IT Security Policy - PCI Compliance

Introduction

The policies and procedures outlined below must be incorporated into company practice to maintain a high level of security awareness. The protection of sensitive data demands regular training of all employees and contractors.

Review handling procedures for sensitive information and hold periodic security awareness meetings to incorporate these procedures into day to day company practice.
Distribute this security policy document to all company employees to read. It is required that all employees confirm that they understand the content of this security policy document by signing an acknowledgement form (see Appendix A).
All employees that handle sensitive information will undergo background checks (such as criminal and credit record checks, within the limits of the local law) before they commence their employment with the Company.
All third parties with access to credit card account numbers are contractually obligated to comply with card association security standards (PCI/DSS).
Company security policies must be reviewed annually and updated as needed.

Credit Card (PCI) Security Incident Response Plan

The Company PCI Security Incident Response Team (PCI Response Team) is comprised of the Information Security Officer and Merchant Services. The Company PCI security incident response plan is as follows:

Each department must report an incident to the Information Security Officer (preferably) or to another member of the PCI Response Team.
That member of the team receiving the report will advise the PCI Response Team of the incident.
The PCI Response Team will investigate the incident and assist the potentially compromised department in limiting the exposure of cardholder data and in mitigating the risks associated with the incident.
The PCI Response Team will resolve the problem to the satisfaction of all parties involved, including reporting the incident and findings to the appropriate parties (credit card associations, credit card processors, etc.) as necessary.
The PCI Response Team will determine if policies and processes need to be updated to avoid a similar incident in the future, and whether additional safeguards are required in the environment where the incident occurred, or for the institution.

The Company PCI Security Incident Response Team (or equivalent in your organisation):

CIO
Communications Director
Compliance Officer
Counsel
Information Security Officer
Collections & Merchant Services
Risk Manager

Information Security PCI Incident Response Procedures:

A department that reasonably believes it may have an account breach, or a breach of cardholder information or of systems related to the PCI environment in general, must inform the Company PCI Incident Response Team. After being notified of a compromise, the PCI Response Team and other designated staff will implement the PCI Incident Response Plan to assist and augment departments’ response plans.

Incident Response Notification

Escalation Members (or equivalent in your company):

Escalation – First Level:

Information Security Officer Controller
Executive Project Director for Credit Collections and Merchant Services Legal
Counsel
Risk Manager
Director of the Company Communications

Escalation – Second Level:

The Company President
Executive Cabinet
Internal Audit
Auxiliary members as needed

External Contacts (as needed)

Merchant Provider Card Brands
Internet Service Provider (if applicable)
Internet Service Provider of Intruder (if applicable) Communication Carriers (local and long distance) Business Partners
Insurance Carrier
External Response Team as applicable (CERT Coordination Center 1, etc) Law Enforcement Agencies as applicable inn local jurisdiction

In response to a systems compromise, the PCI Response Team and designees will:

Ensure compromised system/s is isolated on/from the network.
Gather, review and analyse the logs and related information from various central and local safeguards and security controls
Conduct appropriate forensic analysis of compromised system.
Contact internal and external departments and entities as appropriate.
Make forensic and log analysis available to appropriate law enforcement or card industry security personnel, as required.
Assist law enforcement and card industry security personnel in investigative processes, including in prosecutions.

The credit card companies have individually specific requirements that the Response Team must address in reporting suspected or confirmed breaches of cardholder data. See below for these requirements.

Incident Response notifications to various card schemes

In the event of a suspected security breach, alert the information security officer or your line manager immediately.
The security officer will carry out an initial investigation of the suspected security breach.
Upon confirmation that a security breach has occurred, the security officer will alert management and begin informing all relevant parties that may be affected by the compromise.

VISA Steps

If the data security compromise involves credit card account numbers, implement the following procedure:

Shut down any systems or processes involved in the breach to limit the extent and prevent further exposure.
Alert all affected parties and authorities such as the Merchant Bank (your Bank), Visa Fraud Control, and the law enforcement.
Provide details of all compromised or potentially compromised card numbers to Visa Fraud Control within 24 hrs.
For more Information visit: http://usa.visa.com/business/accepting_visa/ops_risk_management/cisp_if_ compromised.html

Visa Incident Report Template

This report must be provided to VISA within 14 days after initial report of incident to VISA. The following report content and standards must be followed when completing the incident report. Incident report must be securely distributed to VISA and Merchant Bank. Visa will classify the report as “VISA Secret” *

Executive Summary
1. Include overview of the incident
2. Include RISK Level (High, Medium, Low)
3. Determine if compromise has been contained
Background
Initial Analysis
Investigative Procedures
1. Include forensic tools used during investigation

Findings
1. Number of accounts at risk, identify those stores and compromised
2. Type of account information at risk
3. Identify ALL systems analysed. Include the following:

Domain Name System (DNS) names
Internet Protocol (IP) addresses
Operating System (OS) version
Function of system(s)

Identify ALL compromised systems. Include the following:

DNS names
IP addresses
OS version
Function of System(s)

Timeframe of compromise
Any data exported by intruder
Establish how and source of compromise
Check all potential database locations to ensure that no CVV2, Track 1 or Track 2 data is stored anywhere, whether encrypted or unencrypted (e.g., duplicate or backup tables or databases, databases used in development, stage or testing environments, data on software engineers’ machines, etc.)
If applicable, review VisaNet endpoint security and determine risk

Compromised Entity Action
Recommendations
Contact(s) at entity and security assessor performing investigation

*This classification applies to the most sensitive business information, which is intended for use within VISA. Its unauthorized disclosure could seriously and adversely impact VISA, its employees, member banks, business partners, and/or the Brand.

MasterCard Steps

Within 24 hours of an account compromise event, notify the MasterCard Compromised Account Team via phone at 1-636-722-4100.
Provide a detailed written statement of fact about the account compromise (including the contributing circumstances) via secured e-mail to compromised_account_team@mastercard.com.
Provide the MasterCard Merchant Fraud Control Department with a complete list of all known compromised account numbers.
Within 72 hours of knowledge of a suspected account compromise, engage the services of a data security firm acceptable to MasterCard to assess the vulnerability of the compromised data and related systems (such as detailed forensics evaluation).
Provide weekly written status reports to MasterCard, addressing open questions and issues until the audit is complete to the satisfaction of MasterCard.
Promptly furnish updated lists of potential or known compromised account numbers, additional documentation, and other information that MasterCard may request.
Provide finding of all audits and investigations to the MasterCard Merchant Fraud Control department within the required time frame and continue to address any outstanding exposure or recommendation until resolved to the satisfaction of MasterCard.

Once MasterCard obtains the details of the account data compromise and the list of compromised account numbers, MasterCard will:

Identify the issuers of the accounts that were suspected to have been compromised and group all known accounts under the respective parent member IDs.
Distribute the account number data to its respective issuers.

Employees of the company will be expected to report to the security officer for any security related issues. The role of the security officer is to effectively communicate all security policies and procedures to employees within the company and contractors. In addition to this, the security officer will oversee the scheduling of security training sessions, monitor and enforce the security policies outlined in both this document and at the training sessions and finally, oversee the implantation of the incident response plan in the event of a sensitive data compromise.

Discover Card Steps

Within 24 hours of an account compromise event, notify Discover Fraud Prevention at (800) 347-3102
Prepare a detailed written statement of fact about the account compromise including the contributing circumstances
Prepare a list of all known compromised account numbers
Obtain additional specific requirements from Discover Card

American Express Steps

Within 24 hours of an account compromise event, notify American Express Merchant Services at (800) 528-5200 in the U.S.
Prepare a detailed written statement of fact about the account compromise including the contributing circumstances
Prepare a list of all known compromised account numbers Obtain additional specific requirements from American Express