Educause Security Discussion mailing list archives
Re: PCI - Third party vendors
From: "Aube, Jane M." <jaube () MIDDLEBURY EDU>
Date: Fri, 25 Jul 2014 21:13:17 +0000
Blake, I would agree with your conclusion. Our QSA firm has provided us with the same information as you imparted below (and for those wondering, it is not TrustWave). It seems with V3.0 the significance of the Merchant Account holder may not be the determining factor and more emphasis seems to be put on the components and services that could impact cardholder data. It will be interesting to see how different QSA firms interpret Third Party Vendors that hold the merchant account, but are providing a service for an institution—examples; transcripts, tuition payments etc. The third party vendor is the Merchant of Record, however, they are not only a Merchant but are a Service Provider as well. Hence, should be providing the institution with an SAQ D AOC for Service Providers or an On-Site Assessment AOC for Service Providers, not an SAQ A. Requirement 12 required Service Provider Due Diligence, interesting times ahead. I would note that three states; Washington, Nevada and Minnesota, have incorporated PCI DSS, or portions thereof, into law. Craig, I would suggest analog or cellular swipe terminals. Best regards, Jane Jane Aube | Gift Administration Technical Systems Administrator, College Advancement | Middlebury College | 802.443.5790 From: The EDUCAUSE Security Constituent Group Listserv [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Blake Penn Sent: Friday, July 25, 2014 1:25 PM To: SECURITY () LISTSERV EDUCAUSE EDU Subject: Re: [SECURITY] PCI - Third party vendors Mike, I’m not sure that we actually disagree – when I say “compliance requirements” these are in the eyes of the PCI Industrial Complex, not you or your lawyers, or my personal view, etc. – hence the “enforcement” blurb. Just letting you guys know how the “system” views this issue. Blake Penn CISSP, PCIP, MCSE, MCSD, MCDBA, QSA, ISMS Principal Auditor Principal Consultant t: 678.685.1277 Trustwave | SMART SECURITY ON DEMAND www.trustwave.com<http://www.trustwave.com/> DISCLAIMER: The views represented in this message reflect the personal opinions of the author alone and do not neccessarily reflect the opinions of Trustwave. From: The EDUCAUSE Security Constituent Group Listserv [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Mike Chapple Sent: Friday, July 25, 2014 11:25 AM To: SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () LISTSERV EDUCAUSE EDU> Subject: Re: [SECURITY] PCI - Third party vendors Blake, Respectfully, I disagree with the conclusion that you've reached. The important point is that PCI DSS is a contractual obligation, not a law. The only way that you can become subject to a contractual obligation is to voluntarily accept it by signing a contract. If it were true that "Any entity that processes, stores, or transmits CHD must comply with the standard," it would be forcing entities who are not a party to the contract (merchant agreement) to comply with the terms of that agreement. Under this logic, I could take a file of credit card numbers and stick it in Dropbox and that would make Dropbox a service provider subject to PCI DSS. That is not the case, as Dropbox never agreed to handle credit card information for me under the PCI DSS standard. That said, it is clearly the responsibility of the merchant to only use service providers who agree to comply with PCI DSS. The contracts they have with those service providers should include language to that effect, thereby transferring some compliance obligations. Absent that language, it is the responsibility of the merchant to not use that particular service to transmit unencrypted CHD. Just my two cents. I'm not a lawyer :) Mike On Fri, Jul 25, 2014 at 10:54 AM, Blake Penn <BPenn () trustwave com<mailto:BPenn () trustwave com>> wrote: Craig, The fact that they are an external entity does not obviate your PCI DSS compliance. Any entity that processes, stores, or transmits CHD must comply with the standard. The nuance here is that you don’t have an associated MID (since they are a third party) and therefore no associated acquirer relationship/contractual compliance obligations. This changes your *enforcement/validation* requirements (there are none) but not your actual *compliance* requirements. The way the card schemes see it is that CHD is their data and anyone touching it must comply with the DSS (how they would enforce this view is an entirely different matter). That being said, your QSA should be able to come up with controls that may minimize (or perhaps eliminate) the scope of your compliance burden. The easiest way compliance-wise is to avoid the issue, though. I commonly see clients set up a separate physical network routed out to the ole’ Interwebs through a cheap consumer-grade DSL/Cable connection for guest wireless and other such use. That way the networks never touch (“Don't cross the streams.”) and compliance really doesn’t become an issue. Hope that helps. Do consult with your friendly neighborhood QSA, though, for specific guidance on this issue. Blake Penn CISSP, PCIP, MCSE, MCSD, MCDBA, QSA, ISMS Principal Auditor Principal Consultant t: 678.685.1277<tel:678.685.1277> Trustwave | SMART SECURITY ON DEMAND www.trustwave.com<http://www.trustwave.com/> DISCLAIMER: The views represented in this message reflect the personal opinions of the author alone and do not neccessarily reflect the opinions of Trustwave. From: The EDUCAUSE Security Constituent Group Listserv [mailto:SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () LISTSERV EDUCAUSE EDU>] On Behalf Of Drake, Craig Sent: Thursday, July 24, 2014 4:30 PM To: SECURITY () LISTSERV EDUCAUSE EDU<mailto:SECURITY () LISTSERV EDUCAUSE EDU> Subject: [SECURITY] PCI - Third party vendors We have a new coffee shop going into our library. They are completely run by an external entity not associated with the university. They want to connect their terminals to our university network (possibly wireless) to transmit their credit card transactions. What do we need to be concerned with in terms of PCI compliance with them running this through our networks? Thank you, -Craig Craig Drake University Technology Services Northeastern Illinois University 5500 North St. Louis Avenue, Chicago, IL 60625 Phone: (773) 442-4386<tel:%28773%29%20442-4386> Email: C-Drake () neiu edu<mailto:C-Drake () neiu edu> www.neiu.edu<http://www.neiu.edu> [http://homepages.neiu.edu/~markdep/images/neiu_wordmark_color_email.png] ________________________________ This transmission may contain information that is privileged, confidential, and/or exempt from disclosure under applicable law. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, or use of the information contained herein (including any reliance thereon) is strictly prohibited. If you received this transmission in error, please immediately contact the sender and destroy the material in its entirety, whether in electronic or hard copy format. -- Best regards, Mike Mike Chapple, Ph.D. Senior Director for IT Service Delivery Concurrent Assistant Professor, Management University of Notre Dame 236 IT Center | Notre Dame, IN 46556 P: 574-631-5863 | M: 574-274-0151 mchapple () nd edu<mailto:mchapple () nd edu> ________________________________ This transmission may contain information that is privileged, confidential, and/or exempt from disclosure under applicable law. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution, or use of the information contained herein (including any reliance thereon) is strictly prohibited. If you received this transmission in error, please immediately contact the sender and destroy the material in its entirety, whether in electronic or hard copy format.
Current thread:
- Re: PCI - Third party vendors, (continued)
- Re: PCI - Third party vendors Blake Penn (Jul 25)
- Re: PCI - Third party vendors Mike Chapple (Jul 25)
- Re: PCI - Third party vendors Oscar Knight (Jul 25)
- Re: PCI - Third party vendors Theresa Semmens (Jul 25)
- Re: PCI - Third party vendors Joel L. Rosenblatt (Jul 25)
- Re: PCI - Third party vendors Mike Chapple (Jul 25)
- Re: PCI - Third party vendors David James Anderson (Jul 25)
- Re: PCI - Third party vendors Peter Setlak (Jul 25)
- Re: PCI - Third party vendors Robert Lau (Jul 25)
- Re: PCI - Third party vendors Blake Penn (Jul 25)
- Re: PCI - Third party vendors Aube, Jane M. (Jul 25)