Question

PCI DSS/Legal Requirement Advice

Asked by: psykomotor

A client has enquired about connecting thier management platform (which we constructed) to thier payment handler to automatically handle transactions.

At current no sensitive information is stored in terms of bank/card details - but this will now be required. From a security perspective I have worked on several projects whilst in a different employ and have no problems with the technical aspects.

However, as this is my first project by my own company with these requirements I am not 100% sure on the legal/bureaucratic requirements, and just want to clarify them before taking the project on.

Proposed technical setup (key points, not complete):

- Management system runs on Internal server on clients network. The network has access to the internet.
- Network accesses the internet through hardware firewall.
- Server has additional software firewall.
- Management platform runs as a web application on the server, staff access via a browser on thier terminals (internally, never over the internet). Log-in is required. Users only see minimum necessary detail. Payment details especially limited.
- Card & Senstive details encrypted. Encryption key not stored on server drives.

My key questions:

1. Does the PCI DSS even apply here ? - The wording is vauge and card details are not collected over the internet. However, they will be transmitted via the internet to the payment handler.
2. All the requirements for PCI compliance are actually met. The client will count as a level 4 merchant - If so I presume they will need to do the self assessment questionare and have regular 'security scans' by a third party ? (Again, wording is vauge)
3. Aside from the PCI DSS are there any other mandatory compliance schemes I should be aware of ? (i.e PA-DSS ?)

Thanks in advance. Technical suggestions are always welcome but really i'm trying to get my head round a pile of badly written and vaugue, ambiguous documents which don't clearly lay out my legal obligations.

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Asked On
2009-08-11 at 05:22:00ID24642796
Tags

PCI DSS

,

Direct Debit

,

Card Payment

Topics

Payment Processing Recommendation and Integrating

,

E-Commerce Security

Participating Experts
2
Points
500
Comments
4

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Answers

 

by: hmarePosted on 2009-08-11 at 05:51:02ID: 25068357

Contact the payment handler and the bank. They can tell you if compliance scans are necessary, and sometimes they will even pay for it.

 

by: coreybryantPosted on 2009-08-11 at 14:15:59ID: 25073541

>>2. All the requirements for PCI compliance are actually met. The client will count as a level 4 merchant - If so I presume they will need to do the self assessment questionare and have regular 'security scans' by a third party ? (Again, wording is vauge)<<

Yes, you need to complete the scan / questionnaire. However, Level 4 merchants have no set date to be compliant (Breaking Down the Levels of PCI DSS)- this is set by the merchant account provider. Some providers require their compliance now, while some have not set a date. But to protect yourself, you should be compliant - if a breach happens, the merchant can be fined and placed on the TMF / MATCH list. This could cause problems in getting a merchant account, cause the discount rate to be higher, and require the merchant to have a rolling reserve.

Check out Comodo for some PCI scanning solutions.

 

by: psykomotorPosted on 2009-08-18 at 06:42:15ID: 25123069

Thanks guys - Is there any requirement that me or the client fill out the questionnaire, or is either fine ?

 

by: coreybryantPosted on 2009-08-18 at 07:29:39ID: 25123615

The merchant should complete the questionnaire.  The merchant might need to ask you some of the questions, but the merchant should complete so he understands his responsibilities

If I was the merchant, I would also consider getting the developer to sign a contract stating what questions and the answers the developer provided input  - this might not help the merchant if a breach happens, but it helps to protect him some depending on which questions the developer answers.  Some merchant account providers might take that into consideration when re-evaluating his contract.

Plus it will instill more trust that the merchant has for you.  

20120131-EE-VQP-002

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