pkfmalaysia.com. We will attend to you immediately!

 

 

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