PCI FAQs & Myths
Myth: I'm a small merchant who only takes a handful of cards, so I don’t need PCI.
FACT: This is a common misunderstanding with the standard, that small merchants handling only one or a few credit cards a year are exempt from compliance. If you are a merchant and are set up to take credit cards by any mechanism – then you need to be compliant.
Myth: PCI only applies to e–commerce companies.
FACT: No, PCI applies to every company that stores, processes or transmits cardholder information. In fact anyone who takes card present transactions that involve POS devices are typically more at risk than e–commerce solutions. Quite often these types of transactions involve storage of track data (which is forbidden under PCI). Compromise of this type of data may bring heavy fines and requests for compensation from the banks involved.
Myth: You only have to be PCI compliant with the majority of criteria.
FACT: The pass mark for PCI is 100%, so if you fail even one of the criteria, you are not PCI compliant. The standard is not meant to be something to strive for; it is essentially a floor, a basis for further security measures. Failing to achieve even one of the requirements, is failing to meet a basic standard for handling cardholder information. All companies that routinely handle this type of data should be aiming to exceed the standard. It's just good business.
Myth: I only need to protect my credit card data, not ATM debit card related data.
FACT: Incorrect – both are required. Many debit cards are dual–purpose ‘signature debit’, which can be used on debit and credit card networks. As such, they are covered under PCI and must be protected in the same way as credit cards.
Myth: I can wait until my business grows.
FACT: Incorrect – the PCI standard applies to all sizes of business and waiting could be costly. Should you be compromised and not be PCI compliant, the fines and the compensation requirements by the banks (it typically costs between $50 and $90 to replace one card) could be substantial.
Myth: I can just answer ‘yes’ to all the criteria on the Self–Assessment Questionnaire (SAQ).
FACT: The Self-Assessment Questionnaire (SAQ) is a mechanism for getting the information about the level of your compliance to your merchant bank. The standard applies at all times. Just saying yes to the questions puts you at great risk. If a compromise took place and it was obvious that you were not and have never been PCI compliant, the matter would be taken very seriously. You would be risking your whole business by answering ‘yes’ to the questions, when there is no factual basis for the answers.
Myth: I can wait until my bank asks me to be PCI compliant.
FACT: The dates for merchants to be PCI compliant are long gone. You are responsible for making sure you are in compliance. Waiting until the bank asks you could be very costly indeed.
Myth: As a merchant, I did not sign anything saying I would be compliant; therefore, I don't need to be.
FACT: The PCI standard forms part of the operating regulations that are the rules under which merchants are allowed to operate merchant accounts. The regulations signed when you open an account at the bank state that the VISA regulations have to be adhered to. Even if you have been in business for decades, PCI still applies if you store, process or transmit credit cards.
Myth: As a merchant, I'm entitled to store any data.
Myth: One vendor and product will make us compliant.
FACT: Many vendors offer an array of software and services for PCI compliance. No single vendor or product, however, fully addresses all 12 requirements of PCI DSS. When marketing focuses on one product's capabilities and excludes positioning these with other requirements of PCI DSS, the resulting perception of a ‘silver bullet’ might lead some to believe that the point product provides ‘compliance’, when it's really implementing just one or a few pieces of the standard. The PCI Security Standards Council urges merchants and processors to avoid focusing on point products for PCI security and compliance. Instead of relying on a single product or vendor, you should implement a holistic security strategy that focuses on the ‘big picture’ related to the intent of PCI DSS requirements.
Myth: Outsourcing card processing makes us compliant.
FACT: Outsourcing simplifies payment card processing but does not provide automatic compliance. Don't forget to address policies and procedures for cardholder transactions and data processing. Your business must protect cardholder data when you receive it, and process charge backs and refunds. You must also ensure that providers' applications and card payment terminals comply with respective PCI standards and do not store sensitive cardholder data. You should request a certificate of compliance annually from providers
Myth: PCI compliance is an IT project.
FACT: The IT staff implements technical and operational aspects of PCI–related systems, but compliance to the payment brand’s programs is much more than a ‘project’ with a beginning and end – it's an ongoing process of assessment, remediation and reporting. PCI compliance is a business issue that is best addressed by a multi–disciplinary team. The risks of compromise are financial and reputational, so they affect the whole organization. Be sure your business addresses policies and procedures as they apply to the entire card payment acceptance and processing
Myth: PCI will make us secure.
FACT: Successful completion of a system scan or assessment for PCI is but a snapshot in time. Security exploits are non–stop and get stronger every day, which is why PCI compliance efforts must be a continuous process of assessment and remediation to ensure safety of cardholder data.
Myth: PCI is unreasonable; it requires too much.
FACT: Most aspects of the PCI DSS are already a common best practice for security. The standard also permits the option using compensating controls to meet some requirements. The standard provides significant detail, which benefits merchants and processors by not leaving them to wonder, ‘Where do I go from here?’ This scope and flexibility leads some to view PCI DSS as an effective standard for securing all sensitive information.
Myth: PCI requires us to hire a Qualified Security Assessor (QSA).
FACT: Because most large merchants have complex IT environments, many hire a QSA to glean their specialized value for on’site security assessments required by PCI DSS. The QSA also makes it easier to develop and get approval for a compensating control. However, PCI DSS provides the option of doing an internal assessment with an officer sign’off if your credit card processor (acquirer) and/or merchant bank agrees. Mid’sized and smaller merchants may use the Self’Assessment Questionnaire (SAQ) found on the PCI SSC Website to assess themselves.
Myth: PCI makes us store cardholder data.
FACT: Both PCI DSS and the payment card brands strongly discourage storage of cardholder data by merchants and processors. There is no need, nor is it allowed, to store data from the magnetic stripe on the back of a payment card. If merchants or processors have a business reason to store front–card information, such as name and account number, PCI DSS requires this data to be encrypted or made otherwise unreadable.
Myth: PCI is too hard
Q: What is PCI?
A: The Payment Card Industry Data Security Standard (PCI DSS) is a set of requirements designed to ensure that ALL companies that process, store or transmit credit card information maintain a secure environment. Essentially any merchant that has a Merchant ID (MID).
The Payment Card Industry Security Standards Council (PCI SSC) was launched on September 7, 2006 to manage the ongoing evolution of the Payment Card Industry (PCI) security standards with focus on improving payment account security throughout the transaction process. The PCI DSS is administered and managed by the PCI SSC (www.pcisecuritystandards.org), an independent body that was created by the major payment card brands (Visa, MasterCard, American Express, Discover and JCB.).
It is important to note, the payment brands and credit card processors (acquirers) are responsible for enforcing compliance, not the PCI council.
A copy of the PCI DSS is available here.
Q: To whom does PCI apply?
A: PCI applies to ALL organizations or merchants, regardless of size or number of transactions, that accepts, transmits or stores any cardholder data. Said another way, if any customer of that organization ever pays the merchant directly using a credit card or debit card, then the PCI DSS requirements apply.
Q: Where can I find the PCI Data Security Standards (PCI DSS)?
A: The Standard can be found on the PCI SSC's Website:https://www.pcisecuritystandards.org/security_standards/pa_dss.shtml
Q: What are the PCI compliance deadlines?
A: All merchants that stores, processes or transmits cardholder data must be compliant now. However, as a Level 4 merchant, you will have to refer to your merchant bank for their specific validation requirements and deadlines. All deadline enforcement will come from your merchant bank. You may also find more information on Visa's Website:http://usa.visa.com/download/merchants/payment_application_security_mandates.pdf.
Q: What are the PCI compliance 'levels' and how are they determined?
A: All merchants will fall into one of the four merchant levels based on Visa transaction volume over a 12–month period. Transaction volume is based on the aggregate number of Visa transactions (inclusive of credit, debit and prepaid) from a merchant Doing Business As ('DBA'). In cases where a merchant corporation has more than one DBA, Visa credit card processors (acquirers) must consider the aggregate volume of transactions stored, processed or transmitted by the corporate entity to determine the validation level. If data is not aggregated, such that the corporate entity does not store, process or transmit cardholder data on behalf of multiple DBAs, credit card processors (acquirers) will continue to consider the DBA's individual transaction volume to determine the validation level.
Q: What does a small–to–medium sized business (Level 4 merchant) have to do in order to satisfy the PCI requirements?
Q: If I only accept credit cards over the phone, does PCI still apply to me?
A: Yes. All business that store, process or transmit payment cardholder data must be PCI Compliant.
Q: Do organizations using third–party processors have to be PCI compliant?
A: Yes. Merely using a third–party company does not exclude a company from PCI compliance. It may cut down on their risk exposure and consequently reduce the effort to validate compliance. However, it does not mean they can ignore PCI.
Q: My business has multiple locations, is each location required to validate PCI Compliance?
A: This is determined by your acquiring bank. However, if your business locations process under the same Tax ID, then typically you are only required to validate once annually for all locations. And, submit quarterly passing network scans by an PCI SSC Approved Scanning Vendor (ASV), if applicable.
Q: Are debit card transactions in scope for PCI?
A: In–scope cards include any debit, credit, and pre–paid cards branded with one of the five card association/brand logos that participate in the PCI SSC – American Express, Discover, JCB, MasterCard, and Visa International.
Q: Am I PCI compliant if I have an SSL certificate?
Q: What are the penalties for noncompliance?
Q: What is defined as 'cardholder data'?
A: Cardholder data is any personally identifiable data associated with a cardholder. This could be an account number, expiration date, name, address, social security number, etc. All personally identifiable information associated with the cardholder that is stored, processed, or transmitted is also considered cardholder data.
Q: What is the definition of 'merchant'?
Q: What constitutes a Service Provider?
A: Any company that stores, processes, or transmits cardholder data on behalf of another entity is defined to be a Service Provider by the Payment Card Industry (PCI) guidelines.
Q: What is a payment gateway?
A: Payment Gateways connect a merchant to the bank or processor that is acting as the front-end connection to the Card Brands. They are called gateways because they take many inputs from a variety of different applications and route those inputs to the appropriate bank or processor. Gateways communicate with the bank or processor using dial-up connections, Web-based connections or privately held leased lines.
Q: How is IP–based POS environment defined?
A: The point of sale (POS) environment refers to a transaction that takes place at a merchant location (i.e. retail store, restaurant, hotel, gas station, convenience store, etc.). An Internet protocol (IP)–based POS is when transactions are stored, processed, or transmitted on IP–based systems or systems communicating via TCP/IP.
Q: What is PA–DSS and PABP?
Q: Can the full credit card number be printed on the consumer's copy of the receipt?
A: PCI DSS requirement 3.3 states “Mask PAN when displayed (the first six and last four digits are the maximum number of digits to be displayed).” While the requirement does not prohibit printing of the full card number or expiry date on receipts (either the merchant copy or the consumer copy), please note that PCI DSS does not override any other laws that legislate what can be printed on receipts (such as the U.S. Fair and Accurate Credit Transactions Act (FACTA) or any other applicable laws). See the italicized note under PCI DSS requirement 3.3 “Note: This requirement does not apply to employees and other parties with a specific need to see the full PAN, nor does the requirement supersede stricter requirements in place for displays of cardholder data (for example, for point of sale (POS) receipts).” Any paper receipts stored by merchants must adhere to the PCI DSS, especially requirement 9 regarding physical security.
Q: Do I need vulnerability scanning to validate compliance?
A: If you electronically store cardholder data post authorization or if your processing systems have any internet connectivity, a quarterly scan by a PCI SSC Approved Scanning Vendor (ASV) is required.
Q: What is a network security scan?
A: A network security scan involves an automated tool that checks a merchant or service provider's systems for vulnerabilities. The tool will conduct a non–intrusive scan to remotely review networks and Web applications based on the external–facing Internet protocol (IP) addresses provided by the merchant or service provider. The scan will identify vulnerabilities in operating systems, services, and devices that could be used by hackers to target the company's private network. As provided by an Approved Scanning Vendors (ASV's) such as ServerScan the tool will not require the merchant or service provider to install any software on their systems, and no denial–of–service attacks will be performed.
Note, typically only merchants with external facing IP address are required to have passing quarterly scans to validate PCI compliance. This is usually merchants completing the SAQ C or D version.
Q: How often do I have to scan?
A: Every 90 days/once per quarter you are required to submit a passing scan. Merchants and service providers should submit compliance documentation (successful scan reports) according to the timetable determined by their credit card processor (acquirer). Scans must be conducted by a PCI SSC Approved Scanning Vendor (ASV). ServerScan is a PCI Approved Scanning Vendor.
Q: How do I configure my IPS to allow the scans?
Q: What if a merchant refuses to cooperate?
A: PCI is not, in itself, a law. The standard was created by the major card brands such as Visa, MasterCard, Discover, AMEX, and JCB. At their credit card processors (acquirers) discretion, merchants that do not comply with PCI DSS may be subject to fines, card replacement costs, costly forensic audits, brand damage, etc., should a breach event occur.
Q: If I'm running a business from my home, am I a serious target for hackers?
A: Yes, home users are arguably the most vulnerable simply because they are usually not well protected. Adopting a ‘path of least resistance’ model, intruders will often zero-in on home users – often exploiting their ‘always on’ broadband connections and typical home use programs such as chat, Internet games and P2P files sharing applications. BASIC-TDC's scanning service allows home users and network administrators alike to identify and fix any security vulnerabilities on their desktop or laptop computers.
Q: What should I do if I'm compromised?
Q: Do states have laws that requiring data breach notifications to the affected parties?
A: Absolutely. California is the catalyst for reporting data breaches to affected parties. The state implemented breach notification law in 2003 and there are now over 38 states that have similar laws in place. See www.privacyrights.org for more detail on state laws.
Q: Who establishes the scanning requirements?
A: The PCI Security Standards Council (PCI SSC) is an organization formed by American Express, Discover, JCB, MasterCard Worldwide and Visa, Inc. It manages the Approved Scanning Vendor (ASV) program and develops the scanning requirements.
Q: What is an Approved Scanning Vendor (ASV)?
A: An Approved Scanning Vendor (ASV) is a company that has passed rigorous testing requirements set forth by the PCI Security Standards Council. Only Approved Scanning Vendors can fulfill requirement 11.2 (external vulnerability scanning on a quarterly basis) of the Payment Card Industry Data Security Standard (PCI DSS).
Q: Where can I go to learn more about the PCI Approved Scanning Vendor (ASV) scanning requirements?
A: You can find more information on the PCI Security Standards Council's (PCI SSC) website or by clicking ASV Program Guide.
Q: Why do I need a vulnerability scan?
A: Per PCI guidelines, if you have external–facing IP address(es) that are connected to your cardholder data environment, then you require a quarterly vulnerability scan by an Approved Scanning Vendor. Typically, these are merchants that complete Self Assessment Questionnaire (SAQ) C or D.
Q: How does your scanning service help protect me?
A: Scanning is designed to find threats and configurations that may cause your environment to be vulnerable to external attacks. Any threats identified are also accessible to those with malicious intent. Scanning provides you with as much information as possible to secure yourself against potential breaches or loss of data.
Q: How does scanning relate to my Self Assessment Questionnaire (SAQ)?
A: Scanning is typically required for any merchant that has external–facing IP address(es) connected to their cardholder data environment. Typically, these are merchants that complete Self Assessment Questionnaire (SAQ) C or D
Q: Who is responsible for determining the scope of my quarterly scan?
A: It is ultimately up to you to confirm the scope of your cardholder data environment for PCI compliance. BASIC-TDC Support can provide guidance, and our partner ASV ServerScan, is responsible for reporting any scoping discrepancies between the information you provide and the information found in your environment. See the ASV Program Guide for more information on this topic.
Q: What do I scan?
In addition to providing all external–facing IP addresses, the scan customer must also supply all fully qualified domain names (FQDN) and other unique entryways into applications for the entire in–scope infrastructure. This includes, but is not limited to:
Q: What does the scan do?
A: The scan first examines the targets you have specified for ports that are open to Internet traffic. It then looks within open ports for evidence of vulnerable applications and configurations within your environment. Examples include: outdated versions of software, Web applications that are not securely coded or misconfigured networks.
Q: What is a threat (a.k.a. vulnerability)?
A: A threat, or vulnerability, is an identified security issue within your environment that is encountered during the scanning process. A threat can be “confirmed” (there is clear evidence that it exists) or “inferred” (patterns suggest that a problem may exist, but it cannot be determined with certainty). The ASV Program Guide requires your ASV to score and report both types of threats.
Q: What criteria are used to determine if my scan report is passing or failing?
A: Threats identified are scored using a standard Common Vulnerability Scoring System (CVSS) numeric rating – a global standard for reporting threat risk levels. The standard is based on a 0 through 10 scale, and any threat that has a CVSS base score of 4.0 or higher will fail. These scores are translated into a “risk rating” within the report ranging from 0 to 5, such that failing threats have a risk rating of 3 or higher.
Q: What is the difference between a “compliant” and “passing” scan status?
A: A passing scan status represents a completed scan without any failing vulnerabilities (those with a risk rating of 3 or higher). A compliant scan is a passing scan that has been attested to by both the merchant and the ASV. To remain in compliance with the PCI scanning requirement, a compliant scan must be achieved on a quarterly basis.
Q: Will BASIC-TDC help me understand the scan results?
A: Yes, BASIC-TDC Support is available to review the scan results with you and will attempt to answer any questions that you may have.
Q: Does the scan report contain guidance on how to resolve vulnerability findings?
A: The scan report will provide suggested remediation guidance for vulnerabilities that are listed with a risk rating of 3 or highe
Q: Will BASIC-TDC help me fix the vulnerabilities found in the ASV scan?
A: Yes, BASIC-TDC Support will provide guidance and perform the remediation tasks.
Q: What is a false positive?
A: A false positive is a threat flagged during the scan as a potential security risk that you subsequently disprove. When you dispute such threats, they are marked as false positives in the scan results.
Q: Will the scan affect my Website or POS system?
A: The scan is designed to be non-intrusive and should not disrupt a Website or POS system.
Q: What's an IP?
A: An Internet Protocol (or IP address) is a numerical label that is assigned to devices in a network (like the Internet) so that they can be identified and communicated with.
Q: What's a domain?
A: A domain is a collection of related Web pages, images, videos or other digital pieces that can be addressed using a URL. An example of a URL is www.basic-tdc.com
Q: How does an IP address relate to a domain?
A: The domain name (or “www” URL) corresponds to a specific IP address. The advantage of a domain name is that it is always the same – even if the IP address it points to is dynamic and keeps changing.
Q: What is the difference between a static and dynamic IP address?
A: A static IP address stays permanently assigned to the same computer or device, while a dynamic IP address changes periodically. The type of IP address you have depends on the type of service you have with your Internet Service Provider (ISP). Most IP addresses are dynamic – the number of addresses available is limited and ISPs charge more for a static IP address.
Q: How do I find out if my IP address is static or dynamic?
A: If unsure about whether your IP address is static or dynamic, it is best to contact your Internet Service Provider, and they can inform you of the nature of the connection.
Q: What do I do after I achieve a compliant quarterly scan?
A: Once you achieve a compliant scan, verify that there is a compliant SAQ on file for your account so that you can achieve full PCI Compliance for the quarter. Complete information on your compliance status can be reviewed on the main page of your myControlScan portal.
Q: Why is there a Special Note in my attestation?
A: A special note will be included in your attestation if a condition has been encountered that could represent a security risk. It is not sufficient to prevent compliance, but warrants your attention.
Q: How long does a scan take?
A: The length of your scan depends on a number of factors, including the number of probes that are concurrently assessing your target, the number of ports open to Internet traffic, and the breadth and depth of your site. An average scan takes approximately 1–6 hours.
Q: What is the merchant attestation requirement?
A: You must attest to the proper scope of the scan, any special notes found during the scan and that you understand your responsibility as a scan merchant.