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What is in scope for PCI compliance on this network?

Posted on 2014-11-15
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Last Modified: 2015-01-06
I have a network that I am working on and it is shown below:


[Credit Card Machine]----------------Private dedicated fiber line---------[Server]---------[FW]--------[Cable Modem]

The fiber is dedicated and is connected to the server that hosts a VMware vm that the third party payment processor gave us. From this server it is connected to a Linksys router/FW and out to the internet.  What is exactly in scope here for PCI compliance?  I don't believe we are storing any credit card information on the server but I am not certain since I just started work on this.

Also what other options exists for getting the data to the third party processor as we are looking to eliminate the fiber line and the server?

Thanks
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Question by:wayy2be
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btan earned 500 total points
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PCI scope applies to all entities that store, process or transmit cardholder data (CD). If you reference the PCI reference, the main area to note include avoiding cardholder data ever be stored unless it’s necessary, this include sensitive data on the magnetic stripe or chip must never be stored. in short, any sensitive details that can represent the customer must be safeguarded and unreadable unless it is being authorised and authenticated accordingly. Good to check out the FAQ https://www.pcicomplianceguide.org/pci-faqs-2/#8

Noting that, looking at the diagram (which is pretty common CD environment, CDA), the CC machine is the source and all info need to be encrypted at rest, and in transit to different pt in the transaction towards the 3rd party processor system, it need to be encrypted as well to detect tamper and assure data confidentiality and integrity. The CC machine, Server and FW/Modem is under check scope which include its hardening and regular security scan aspect. It is best you check out the  Self-Assessment Questionnaire (SAQ) which is a series of yes-or-no questions from PCI-DSS to guide compliance state and state the remediation in place for any "no". Eventually the Qualified Security Assessor (QSA) and Approved Scanning Vendor (ASV) will be the recognised personnel to assess the whole CDE. See this ref guide.

https://www.pcisecuritystandards.org/documents/PCI%20SSC%20Quick%20Reference%20Guide.pdf

For the reducing of scoping, I will say if we can limit the credit card details on its traversing and storage pt it will help. And also avoid external entity to remote access or external network (unless trusted and authorised) to be connected to this infra. This is commonly relooking into network segmentation. This link also help to calrify understanding on if encrypted data implemented means it is out of scope http://pciguru.wordpress.com/2013/03/07/encrypted-cardholder-data-out-of-scope/
..The only way encrypted cardholder data (CHD) is out of scope is if the entity being assessed for PCI compliance cannot decrypt the encrypted CHD...
..Where stored encrypted CHD is out of scope is when a third party controls the encryption keys.  This most often occurs with tokenization...
..what happens to the users and devices in between the two encryption endpoints on an encrypted communication link?  They are out of scope as long as they do not have the ability to decrypt the data stream.
..The bottom line in all of this is; if your organization has the ability to decrypt either the stored CHD or transmissions of CHD, then you are in-scope for PCI compliance...
..just because something is out of scope it does not mean that it does not need to be assessed.  It is always necessary for a certain amount of testing procedures to be conducted to determine that the item is out of scope
Some upcoming scheme include tokenisation (also mentioned in above) which is using some ref# to "map" the CD so that instead of CD, this ref# is used and compromising that should not affect the CD at all. Having said that the tokenisation systems are within the scope of PCI so it is a balance hence not a big take up rate yet . You can check out http://resources.infosecinstitute.com/want-limit-pci-dss-scope-use-tokenization/
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