PCI Article C24

PCI DSS do not become the Weakest link
By David Ricketts Head of Marketing C24

All merchants and service providers who store, process and transmit credit card information
must comply with PCI DSS which was developed as part of a collaboration by MasterCard
Worldwide, Visa International, American Express, Discover Financial Services and JCB. The
standard serves as directive and guideline to help organisations prevent the misuse of credit
card data. To comply retailers must undergo quarterly self-assessments as well as audits
(vulnerability scans) by an Approved Scanning Vendor (ASV) and in accordance with PCI DSS
Scanning Procedures.

Large merchants (i.e. more than 6 million transactions per year for all outlets including e-
commerce) and service providers (i.e. more than 1 million transactions per year) must also
undergo annual on-site audits performed by a PCI DSS Qualified Security Assessor (QSA). The
audit is inclusive of all systems, applications and technical measures, as well as policies and
procedures used in the storing, processing and transmission of cardholder and credit card
information.

What Is Considered Sensitive Data
Per the standard, the following information is considered sensitive:

 Primary Account Number (PAN)
 Cardholder name
 Service code
 Expiration date
 Pin Verification Value (PVV)
 Security code (3 or 4 digit)

In accordance with the standard, merchants or service providers are not allowed to store the
PVV or the security code that uniquely identifies the piece of plastic in the cardholder’s

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C24 David Ricketts PCI DSS

possession at the time of the transaction. However, the PAN, cardholder name, service code and
expiration date may be stored.

PCI Compliance Is More Than Just Securing Cardholder Information Within Databases
Many organisations naturally focus efforts for protecting cardholder information within
databases, a challenge for which technical solutions abound. However, as breaches like
Citigroup’s1 and Pfizer’s have shown, enterprises also face challenges controlling access to and
dissemination of spreadsheets and documents that contain cardholder information. Exporting
sensitive cardholder data out of databases is all too common, often done so that the
information may be analysed as part of market research or be imported into other applications.
In fact, 42 percent of enterprises hold customer data in spreadsheets as a matter of course
according to Ventana Research2, and these figures don’t include the individual users who
conduct such exports on their own for business analytics or other purposes.

In the case of PCI, it is important to protect not only databases, but also file shares and
SharePoint sites that house these spreadsheets and documents. Organisations need to
implement a comprehensive system for not only finding the PCI information that resides outside
of databases, but also for authorization, access control and auditing of all unstructured & semi-
structured data stores. When file shares contain any of the PCI-designated sensitive information,
organisations need to audit, review, and tighten up access to these shared networked resources
as part of their PCI compliance efforts.

What Are The Costs/Risks Of Non-Compliance
Credit card fraud and misuse reaches into the billions of dollars annually. While the costs per
incident may vary by merchant size, they include:

 Loss of income from fraudulent transaction

1
Citigroup Customer Data Leaked on LimeWire (2007): http://www.eweek.com/c/a/Security/Citigroup-Customer-
Data-Leaked-on-LimeWire/

2
Organisations Struggle To Manage Customer Data As Information Assets (2007):
http://www.itbusinessedge.com/cm/community/features/guestopinions/blog/organizations-struggle-to-
managecustomer-data-as-information-assets/?cs=22600

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 Cost to reissue cards
 Costs of investigation and possible litigation
 Possible fines imposed by credit card companies
 Loss of reputation, customer confidence and business
 Possible loss of ability to accept credit cards for payment

PCI Compliance the Easy Way
There are five principles organisations need to address when seeking to comply with PCI DSS:

 Continual identification of relevant data
 A process to identify and revoke unwarranted access
 A process to configure and review logical access controls
 Proper separation of duties
 Evidence that these processes are being followed

Logical access control objectives are based on the principal of least privilege; access should be
granted to only those resources that are required to perform a user’s function. Many audit
regulations now focus on proper access and use of unstructured data on file systems and
SharePoint servers.

It stands to reason that wherever the organisation has permissions to write or read data, a data
owner, or steward, should be designated to make decisions about who gets access, acceptable
use, etc. Otherwise, decisions about that data are left up to members of IT, who have little
organisational context about the data they are trying to manage and protect.
In order to identify an owner/steward, IT needs to know who is making use of data—analysing
data usage over time provides actionable business intelligence on the probable data owner of
any folder. Using these statistics, administrators can quickly see the most active users of a data
container. Often, one of the active users is the data owner. If none of the active users is the
business owner, he or she will likely work for the data owner, or at least know who the data
owner is likely to be.

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Data Owners/stewards need to be automatically involved in the authorisation workflows and
reviews for their data. Automation should enable users to request access to data, route the
requests to the data owner and other appropriate parties, execute the appropriate actions, and
track each requests. Entitlement reviews, or attestations, should also be similarly automated
and auditable.

While this may all seem an insurmountable task, software solutions are available to find PCI
data, aggregate user and group information, permissions information, access information, and
content information (which files actually contain PCI data) from directories and file servers.
Sophisticated analytics can then be applied to reveal detailed data use, misuse, and determine
rightful access based on business need. Using this intelligence, organisations can then:

 Continually scan for PCI data (the audit trail enables true incremental scanning for only
changed or modified files)
 Protect data by removing overly permissive access controls
 Ensure on-going compliance with automated entitlement reviews, and authorization
workflows
 Restrict unstructured data access to those with a business need for that data
 Automatically update access controls to account for changes in roles and file server
contents
 Track and monitor file touches for each and every user
 Alert on behavioural deviations that may signal a possible data breach

Securing your customers sensitive information is not only important for PCI DSS compliance it is
also good business sense, as a breach doesn’t just affect the person whose account has been
emptied— it will affect your reputation and your partners if the violation is traced to doing
business with you. Compliance is important, for every one in the chain, and it is easier than
many people realize to not be the weakest link.

If you require further information about PCI or solution from C24 please visit www.c24.co.uk

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PCI Article C24

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PCI Article C24