From the webcast I’ve done awhile back, here are some fun Q&A that I volunteered to answer. PCI DSS literati reading this blog, don’t freak out – this is BASIC since the webinar was for Level4 ecommerce merchants.
Q: I have a hosted Card Service Provider, are the SSL tunnel with certificates good enough security? What PCI say about this?
A: Well, “SSL tunnel with certificates” is good security (at least compared to no SSL!), but is it enough? Not really. PCI DSS has a long list of other security controls which need to be implemented - for example, if are and e-commerce merchant, web application security is extremely important, likely more so than SSL.
Q: Another crystal ball question. Do you think the day will come when merchants are not permitted to store credit card information in order to be PCI compliant?
A: Well, merchants are not permitted to store CVV data today, merchants are not permitted to store PAN in cleartext and they are strongly discouraged to store PANs at all today (example) – all as per PCI DSS. I do not foresee a complete ban on PAN storage, but these rules might well become stronger. If
Q: If we are not processing cards at all, but instead are protecting client lists, how much security is needed?
A: The beauty of this question is that it is up to you to determine that risk. There are no regulations to compel you so you have to make your own decisions based on your own research. The answer might vary from “none” (if these are essentially public) to “a lot” if loss of those lists will destroy your business.
Q: What about ACHDirect processing?
A: Not under PCI – all risks are yours, same as above. In recent years, a lot of smaller companies have been attacked by ACH credential stealing malicious software.
Q: The question about 2 or 3 things to secure their system. Could they not just go to dial up credit terminals?
A: They sure can a net will help protect the card data.
Q: How can a criminal use stolen card data for themselves?
A: Charge cards themselves, resell them in bulk, manufacture cards for resale and use (if Track2 data is available), buy and resell goods, buy software and then pirate it, etc, etc, etc. Think what you’d do if you are given a “free credit card”
Q: Retailer that use MPLS networks have historically not had to encrypt data over a "private" network connection like MPLS. Do you expect MPLS to require data encryption and firewalling like you find with networks served by public internet connections?
A: No, this is not a “public” network defined in PCI DSS, at least to the best of my knowledge. So, while encryption and firewalls are “a good idea”, they are not “the law.” Requirement 4.1 states that “Use strong cryptography and security protocols (for example, SSL/TLS, IPSEC, SSH, etc.) to safeguard sensitive cardholder data during transmission over open, public networks”
Q: When we went to our website provider to close ports as we said it was not PCI compliant. we were told that because there was no CC data being taken through the site (it's informational only), it doesn't have to be PCI compliant. Is that true?
A: Not exactly true. Public servers are in scope and must be scanned for vulnerabilities; having less open ports will help you have less vulnerabilities exposed to Internet. Now, if you don’t accept credit cards at all in your business, then obviously your website is not under PCI DSS.
Q: We have a third party vendor that handles our payments; what tools can we use to audit our vendor?
A: Likely, you're talking not about technical tools, but “legal tools” like SLA, agreements, etc.
Q: To be totally honest, we save the CVV number. This is because is it a huge annoyance to have to call the customer every time we need to charge the card. Is there another solution so we don't have to contact our customers for their CVV number?
A: It is OK to save the CVV if you accept the fact that can never be PCI DSS compliant and will always be in violation of your agreement with your acquiring bank. If I were you, I’d ask you acquiring bank about how to do recurring payments without saving the CVV – it IS possible.
Q: Besides a firewall and web application firewall what other layer of security can be used?
A: Yes, many (if you are under SAQ D) – please read PCI DSS. Examples include log management, configuration management, IDS/IPS, FIM, etc, etc.
Q: What about credit card data stored in QuickBooks?
A: QB does have encryption, do you use it? PANs stored in this application are just like any other stored complete PANs: they need to be encrypted.
Q: What IDS/IPS system would you recommend?
A: Snort is free and is hard NOT to recommend for that reason.
Q: I use PayPal website Pro integrated into my site to process payments. Do I still need a firewall to be PCI DSS compliant?
A: It depends how it is used, but most likely yes (and not just a firewall). Read this for details.
Q: If we use a swipe machine, are we storing data, or is it just transmitted?
A: Depends on the machine, likely just transmitted but older machines are known to store data and should be replaced, whenever possible.
Q: What products/solutions do you recommend for managing logs from different types of applications (e.g., web applications) and systems (e.g., /var/log/*) ?
A: Many tools exist with prices from $0 to (literally) millions, here are some of my favorite free log tools.
Q: How do I know if a website is PCI compliant before I accept credit cards? Should the web host give me a certificate?
A: Ah, good question and you are not the only one to wonder about that. But there's no good answer! Many security seals exist (and some mention PCI DSS scanning on them), but their credibility is frequently called into question.
Q: Why hasn't the term 'passphrase' taken off? I tell all my users, use a pass phrase, with proper punctuation and spacing.
A: Hard to say, this is a really good way to create long while memorable passwords.
Q: We still transmit our payment card data over telephone lines. Is that less risky?
A: Yes, much less risky. Dial-up terminal makes PCI DSS easier and genuinely reduces the risks to cardholder data
Q: On the Who/What do Hackers Target question, what are the constraints for including the company data? Are all companies included or only ones that require PCI compliance?
A: All data is potentially under risk – but payment card data (and now ACH credentials) are easier to profit from, if you are a criminal. Many companies use PCI DSS to learn about security and then expand their knowledge to protect other kinds of data, beyond the card numbers.
Enjoy the basics!
Possibly related posts:
- Blatant: buy our PCI book NOW!