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Brian Pennington

A blog about Cyber Security & Compliance

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Payment card industry

PCI Security Standards Council publishes card production security requirements

The PCI Security Standards Council (PCI SSC), has announced the publication of a standard for secure payment card production.

The standard consists of two sets of requirements:

  1. PCI Card Production Physical Security Requirements
  2. PCI Card Production Logical Security Requirements

Together, these documents provide card vendors with a comprehensive source of information describing the security requirements to follow for card production activities including card manufacture, chip embedding, magnet-stripe encoding, embossing, card personalization, chip initialization, chip personalization.

Formerly managed as separate requirements by each payment card brand, the Council aligned these requirements and solicited feedback from the PCI community to produce one set of criteria recognized across the industry. The resulting standard is designed to secure the components and sensitive data involved in the production of payment cards and protect against the fraudulent use of card materials.

It’s broken down into two core areas:

  1. Physical security requirements – for all card vendors, these requirements address the presence, movement, and accountability of a card, including tangible features such as the security of the premises, personnel access to secure areas, and CCTV surveillance.
  2. Logical security requirements – for card personalization vendors, these requirements address threats to the confidentiality of personalization data during data transfer, access, storage, and destruction; and all aspects associated with cryptographic key management, including the protection of issuer keys used in the personalization process.

The security requirements are available for immediate download here. Vendors should work with the individual card brands to confirm timing for when future security reviews must be performed against the new PCI Card Production Security Requirements.

In line with other PCI Standards, the requirements will be updated on a three-year lifecycle, based on feedback from the PCI community.

There are a lot of pieces involved in securely producing payment cards, from design all the way through delivery,” said Bob Russo, general manager, PCI Security Standards Council. “The publication of these requirements gives card vendors one set of criteria to follow, and as we’ve seen with our other standards, will help drive improved security across the payments chain

Want to be PCI DSS compliant? Here are 5 mistakes to avoid.

Charles Denyer a QSA with NDB has produced a list of 5 Mistakes all people striving for PCI DSS compliance must avoid. 

  1. Not conducting a formal Readiness Assessment.  It’s important with PCI DSS compliance to truly understand all facets of the Payment Card Industry Data Security Standards (PCI DSS) provisions, which essentially means answering the “who, what, when, where, and why” of PCI with a comprehensive Readiness Assessment. And by no means should it be looked upon as yet another added cost to the engagement, rather, a proactive and necessary measure for properly defining and understanding many important facet of PCI, which by the way, is always a moving target, to say the least. A competent, well-skilled PCI-QSA, such as Charles Denyer of NDB Advisory, can provide your organization with a PCI DSS Readiness Assessment. Knowing what you are getting into is important! 
  2. Having no buy in from senior management and others. “Going it alone” as the saying goes, can have its risks and rewards – but in the case of PCI DSS compliance – it’s not only a bad idea, but one that creates real challenges for organizations. Sure management may very well be aware of their organization undertaking PCI compliance, but have they provided true operational and financial support, have they taken the time to really understand the commitment and effort needed? If not, then it’s time to make them aware of this, and soon.  Remember, setting expectations for PCI compliance is a must, no questions about it. 
  3. Failing to understand PCI Scope.  Organizations struggle with this immensely – after all – determining the actual scope for purposes of PCI compliance can be challenging, and it’s not always a black and white answer? Do you have a “flat” network? What is the true definition of the cardholder data environment (CDE)? What third-party providers are in scope? These, and many, many other questions, often require thoughtful consideration for PCI compliance. 
  4. Not conducting Remediation efforts.  As a PCI-QSA, I’m amazed at the lack of remediation efforts by companies pursuing PCI compliance.  What I find more troubling is that these remediation efforts – when even conducted – are only undertaken for a sample of system components, not the entire population of in-scope items. Being compliant with the Payment Card Industry Data Security Standards means meeting all the stated requirements for ALL in-scope systems components, not just a chosen few.  A PCI-QSA with true independence and professionalism will always tell their clients that, and that’s exactly what I’m doing here!  Simply put, remediate, and remediate all items that are in-scope for an actual PCI DSS assessment. 
  5. Failing to recognize the importance of policies and procedures.  Here’s an issue that seems to go unnoticed many times regarding PCI compliance – after all – how challenging and time-consuming can it really be to develop PCI policies and procedures?  Very challenging and time-consuming, just look at the amount of documents that’s required by PCI – policies for this, procedures for that – get the point?  Sure, PCI compliance is technical in nature, but don’t lose sight of one of the most important requirements, and that’s developing a comprehensive set of PCI policies and procedures.  As a PCI-QSA, my advice is to hire an expert consultant to develop a customized set of these policies (which is part of the services offered by NDB Advisory) or to use the high-quality PCI security policies from pcipolicyportal.com.

Supporting point 3 there is a good white paper “8 ways to reduce the scope of PCI DSS” here.

65% of businesses do not protect their customers’ private data

According to a survey by GreenSQL more than 65% of businesses do not protect their customers’ private data from unauthorised employees and consultants.

The results are interesting because every day we hear of another data breach or another form of malware which can steal data or at least damage data and you would think that with this amount of coverage business would sit up and start protecting their livelihood because that is what customer information is, their livelihood.

For an idea of the scale of the UK’s problem have a look at my post “Who has breached the Data Protection Act in 2012? Find the complete list here“.

Maybe it is bad news fatigue? Maybe the constant flow of horror stories makes them think that they cannot do anything about it so why bother.

I can understand the sentiment because on a personal level I do not wear a Kevlar jacket and carry pepper spray when I walk my dogs on a cold dark winter evening on the distant chance I might be mugged.

However, business cannot escape their contractual commitment to protect credit card data under the Payment Card Industry’s Data Security Standards (PCI DSS) and they cannot escape the legislative requirements to protect Personally identifiable Information (PII) for example the Data Protection Act and the pending European Wide Data Protection Act.

The survey results fall into three categories

  1. Ignore. 65% take no preventative measures
  2. Think about it. 23% use masking techniques only in non-production environments, such as dummy data and scrambling
  3. Try. 12% deploy dynamic data masking solutions on their production environments

I suspect that those who indicated that they deploy technologies to mask data are talking about credit card data where all payment applications are governed by the Payment Card Industry’s PA DSS but it should be applied to all sensitive data that could cause financial or reputational damage to anyone; customer, employee or contractor.

“Most companies would say protecting customer data is critical to maintaining their business and reputation,” said GreenSQL CEO, Amir Sadeh. “However, something is wrong when we discover that many IT departments are making no masking efforts whatsoever, and others are taking tepid approaches.”

GreenSQL surveyed “hundreds of IT managers and developers at large organizations” about the measures they took to prevent developers, QA, DBAs, consultants, outsourced employees, suppliers and application users from having access to sensitive data.

In summary adding protection to data bases and sensitive data is not hard and with current market trends moving towards cloud based solutions the costs are no longer prohibitive compared to becoming one of those horror stories people keep ignoring.

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PCI Security Standards Council’s Qualified Integrators and Resellers program is now live

The PCI SSC’s the Qualified Integrators and Resellers (QIR)™ Program will train and qualify integrators and resellers that sell, install and/or service payment applications on the secure installation and maintenance of PA-DSS validated payment applications to support merchant PCI DSS security efforts.

Eligible organizations can now register for the QIR program by visiting the PCI SSC website. Training will be available beginning October 1, 2012.

“Integrators and resellers play a key role in securing the payment ecosystem as merchants depend on these providers to install, configure, and maintain their PA-DSS validated applications in a way that facilitates their PCI DSS compliance. Industry reports point to errors being made during the implementation and maintenance process as a significant risk to the security of cardholder data. The QIR program provides integrators and resellers with highly specialized training to help address these risks, such as ensuring that remote access is used securely and that all vendor default accounts and values are disabled or removed before the customer uses the application.

Merchants will benefit from a global list of QIRs on the PCI SSC website, providing them with a trusted resource for selecting PCI approved implementation providers. The program also includes a feedback loop for merchants to evaluate a QIR’s performance.”

QIR customers will have the opportunity to submit a formal feedback form online, which the Council will review as part of its quality assurance process.

The QIR training curriculum is comprised of an eight-hour self-paced eLearning course made up of three modules covering:

  • PCI DSS awareness overview and understanding industry participants
  • QIR roles and responsibilities
  • PA-DSS and key considerations for QIRs when applying expertise to installing and configuring the PA-DSS application
  • Guidance for preparing and implementing a qualified installation

After taking the eLearning course, participants will be eligible to schedule the 90-minute exam at one of more than 4,000 Pearson VUE Testing Centers worldwide. Once a company has two employees complete the training and pass the exam, the company and QIRs will be listed on the PCI SSC website for merchants to use as a resource for choosing a PCI SSC approved provider. The training course and exam will be available October 1, 2012.

The Council will also host a webinar for those interested in learning more about the QIR program, followed by a live question and answer session with PCI SSC experts:

  • To register for the Thursday, August 16, 2012 session, click here.
  • To register for the Wednesday, August 29, 2012 session, click here.

“Although the merchant community continues to accept and adopt PCI, small merchants are increasingly being targeted as opportunities to steal card data,” said PCI SSC Chair and Vice President of Global Data Security Policies and Process for American Express, Mike Mitchell.

“This new and exciting PCI program will continue to close the gap from implementation, to ongoing compliance and in the assessment processes. Merchants should start to feel better about having a “hard-hitting” partner in their fight to prevent fraud.”

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PCI Security Standards Council releases Point-to-Point encryption (P2PE) resources

The PCI Security Standards Council (PCI SSC), has announced availability of the Point-to-Point Encryption (P2PE) Program Guide and Self-Assessment Questionnaire (SAQ) to support implementation of hardware-based point-to-point encryption (P2PE) solutions. They are downloadable from the PCI SSC website in an MS Word format.

The resources follow the Council’s release of updated Solution Requirements and Testing Procedures for hardware-based P2PE solutions in April, (find the link in my resources page)which provide a method for vendors to validate their P2PE solutions and for merchants to reduce the scope of their PCI DSS assessments by using a validated P2PE solution for accepting and processing payment card data.

Eligible merchants using these P2PE hardware solutions may be able to reduce the scope of their PCI DSS assessments and validate to a reduced set of PCI DSS requirements. To help with this validation process, the Council has developed a new Self-Assessment Questionnaire (SAQ P2PE-HW).

SAQ P2PE-HW is for merchants who process cardholder data via hardware terminals included in a validated P2PE solution and consists of the following components:

  • Merchant eligibility criteria
  • SAQ completion steps
  • Self-Assessment Questionnaire (validation of PCI DSS Requirements)
  • Attestation of Compliance, including Attestation of PIM Implementation

Merchants should refer to their acquirer and/or payment brand to determine if they are eligible to use this new SAQ.

The Council has also updated the PCI DSS SAQ Instructions and Guidelines document to provide additional guidance on use of the SAQ P2PE-HW.

The PCI P2PE Program Guide is designed to help solution providers, application vendors, and P2PE assessors understand how to complete a P2PE assessment and submit it to the Council for acceptance and listing on the PCI SSC website.

The document includes:

  • Overview of P2PE solution validation processes
  • Considerations for P2PE Solution providers preparing for assessment
  • Reporting considerations for P2PE assessors
  • Considerations for managing validated P2PE Solutions
  • Listing of applications used in P2PE solutions

Solution providers, application vendors, and P2PE assessors can use this document immediately to plan for their P2PE assessments.

The Council will shortly be providing templates and Reporting Instructions for P2PE validation reports, as well as new Attestations of Validation (AOVs) and vendor release agreement (VRA).

P2PE assessors, solution providers and application vendors can then complete their assessments of P2PE Solutions and applications and submit their reports and validation documentation to the Council for acceptance and listing. The Council will list the validated solutions on the PCI SSC website for merchants to use.

“These resources are a critical part of rolling out this program,”

said Bob Russo, general manager, PCI Security Standards Council

“The program guide outlines the submission and listing process for P2PE solution providers and application vendors who want to validate their products, while the SAQ will help simplify PCI DSS validation efforts for merchants taking advantage of this process to minimize the amount of cardholder data in their environments.”

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PCI Point-to-Point Encryption Solution Requirements and Testing Procedures v1.1

The Payments Security Standards Council (PCI SSC) have released their solutions Requirements and Testing Procedures version 1.1 for Point-to-Point Encryption (P2PE).

The press release can be found here.

The main document is 210 pages long but for those who have looked into this before there is a short four page summary of changes from version 1.0 to version 1.1 here.

The document covers many things but the five main scope assessments for P2PE Solutions are

  1. Network Segmentation
  2. Third Parties/Outsourcing
  3. Sampling of System Components
  4. Multiple Acquirers
  5. P2PE Program Guide

Scope of Assessment for P2PE Solutions

The first step of a P2PE solution assessment is to accurately determine the scope of the solution. At least annually and prior to each assessment, the solution provider should confirm the accuracy of their solution scope by identifying all devices, P2PE data flows and processes, key-management functions and account-data stores, and ensure they are included in the solution scope. To ensure the accuracy of the solution scope is maintained on an on going basis, the solution provider must have processes in place that ensure the following:

  • Any changes are implemented in a manner that ensures continued adherence to P2PE requirements for the entire solution.
  • Any new rollouts/additions adhere to all P2PE solution requirements.
  • Any new rollouts/additions are included in the next P2PE assessment.

Network Segmentation

The solution provider must ensure that network segmentation is in place between any systems owned or managed by the solution provider that are used in the P2PE solution, and any that are not included in their PCI DSS compliant environment. The QSA (P2PE) must validate that the network segmentation is adequate to isolate the P2PE environment from out-of-scope networks and systems.

Third Parties/Outsourcing

A given P2PE solution may be entirely performed and managed by a single solution provider, or the solution provider may outsource certain functions (for example, loading keys into POIs) to third parties who perform these functions on behalf of the solution provider. All third parties that perform P2PE functions on behalf of the assessed P2PE solution provider, including POI vendors, KIFs, CAs, etc., must be validated per P2PE solution requirements.

There are two options for third-party entities performing functions on behalf of solution providers to validate compliance:

  1. They can undergo a P2PE assessment of relevant P2PE requirements on their own and provide evidence to their customers to demonstrate their compliance; or
  2. If they do not undergo their own P2PE assessment, they will need to have their services reviewed during the course of each of their solution provider customers’ P2PE assessments.

Multiple Acquirers

The P2PE standard outlines the technology and processes needed to ensure the security of a solution that protects account data from the point of interaction to the solution provider. In some instances, multiple acquirers or multiple solution providers may manage one or more P2PE solutions on the same merchant POI device. P2PE does not preclude these scenarios, as the business processes which govern this shared environment are outside the responsibility of the PCI SSC.

P2PE Program Guide

Please refer to the P2PE Program Guide for information about the P2PE program, including the following topics:

  • P2PE Report on Validation submission and acceptance processes
  • Annual renewal process for solutions included on the list of Validated P2PE Solutions
  • Notification responsibilities in the event a listed P2PE solution is determined to be at fault in a compromise

Third Parties/Outsourcing

A given P2PE solution may be entirely performed and managed by a single solution provider, or the solution provider may outsource certain functions (for example, loading keys into POIs) to third parties who perform these functions on behalf of the solution provider. All third parties that perform P2PE functions on behalf of the assessed P2PE solution provider, including POI vendors, KIFs, CAs, etc., must be validated per P2PE solution requirements.

There are two options for third-party entities performing functions on behalf of solution providers to validate compliance:

  1. They can undergo a P2PE assessment of relevant P2PE requirements on their own and provide evidence to their customers to demonstrate their compliance; or
  2. If they do not undergo their own P2PE assessment, they will need to have their services reviewed during the course of each of their solution provider customers’ P2PE assessments.

At-a-Glance – Steps Required to Create and Validate a P2PE Solution

The process for developing and validating a P2PE solution that uses SCDs for encryption, decryption, and cryptographic key management is provided below. This flow chart and the following table illustrate the parties responsible for implementing requirements and validating compliance with each domain, the high-level purpose of controls for each domain, and how validation of each domain can ultimately lead to a P2PE solution validation.

Like a lot of people I shall be looking into the details to see where existing and planned solutions meet the standard. The full 210 page document can be found here.

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The PCI SSC has opened its registration for the 2012 PCI Community Meetings

PCI North American Community Meeting will be held on September 12-14, 2012 in Orlando, Florida

PCI European Community Meeting will be held this year in Dublin, Ireland, October 22-24, 2012

This year’s meetings offer Council Participating Organizations and PCI stakeholders access to three days of knowledge sharing, networking and learning, including keynote presentations from industry experts, PCI case studies, and technical sessions.

“2012 is a critical year in the standards development process that hinges on feedback from the PCI community. At this year’s meeting, we’ll focus on discussing stakeholder feedback on the standards in preparation for release of the next versions of the PCI DSS and PA-DSS in 2013, as well as share our successes and challenges, ideas and suggestions as a community,” said Bob Russo, general manager, PCI Security Standards Council. “We’ll discuss Council initiatives, including the Point-to-Point Encryption (P2PE) program, mobile payment acceptance security and other technology areas, as well as the work being done through our Special Interest Groups. Attendees will also have the opportunity to take advantage of our PCI SSC Training offerings.”

New to this year’s agenda, the Community Meetings will also feature:

  • Increased networking opportunitie
  • Targeted breakout sessions for different stakeholder groups
  • More industry case studies delivered by members of the PCI community
  • Expanded opportunities to meet with card brands
  • Two-day vendor showcase
  • Event mobile app to help make the most of attendees’ time

Special sessions for Qualified Security Assessors (QSAs) and Approved Scanning Vendors (ASVs) will be held at the meetings.

Several training courses will also be available. These offerings provide participants the opportunity to combine the value of peer to peer education at the Community Meeting with more formal training sessions, maximizing their time in Orlando and Dublin.

“The record attendance at last year’s meeting is a strong testament to the work that together we as a community are doing to drive payment security forward globally, but especially within Europe,” said Jeremy King, European Regional Director. “I’m thrilled about the growing involvement of the PCI community in Europe and look forward to coming together in Dublin to continue this momentum.”

Attendance fees:

  • Participating Organization: First two registrants are free; $395 for additional registrants
  • Qualified Security Assessor (QSA)/Approved Scanning Vendor (ASV)/Internal Security Assessor (ISA)/PIN Transaction Security (PTS) members: First registrant is free; $695 for additional registrants

For more information, or to register

See you in Dublin.

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Eight Ways to Reduce PCI DSS Audit Scope by Tokenizing Cardholder Data

Credit card
Image via Wikipedia

Eight Ways to Reduce PCI DSS Audit Scope by Tokenizing Cardholder Data

Merchants are constantly seeking ways to simplify and reduce the scope of the Payment Card Industry’s Data Security Standard (PCI DSS) compliance by shrinking the footprint where cardholder data is located throughout their organization.

By reducing the scope, these Merchants can dramatically lower the cost and anxiety of PCI DSS compliance and significantly increase the chance of compliance be that an audit or a Self Assessment Questionnaire (SAQ).

The White Paper “Eight Ways to Reduce PCI DSS Audit Scope by Tokenizing Cardholder Data” explores the use of tokenization as a best practice in improving the security of credit card transactions, while at the same time minimising the cost and complexity of PCI DSS compliance by reducing audit scope.

The 8 Ways are

  1. Centralized data vault
  2. Tokens as data surrogates
  3. Tokens as surrogates for masked data
  4. No mathematical relationship between tokens and data values
  5. One-to-one or one-to-many token/data relationships
  6. Format Preserving Tokenization™
  7. Centralized key management
  8. Tokenization as a Service™ (TaaS)

For the full description of the 8 methods simply download the white paper here

Registration is required, some personal email accounts do not work e.g. Hotmail and Gmail. If you are having a problem please leave a comment and I will try to email the paper directly to you.

Also see a Free eBook  “Tokenization for Dummies” here.

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PCI Security Standards Council announces winners of Special Interest Group elections

The PCI PCI SSC today announced the results of the PCI Council election for Special Interest Groups (SIGS).

Special Interest Groups (SIG) leverage the expertise of more than 600 PCI SSC Participating Organizations and provide a vehicle for incorporating their ideas and input into the work of the Council.

Almost 500 votes were cast by merchants, financial institutions, service providers and associations for the initiatives they want to prioritize in 2012.

The three elected groups will focus on:

  • Cloud
  • eCommerce Security
  • Risk Assessment

Participating Organizations were allowed three votes on a shortlist of seven topics that were the result of 13 proposals by the community.

Successful project proposals represent a cross section of the PCI SSC community from around the globe and include active participants from CyberSource, HyTrust, Sense of Security Pty Ltd., SISA Information Security, The UK Cards Association, Trend Micro and TSYS.

This is our first SIG election and I’m really pleased with the turnout, with a quarter of all of our Participating Organizations voting. Most impressively, a third of our votes came from outside North America showing that involvement in the Council’s activity and development of PCI Standards and resources to help secure the payment chain is truly a global endeavor,” said Jeremy King, European director, PCI Security Standards Council.

I’m looking forward to close collaboration between the Council and SIG membership.”

Special Interest Groups are a critical forum for industry participation in Council initiatives to increase payment card security. SIGs focus on providing recommendations to the Council which often results in guidance for interpreting and implementing the PCI Standards. To date SIG participants have made significant contributions to Council resources on topics such as wireless security, EMV chip, point-to-point encryption and virtualized environments.

The Council invites any members of the PCI SSC community interested in participating in one of these SIG projects to indicate their interest by emailing sigs@pcisecuritystandards.org before November 30th. Following this, Council SIG leads will convene each group to formalize the group charter and precise scope of work project. This will be shared with the Community by the end of the year, with SIGs anticipated to start work in the beginning of 2012.

We’re delighted that risk assessment has been selected by our peers to move forward as a 2012 SIG project. I’d like to encourage anyone with expertise or interest in this topic area or the other final selections to get involved,” said Dharshan Shanthamurthy, chief consultant at SISA Information Security.

 “Council SIGs are a great opportunity for professional development, networking, and contributing to something that will benefit the entire industry.”

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PCI Security Standards Council adds PCI PIN Security requirements to PTS standard

The PCI Security Standards Council (PCI SSC)  has announced that the Council is expanding the PTS standards to encompass the PCI PIN Security Requirements, formerly administered by Visa and MasterCard, to provide organizations with one set of criteria for the protection of PIN data.

After officially taking over management of the requirements earlier this year, the PCI SSC solicited feedback from the PCI community to make updates to the standard. Today’s release contains a complete set of reqirements for the secure management, processing and transmission of personal identification number (PIN) data at ATMs, and attended and unattended point-of-sale (POS) terminals. The PIN Security Requirements will be included in current PTS security requirements.

The updated PTS program requirements and detailed listing of approved devices are available on the Council’s website here.

“Point of sale continues to be a security hotspot as criminals are using more advanced techniques to steal PIN and cardholder data,” said Bob Russo, general manager of the PCI Security Standards Council. The requirements are specifically geared toward protecting not just the devices that accept PINs but also the people and processes surrounding them.”

The PCI PIN Security Requirements provide one set of criteria for protection of Primary Identification Number (PIN) data. For merchants – examples of common vulnerabilities for PIN theft that the requirements address include:

  • PINs that are not protected by a secure PIN block
  • Failure to use approved cryptographic devices for PIN processing
  • Cryptographic keys that are non-random, not unique, and never change
  • Few, if any documented PIN-protection procedures
  • Audit trails or logs that are not maintained

“With this addition to the PTS requirements, we hope to strengthen POS security at merchants around the globe,” noted Russo.

The Council will also host a Webinar for Participating Organizations and the public outlining the newest updates to the PIN Transaction Security program, including the PIN Security Requirements, followed by a live Q&A session.

Register for the November 8 session here.

Register for the November 10 session here

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PCI Security Standards Council invites industry input during next phase of standards development

 The PCI Security Standards Council has launched its formal feedback period on version 2.0 of the PCI DSS and PA-DSS, inviting Participating Organizations and assessors (QSAs) to provide suggestions and commentary on the development of the next PCI Standards.

The PCI Council works on a three-year lifecycle to update the PCI Standards. Feedback from Participating Organizations representing merchants, banks, processors, vendors, security assessors and those across the payment chain is the foundational element of this process. The feedback period takes place a full year after the new versions of the DSS and PA-DSS were released, giving organizations the opportunity to provide input based on their experiences in implementing the standards. As of December 31, 2011, version 1.2.1of the PCI DSS and PA-DSS is retired and all validation efforts for compliance must follow version 2.0.

Beginning today, PCI stakeholders can submit input through a new online tool that automates and makes feedback easier to supply. All feedback will be reviewed by the Council and included in discussion for the next iteration of the PCI Standards.

In the Council’s last feedback cycle, hundreds of comments were received, with more than 50 percent coming from outside the U.S.

 “With the Council’s Participating Organization base having grown substantially in Europe over the last year, and particularly with increased global representation on our Board of Advisors, we’re really looking forward to receiving input from our stakeholders around the world,” said Jeremy King, European Director, PCI Security Standards Council. “In a changing payments environment, it’s this input that will help us maintain a global standard that ensures the protection of cardholder data remains paramount.”

Feedback submissions will be grouped into three categories – Clarifications, Additional Guidance and Evolving Requirements – and shared for discussion with Participating Organizations and the assessment community at the 2012 PCI Community Meetings.

“Our community is made up of experts from across the payments chain, around the world and from organizations of every size, each dealing with different aspects of the PCI process,” said Bob Russo, general manager, PCI Security Standards Council. “We rely on their feedback and unique experiences to help us continually improve these standards for the protection of cardholder data.”

The online feedback tool can be accessed at online here.

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PCI Security Standards Council opens election for new Special Interest Groups

The PCI Security Standards Council (PCI SSC) opens election for new Special Interest Groups (SIG).

The Council developed Special Interest Groups (SIG) to leverage the expertise of more than 600 Participating Organizations and provide a vehicle for incorporating their ideas and input into the work of the Council. SIGs focus on providing recommendations to the Council which often results in guidance for the Community to interpret and implement the PCI Standards.

To date SIG participants have made significant contributions to Council resources on topics such as

  • Wireless security
  • EMV chip
  • Point-to-Point Encryption
  • Virtualized environments

Participating Organizations are invited to submit votes for their top three of the seven shortlisted proposals. The proposals were submitted by a cross-section of merchants, acquirers, industry associations, service providers, Qualified Security Assessors (QSA) and vendors. They cover the following topics:

  • Small ecommerce merchants
  • Effective patch management that is compliant with PCI DSS requirement 6.1
  • Administrative access to systems and devices
  • Cloud
  • Small businesses
  • Hosted, managed application and service providers
  • Risk assessments

“The Council is delighted at the level of input we’ve received from the community in the form of SIG proposals,” said Jeremy King, European director, PCI Security Standards Council. “I’m particularly pleased to see such broad global representation and perspectives in submissions. Securing payment card data is a global challenge and the Council’s worldwide stakeholders are uniquely positioned to partner with us in tackling this.”

The polls close on Friday November 4th 2011.Results will be announced following the election, together with next steps on how to volunteer for the Special Interest Groups.

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Merchants are complacent about PCI DSS, report reveals.

Verizon logo
Image via Wikipedia

Verizon have launched their 2011 Payment Industry Compliance Report which draws on their experiences as a QSA company and previous annual reports.

Extracts from the report are below.

Unchanged from last year, only 21 % of organizations were fully compliant at the time of their Initial Report on Compliance (IROC). Verizon commented with “This is interesting, since most were validated to be in compliance during their prior assessment”.

  • Organizations met an average of 78% of all test procedures at the IROC stage
  • 20% of organizations passed less than half of the DSS requirements
  • 60 % scored above the 80 % mark

Organizations struggled most with the following PCI requirements:

  • 3 (protect stored cardholder data)
  • 10 (track and monitor access)
  • 11 (regularly test systems and processes)
  • 12 (maintain security policies).

The PCI Requirements showed the highest implementation levels were:

  • 4 (encrypt transmissions over public networks)
  • 5 (use and update anti-virus)
  • 7 (restrict access to need-toknow)
  • 9 (restrict physical access)

Organizations do not appear to be prioritizing their compliance efforts based on the PCI DSS Prioritized Approach published by the PCI Security Standards Council even less so than in the previous year.

A mini-study comparing governance practices to the initial compliance score suggests that the way organizations approach compliance significantly factors into their success.

Once again, organizations that suffered data breaches were much less likely to be compliant than a normal population of PCI clients. Analysis of the top threat actions leading to the compromise of payment card data continues to exhibit strong coverage within scope of the PCI DSS. For most of them, multiple layers of relevant controls exist across the standard.

In the pool of assessments performed by Verizon QSAs included in this report

  • 21% were found fully compliant at the completion of their IROC
  • This is just 1% less than in their last report, and effectively the same number

The lack of change is a disappointing, as many in the industry were hoping to see an increase in overall compliance as the PCI DSS became more familiar to an increasing number of organizations.

79% of organizations were not sufficiently prepared for their initial assessment

Having established that only 21% “passed the test” the next question becomes “what was their score?”

  • On average, organizations met 78% of all test procedures defined in the DSS at the time of their IROC.
  • Down 3% from Verizon’s last report; but again, the difference is nominal.

Therefore, the baseline set by the PCI DSS must not reflect the baseline set by the companies themselves. For most organizations, to achieve compliance they must do things they were not previously doing (or maintaining).

Another common Achilles heel of merchants and service providers in the PCI assessment process is over confidence

 “It was painful, but we made it through last year, so this year should be a breeze”

is a typical sentiment with which many organizations approach the yearly assessment. That can be a costly mistake. When the QSA arrives on-site, a mere 1/5th of businesses are found to be compliant, even when given the extra time between the on-site visit and completion of the IROC.

Complacency and fatigue are two additional drags that make maintaining compliance year over year difficult. Too many businesses approach PCI from the point of view that “what was good enough last year will be good enough this year.” But unless someone’s been babysitting a process, such as documenting and justifying all services allowed through the firewalls, things can easily be forgotten in the haste to get business done.

When examining the percentage of organizations passing each requirement at the IROC phase.

  • Some requirements show percentages dipping below 40%, while others exceed the 70% range.
  • Six of the twelve show an increase over last year, and the average is up two points.
  • However, the average number of test procedures met within each requirement is down 4%.
  • None of these numbers is indicative of a clear change given the size and makeup of the dataset, but it certainly reinforces the notion that
  • organizations continue to struggle (at varying degrees) in all areas of the DSS.

How do organisations perform against the 12 Requirement? The four highest rated Requirements are:

  • 4 (encrypt transmissions)
  • 5 (AV software)
  • 7 (logical access)
  • 9 (physical access)

Requirement 10 (tracking and monitoring) boasted the highest gain+13 %

Requirement 5 (AV software) may lose its place in the top three, which is an odd development, since AV software has for so long been among the most basic and widespread of security controls.

Requirement 4 (encrypt transmissions) showed a marked improvement which may indicate that administrators are deciding it’s easier to direct all Internet traffic containing credit card data over SSL.

Requirement 7 (logical access) showed a slight improvement, which could mean more strict attention is being paid to who is given access to cardholder data.

Requirements 3 (stored data) and 11 (regular testing) are once again in the bottom tier, while Requirement 12 (security policies) ousted 10 (tracking and monitoring) from the bottom. This suggests that the encryption of data at rest continues to be a major headache for organizations, especially the more detailed portions, such as annual key rotations.

Requirement 11’s low showing reminds us why ‘set and forget is a very bad bet’ should be a core mantra of the security profession. The fact that security policies rank among the lowest of the low is not a good sign since policy drives practice.

Requirement 1 remains virtually unchanged since last year, at 44% compliance, compared to the 46% in the last report. Only 63% of companies met Requirement 1.1.5 regularly

Compliance is the continuous state of adhering to the regulatory standard. In the case of the PCI DSS there are daily (log review), weekly (file integrity monitoring), quarterly (vulnerability scanning), and annual (penetration testing) activities that an organization must perform in order to maintain this continuous state of compliance

The entire report can be found on the Verizon web site here.

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PCI SSC publishes its first set of PCI Point-to-Point Encryption Solution requirements

New requirements focus on hardware-based solutions and support optional scope reduction efforts in a secure, PCI DSS compliant environment

The PCI Security Standards Council (PCI SSC), a global, open industry standards body providing management of the Payment Card Industry Data Security Standard (PCI DSS), PIN Transaction Security (PTS) requirements and the Payment Application Data Security Standard (PA-DSS), today announced availability of the first set of validation requirements of its point-to-point encryption program. The PCI Point-to-Point Encryption Solution Requirements document provides requirements for vendors, assessors and merchants, that wish to build and implement hardware- based point-to-point encryption solutions that support PCI DSS compliance and offer scope reduction for merchants. Hardware-based P2PE solutions utilize secure cryptographic devices for both encryption and decryption including at the point of merchant acceptance for encryption and within Hardware Security Modules (HSMs) for decryption.

The PCI Security Standards Council recognizes the potential for new technologies to reduce scope for PCI DSS assessments and provide new ways of securely handling cardholder data. This new document for vendors, assessors and solution providers that play a role in developing, implementing or assessing products, defines requirements for applicable point-to-point encryption (P2PE) solutions, with the goal of reducing the scope of the PCI DSS assessment for merchants using such solutions. Merchants themselves will also find the document a useful resource for understanding more about P2PE and PCI DSS scope. The new requirements do not supersede the PCI Data Security Standard, nor is a merchant mandated to use P2PE technology.

However, merchants interested in this technology are encouraged to consult with the Council’s listing of validated P2PE solutions, targeted for spring 2012, to choose a secure solution that will support compliance with PCI Standards. The new requirements document includes information on:

  • Roles and responsibilities in validating, implementing and assessing hardware based P2PE solutions
  • Six critical domains of hardware-based P2PE that cover; the encryption device and environment, application security, transmission, decryption and key management.
  • Steps required to create and validate a P2PE solution
  • Visual representations of a typical implementation
  • Interrelation between P2PE validation requirements and other PCI Standards such as PTS Point of Interaction (POI), PCI PIN, PA-DSS and PCI DSS

The hardware-based requirements incorporate many requirements and principles covering both physical and logical security that will be familiar to users of other PCI Standards. Requirements focus on securing systems and devices, implementing monitoring and response processes, developing and maintaining secure applications, protecting sensitive data, and using secure cryptographic key management methodologies.

“This is a solid first step in recognizing one popular type of deployment of P2PE solutions,” said Bob Russo, general manager, PCI Security Standards Council. “These P2PE requirements will help vendors, assessors, and merchants that are choosing to use hardware-based versions technology, to build, assess and implement P2PE solutions securely. If implemented in accordance with PCI requirements, P2PE solutions can significantly reduce a merchant’s card data environment, mitigate potential breaches and simplify PCI DSS validation efforts.”

Following the release of this first document the Council will introduce the associated testing procedures before the end of 2011. In addition, the Council will detail training opportunities for assessors and provide a listing of validated solutions on the PCI SSC website in spring 2012. As recently outlined in our program update, additional phases of the point-to-point encryption program this year will focus on requirements for solutions

that combine hardware based encryption and decryption through secure cryptographic devices, with software that may manage transaction-level cryptographic keys for decryption. The Council will also continue to explore the development of requirements for pure software solutions that encrypt cardholder data at the point of merchant acceptance, and/or decrypt cardholder data at a host system. Pure software solutions may use software to conduct encryption and decryption, performing cryptographic key management of both the master and transaction keys.

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Merchants are more concerned about their brand than PCI fines

Image representing Cybersource as depicted in ...
Image via CrunchBase

A joint CyberSource and Trustwave survey has shown that nearly 70% of Merchants cited the need to “protect the brand” as the primary driver for tightening controls against hackers and other payment security risks.

Only 26 percent said avoiding fines resulting from non-compliance with the Payment Card Industry Data Security Standard (PCI DSS) were the key motivator.

A few highlights from the report include:

  • Brand Protection is Key Driver of Investment: The need to protect the organization’s brand and its revenues was given as the primary driver for investment in payment security.
  • Threat from External and Internal Sources Perceived as Equal: While the successes of external hackers often make headlines, employees can be an equally damaging source of risk. The survey found that organizations perceive the threats from internal and external sources as being nearly equal.
  • Trend Towards Remote Data Storage: With the need to secure payment data and efficiently comply with PCI DSS, organizations are planning to shift their payment data security approach from an on-site strategy to a remote one. Those organizations that had already made the shift reported shorter time-to-compliance and fewer full-time equivalent employees managing payment security.
  • Payment Security Cost and Complexity Expected to Increase: Most survey respondents expect that the technological complexity, cost, and resources required to manage payment security will increase over the next 24 months.

A breach has serious consequences for nearly every division of an eCommerce merchant’s organization,” said Dayna Ford, Senior Director, Product Management at CyberSource. “But by far the most damaging impact is to the company’s brand, affecting revenue, customer loyalty, and even stock valuation. Knowledge of this phenomenon is now widespread, so we’re not surprised at the survey finding that puts brand integrity as the most important rationale for payment security investment.”

In the face of increasing numbers of security breaches and data theft, there’s a real urgency for organizations to deploy powerful and effective security strategies,” said James Paul, Senior Vice President of Global Compliance Services at Trustwave.  “Studies like ‘The Payment Security Practices and Trends Report,’ published today, should help organizations learn best practices and likely costs to attain appropriate levels of security.”

Selected survey findings

  • Data moving out:  Over the next 24 months, an increasing proportion of organizations expect to remove payment data from their environment as a way of reducing security risks.
  • Efficiency improving: Organizations that do not capture, transmit, or store data inside their own network tend to employ fewer personnel, validate PCI DSS compliance more quickly, and operate at a lower overall cost of payment security management.
  • “Data out” merchants spend less on infrastructure: 75 percent of PCI DSS Level 1 merchants  that have removed payment data from their environments spend less than $500,000  on their payment security infrastructure.  Only 60 percent of those that keep data in-house can make that claim.
  • Risk not confined to outsiders:  In one counter-intuitive finding, respondents said they felt the threat of payment data theft from inside employees was about equal to the threat from external hackers.

Read the full report here, registration is required.

Learn more about the Payment Card Industry Data Security Standard (PCI DSS) by visiting my PCI DS Resources page here.

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PCI DSS – updated guidelines for WiFi and new guidance on Bluetooth

wireless tower
Image via Wikipedia

The Wireless Special Interest Group (SIG) PCI Security Standards Council (PCI SSC) have released an Information Supplement for PCI DSS Wireless Guidelines.

The update updates the PCI DSS guidance to align to version 2 of the PCI Data Security Standard and incorporates guidance for Bluetooth.

All Merchants and Credit Card processors should read the document which can be found here.

The three main sections in the Information Supplement are:

  1. Wireless Guidance Overview
  2. Generally Applicable Wireless Requirements
  3. Applicable Requirements for In-scope Wireless Networks

For further information on the PCI Data Security Standard visit the PCI Resources page on my blog here.

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PCI Security Standards Council Exceeds 100 Members in Europe

Credit card
Image via Wikipedia

In advance of annual PCI Community Meeting, Council celebrates more than 100 European companies as key contributors to the ongoing development of the PCI Standards.

The PCI Security Standards Council (PCI SSC), a global, open industry standards body providing management of the Payment Card Industry Data Security Standard (PCI DSS), PIN Transaction Security (PTS) requirements and the Payment Application Data Security Standard (PA-DSS), today announced a milestone in ongoing momentum and global participation – more than 100 European companies are now PCI Participating Organizations, promising a strong showing for this year’s PCI European Community Meeting on October 17-19, 2011, in London, England.

The Council is made up of more than 600 global Participating Organizations (POs) worldwide. Continual global involvement not only benefits stakeholder organizations but also the larger payment security community, by ensuring the diverse and unique industry and geographic perspectives of those across the payment chain are represented in the work of the Council.

European participation – including merchants, financial institutions and processors from around the continent – has been a key factor in the Council’s analysis and guidance on technologies in the payment environment, such as call center recording technologies and EMV, as well as the development of critical resources like the Prioritized Approach framework.

This year, Participating Organizations also elected a new Board of Advisors, with 7 of the 21 seats being represented by European companies, a testimony to the growing European involvement in the Council and the work and collaboration that is taking place in Europe to drive payment security forward.

”As a member of the Council since 2007, we are pleased to see the growing awareness around payment security in the UK and European regions over the last few years,” said PCI SSC Board of Advisors member Philip Morton, information security compliance manager, British Airways. “We are excited to bring our geographic and industry perspectives to the Council in serving on the Board this term and working with the PCI community to continue to drive increased protection of cardholder data in Europe and globally.”

Twenty-five percent of the growth among European POs has occurred in the last year, since the Council brought on European Director Jeremy King to concentrate PCI efforts in the region. This number has more than tripled since the first year of the Council’s existence.

“Counter to those who suggested that the issue of PCI Standards and global card security were U.S. centric initiatives, our ongoing growth in participation in Europe illustrates the increase in awareness, focus and feedback we are achieving globally,” said Jeremy King, European director, PCI Security Standards Council. “I am very excited about the growing number of European-based organizations who will join us at this year’s European Community Meeting. As we kick off our feedback period for the PCI Standards, I look forward to engaging this core group of stakeholders in our global standards lifecycle process. Together, these organizations will help influence the Council’s agenda and the direction and evolution of the PCI Standards in the coming years.”

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Exactly how many Merchants are PCI DSS compliant?

Credit cards
Image via Wikipedia

The number of Merchants who are compliant to the Payment Card Industry Data Security Standard (PCI DSS) vary from continent to continent, country to country but the figures released by VISA for the US make interesting reading.

The table below shows the results for the US up to the 30th June 2011 as per the VISA.com website.

Cardholder Information Security Programme (CISP) Category (Visa Transactions per year) Estimated Population Size Estimated % of
Visa Transactions
PCI DSS
Compliance Validated
Validated Not  storing Prohibited Data
Level 1   Merchant (>6M) 377 50% 97% 100%
Level 2 Merchant (1-6M) 881 13% 96% 100%
Level 3 Merchant (e-commerce only 20,000-1M) 3,024 <5% 60% N/A
Level 4 Merchant (<1M) ~5,000,000 32% Moderate * TBD
VisaNet Processor (Direct Connection) 62 100% 94% High
Agent (Downstream) 1,262 N/A 83% High

*Level 4 compliance is moderate among stand-alone terminal merchants, but lower among merchants using integrated payment applications

Since the PCI DSS standard was released and enforced the Level 1 Merchants has been the main focus of the Card Issuing companies and of course, the QSAs because, as the table above shows, they represent the largest percentage of transactions for a single group and are a small enough number to easily manage. This focus is why Visa can report a near 100% validation rate for Level 1 Merchants.

The largest risk group by number of business are the Level 4 Merchants with over 5,000,000 in the US alone.

Level 4 Merchants have not yet achieved a % on the Visa chart. This is probably because they do not need to have their Self Assessment Questionnaire (SAQ) validated by and external party e.g. a QSA, except in rare circumstances. Reliance on the Merchants ability to understand the requirements of PCI DSS and to be able to put in place the processes, policies and protections required to protect Credit Card Data requires a lot of “faith” by Visa.

The majority of credit card breaches happen in Level 4 Merchants, e.g. restaurants and hotels, which is why Visa is pushing EMV on a world-wide basis.

All in all it looks like the majority of Merchants are PCI DSS compliant, which means the programme is doing some good…

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Good news for Merchants as the PCI Security Standards Council releases Tokenization guidance

Information Security Wordle: PCI Data Security...
Image by purpleslog via Flickr

On August the 12th The Payment Card Industry Security Standards Council (PCI SSC) published guidelines to help Merchants and credit card processors take advantage of “Tokenization“.

The PCI SSC definition of Tokenization:  “Tokenization technology replaces a Primary Account Number (PAN) with a surrogate value called a “token”. Specific to PCI DSS, this involves substituting sensitive PAN values with non-sensitive token values, meaning a properly implemented Tokenization solution can reduce or remove the need for a merchant to retain PAN in their environment once the initial transaction has been processed.

Merchants are ultimately responsible for the proper implementation of any Tokenization solution they use, including its deployment and operation, and validation of its Tokenization environment as part of their annual Payment Card Industry Data Security Standard (PCI DSS) compliance assessment.

Organizations should carefully evaluate any solution before implementation to fully understand the potential impact to their CDE (Cardholder Data Environment). The paper helps guide merchants through this process by:

  • Outlining explicit scoping elements for consideration
  • Providing recommendations on scope reduction, the tokenization process itself, deployment and operation factors
  • Detailing best practices for selecting a tokenization solution Defining the domains, or areas that specific controls need to be applied and validated, where tokenization could potentially minimize the card data environment

This additional guidance also benefits tokenization service providers and assessors by informing them on how the technology can help their merchant customers limit or eliminate system components that process, store, or transmit Cardholder data, and reduce the scope of the CDE and thus the scope of a PCI DSS assessment.

“We’ve continued the process to investigate these technologies and ways that the community can use them to potentially increase the security of their PCI DSS efforts” said Bob Russo, general manager of the PCI Security Standards Council. “These specific guidelines provide a starting point for merchants when considering tokenization implementations. The Council will continue to evaluate tokenization and other technologies to determine the need for further guidance and/or requirements.”

Jeremy King, European director of the PCI SSC, said the process is challenging because not all cards have a 16-digit primary account number (PAN). Some Tokenization methods are more applicable than others according to the card in question. Some tokens try to preserve the format of the original PAN in order to maintain compatibility with internal processing applications, while other approaches may generate a new truncated or randomised number, King said.

Systems that allow you to get back to the PAN need to be properly protected, and are in scope,” King said.

Tokenisation can have a dramatic reduction on the requirements of PCI DSS. In simple terms if a Merchant has no credit card data stored the scope of PCI DSS is reduced.

For the majority of Merchants reducing the scope of PCI DSS by not storing Credit Card Data can mean the difference between a relatively simple Self Assessment Questionnaire (SAQ) e.g. SAQ A and the highly complex and extremely difficult SAQ D.

The PCI SSC Tokenization Information Supplement can be downloaded here.

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PCI Compliance Cost Calculator for Level 1-4 Retailers

StillSecure have produced the “StillSecure PCI Calculator”, a free online tool designed to help Level 1 though 4 retailers examine, and potentially significantly reduce, the costs and complexities associated with PCI compliance. It is a very interesting approach to calculating the cost of compliance.

From the StillSecure press release:

Gartner issued its Retail Security & Compliance survey 2011, which examined security processes used by organizations subject to PCI, including current level of PCI compliance, spending on PCI compliance, and security threats. Among the key findings, the survey revealed that the costs associated with PCI security and compliance for merchants — excluding the cost of assessors — is an average of $1.7 million over 2.35 years. Over the same time period, Level 1 retailers spent an average of $2.1 million on PCI compliance, with Level 2-4 retailers spending an average of $1.1 million.

Based on the Gartner research StillSecure claim that by using their PCI Complete security solution, Level 1 merchants would save approximately $750,000 by utilizing StillSecure’s solution, and Levels 2-4 would save over $400,000 over the same period.

“Gartner’s Retail Security & Compliance Survey 2011 data clearly shows that organizations are spending significant amounts to become PCI compliant,” said Avivah Litan, VP Distinguished Analyst, Gartner, Inc. “The data further shows that it’s not easy to become compliant and many retailers may be overwhelmed with the complex and numerous steps involved in the process. In fact, security breaches are common. Our assessment underscores the importance of exploring all available options for compliance and security.”

The Gartner report also tracked overall PCI compliance investments and PCI-related security risks. While 28 percent of respondents believed that their organization had to spend too much money to comply with PCI standards, 43 percent of respondents had experienced at least one type of security incident.

“StillSecure has been intensely focused on helping organizations achieve PCI compliance through our fully managed, independently approved solution, PCI Complete,” said Rajat Bhargava, CEO of StillSecure. “These solutions are certified by one of the world’s most stringent qualified security assessors (QSAs) and include PCI monitoring, scanning, as well as reporting and evidence creation capabilities that will save organizations as much as 30 to 50 percent on PCI compliance and auditing. Our PCI Calculator allows organizations to compare their current PCI compliance expenditures with other merchants of similar size, while also informing them on steps to reduce the costs of compliance.”

Download the PCI Calculator for yourself here, registration is required.

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