Archive for July, 2008

Sample PCI-DSS Policy Part 6: Roles and Responsibilities

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12.2.a Will maintain daily operational security procedures consistent with this the PCI-DSS, including administrative and technical procedures for each of the requirements

(12.5) Chief Security Officer (or equivalent) is responsible for overseeing all aspects of information security, including but not limited to:

  • (12.5.1) creating and distributing security policies and procedures
  • (12.5.2) monitoring and analyzing security alerts and distributing information to appropriate information security and business unit management personnel
  • (12.8.4) monitoring service providers PCI compliance at least annually
  • (12.5.3) (12.9) creating and distributing security incident response and escalation procedures that include:

◦           (12.10.1) roles, responsibilities, and communication

◦           (12.10.1) coverage and responses for all critical system components

◦           (12.10.1) notification, at a minimum, of credit card associations and acquirers

◦           (12.10.1) strategy for business continuity post compromise

◦           (12.10.1) reference or inclusion of incident response procedures from card associations

◦           (12.10.1) analysis of legal requirements for reporting compromises (for example, per California bill 1386)

◦           (12.9.2) annual testing

◦           (12.9.3, 12.9.5) designation of personnel to monitor for intrusion detection, intrusion prevention, and file integrity monitoring alerts on a 24/7 basis

◦           (12.9.4) plans for periodic training

◦           (12.9.6) a process for evolving the incident response plan according to lessons learned and in response to industry developments

  • (12.6; 12.6.1.a) maintaining a formal security awareness program for all employees that provides    multiple methods of communicating awareness and educating employees (for example, posters, letters, meetings)
  • (10.6.a) review security logs at least daily and follow-up on exceptions

(12.2.a) The Information Technology Office (or equivalent) shall maintain daily administrative and technical operational security procedures that are consistent with the PCI-DSS (for example, user account maintenance procedures, and log review procedures).

System and Application Administrators shall

  • Monitor and analyze security alerts and information and distribute to appropriate personnel
  • (12.5.4) administer user accounts and manage authentication
  • (12.5.5) monitor and control all access to data
  • (12.10.1) maintain a list of connected entities
  • (12.10.2) perform due diligence prior to connecting an entity, with supporting documentation
  • (12.10.3, 12.4) verify that the entity is PCI-DSS compliant, with supporting documentation
  • (12.10.4) establish a documented procedure for connecting and disconnecting entities
  • (10.7.a ) retain audit logs for at least one year

The Human Resources Office (or equivalent) is responsible for tracking employee participation in the security awareness program, including:

  • (12.6.1.b) facilitating participation upon hire and at least annually
  • (12.6.2) ensuring that employees acknowledge in writing that they have read and understand the company’s information security policy
  • (12.7) screen potential employees to minimize the risk of attacks from internal sources

Internal Audit (or equivalent) is responsible for executing a (12.1.2) risk assessment process that identifies threats, vulnerabilities, and results in a formal risk assessment.

General Counsel (or equivalent) will ensure that for service providers with whom cardholder information is shared:

  • (12.8.1) contracts require adherence to PCI-DSS by the service provider
  • (12.8.2) contracts include acknowledgement or responsibility for the security of cardholder data by the service provider

Sample PCI-DSS Policy Part 5: Critical Employee-Facing Technologies

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(12.3) For critical employee-facing technologies, departmental procedures shall require:

  • (12.3.1) explicit management approval to use the devices
  • (12.3.2) that all device use is authenticated with username and password or other authentication item (for example, token)
  • (12.3.3) a list of all devices and personnel authorized to use the devices
  • (12.3.4) labeling of devices with owner, contact information, and purpose
  • (12.3.8) automatic disconnect of modem sessions after a specific period of inactivity
  • (12.3.9) activation of remote access technologies used by vendors only when needed by vendors, with immediate deactivation after use

Departmental usage standards shall include:

  • (12.3.5) acceptable uses for the technology
  • (12.3.6) acceptable network locations for the technology
  • (12.3.7) a list of company-approved products
  • (12.3.10) prohibition of the storage of cardholder data onto local hard drives, floppy disks, or other external media when accessing such data remotely via remote access technologies
  • (12.3.10) prohibition of use of cut-and-paste and print functions during remote access

Sample PCI-DSS Policy Part 4: Access to Cardholder Data

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(7.1) Procedures for data control must be maintained by each department and must incorporate the following:

  • Access rights to privileged User IDs are restricted to least privileges necessary to perform job responsibilities
  • Assignment of privileges is based on individual personnel’s job classification and function
  • Requirement for an authorization form signed by management that specifies required privileges
  • Define access needs and privileges for each job role.
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Sample PCI-DSS Policy Part 3: Handling of Cardholder Data

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(9.7) Distribution, maintenance, and storage of media containing cardholder data, must be controlled, including that distributed to individuals.  Procedures must include periodic media inventories in order to validate the effectiveness of these controls. (9.9) listings of devices must be maintained along with periodic inspections of devices for signs of tampering.  Training mechanisms must be place to alert staff when device tampering is evident.

(3.1) Procedures for data retention and disposal must be maintained by each department and must include the following:

  • legal, regulatory, and business requirements for data retention, including specific requirements for retention of cardholder data
  • provisions for disposal of data when no longer needed for legal, regulatory, or business reasons, including disposal of cardholder data
  • a programmatic (automatic) process to remove, at least on a quarterly basis, stored cardholder data that exceeds business retention requirements, or, alternatively, an audit process, conducted at least on a quarterly basis, to verify that stored cardholder data does not exceed business retention requirements
  • (9.8) destruction of media when it is no longer needed for business or legal reasons as follows:

◦           cross-cut shred, incinerate, or pulp hardcopy materials

◦           purge, degauss, shred, or otherwise destroy electronic media such that data cannot be reconstructed

[If records management is a centralized function, you may choose to offload the above section to a data retention standard and/or procedure, and then reference that procedure in the policy.]

(3.3) Credit card numbers must be masked when displaying cardholder data.  Those with a need to see full credit card numbers must request an exception to this policy using the exception process.

(4.2) Unencrypted Primary Account Numbers may not be sent via email, instant messaging, SMS, chat. Etc.

Sample PCI-DSS Policy Part 2: Adherence to Standards

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(2.2.a) Configuration standards must be maintained for applications, network components, critical servers, and wireless access points.  These standards must be consistent with industry-accepted hardening standards as defined, for example, by SysAdmin Assessment Network Security Network (SANS), National Institute of Standards Technology (NIST),  International Organization for Standardization (ISO), and Center for Internet Security (CIS).  [2.2.b should be captured in your system configuration standard; 2.2.c and 2.2.3.b should be covered in your procedure for new server set-up]

Configuration standards must include:

  • (5.2) updating of anti-virus software and definitions, perfom periodic scans, and generate audit logs
  • (6.1.a) identify new security vulnerabilities and assigns risking rankings that identifies all “high risk” and “critical” vulnerabilities based on reputable outside sources.
  • (6.2.a) provision for installation of all relevant new security patches within 30 days, and all vendor supplied security patches within an appropriate time frame.
  • (8.6.a) authentication mechanisms are assigned to individual accounts and are not shared, and physical and/or logical controls ensure only the attend account can gain access.

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