Information security officers for credit institutions
Janine Wolff

PCI DSS v4.0 blog entry for October

Evidences in PCI DSS assessments

In this episode of our PCI DSS v4.0 blog, we explain assessors’ respon­si­bil­ities for providing evidence of their assessment findings, and how to prepare the provision of appro­priate evidences for PCI DSS v4.0 assessments.

Assessment process

During a PCI DSS assessment, assessors check the extent to which a company has imple­mented the PCI DSS requirements.

Typically, an assessment process includes the following steps:

  • Review of documents,
  • Review of system components/settings,
  • Review of processes,
  • Review of physical condi­tions, 
  • review of protocols/results, and
  • Inter­views with staff.

This does not change with the migration to PCI DSS v4.0.

Evidence require­ments

It usually remains hidden for the assessed company how an assessor makes notes and files evidences. We give you a little insight into according changes with PCI DSS v4.0.

With the new reporting template for PCI DSS v4.0 as well as with an update of the PCI DSS Program Guide for QSAs, the PCI SSC has now clarified that they require the assessor to file a corre­sponding evidence for each assessment step. The PCI SSC checks whether the assessor companies meet this by taking samples.

For documents, this is easy: the respective document itself is the required evidence. With protocols/results, it is similar – here you just have to make sure that it is clear which system or process you are talking about.

 If you send a screenshot or file to an assessor as evidence, please make sure to include the infor­mation which system component and/or process it is about.

When reviewing system components/settings, the assessor must take dedicated notes on the system and setting in question.

When reviewing processes or physical condi­tions, the respective condition must be described in detail and it must be shown what conclu­sions the assessor draws from the obser­vation. Similarly, in an interview, the assessor is expected to roughly write down the questions and answers.

Please give the assessor enough time to take notes during the assessment. In many cases, it can shorten the paperwork if the assessor is provided with copies or screen­shots or is allowed to take photos.

The PCI DSS v4.0 lists about 250 sub-items for the 12 main require­ments — the assessor will need a corre­spond­ingly large amount of evidence.

Retention require­ments

The PCI DSS Program Guide requires that all of the above evidence must be securely retained by the assessor company for at least three years and made available to the PCI SSC and associated companies upon request.

For reasons of privacy or confi­den­tiality, companies sometimes do not allow the assessor to take and file certain evidences. In this case, the PCI SSC stipu­lates that the evidence may be filed with the assessed company instead. The require­ments for retention period and avail­ability are the same in this case.

Since the oblig­a­tions to provide evidence have become greater with PCI DSS v4.0, this case is expected to occur more frequently in the future.

 If you expect that not all evidence may be passed on to the assessor, the best way to prepare yourself as an assessed company is by

  • preparing an audit-proof storage of the evidence for at least three years,
  • keeping a list of documents and evidences not handed over during the assessment,
  • preparing a written confir­mation for the assessor, in which you 
    • name the place of storage,
    • name the contact person whom the PCI SSC can contact if it wishes to inspect evidence, and
    • confirm audit-proof storage until a specific date at least three years in the future.

Dealing with deviations

How about evidence if the assessment did not immedi­ately demon­strate compliance with all require­ments, but devia­tions were found?

Planned devia­tions

The simplest case is when you, as the assessed company, have already recog­nised in advance that you cannot fulfil a requirement or do not want to fulfil it in the specified way. In this case, you have already prepared documen­tation of a compen­sating control or a customised approach for the assessment. A PCI DSS expert can also help you with this — but it must not be the same one who then assesses the implementation.

We will comment in detail on the Customised Approach in a later episode of our PCI DSS v4.0 blog.

In both cases, the assessor will review the evidence of your company’s Compen­sating Control or Customised Approach, ask questions if necessary, and then derive and implement appro­priate testing methods. The oblig­a­tions to collect evidence result from the respective assessment method.

Unplanned devia­tions — “INFI”

If unplanned devia­tions from PCI DSS require­ments occur during an assessment period, they must be remedied and the remedi­ation verified by the assessor. This was already the case under PCI DSS v3.2.1.

PCI DSS v4.0 additionally explicitly requires that the cause for the occur­rence of the deviation is identified and that processes are imple­mented to prevent a recur­rence of such a deviation. Only if this is the case, the assessor can still consider the requirement as in place.

All devia­tions, their causes, corrective and preventive controls must be documented in the new “Items Noted For Improvement” (INFI) document for any PCI DSS v4.0 assessment.

The assessor provides the INFI document to the assessed company at the end of the assessment and both parties sign it. The INFI document proves that the assessed company has success­fully managed the devia­tions. The document can be used inter­nally within the assessed company — e.g. in compliance and risk depart­ments — and can also be shared with third parties if desired. There is no oblig­ation to present the INFI document anywhere, nor is it refer­enced in the Attes­tation of Compliance (AoC).

 Partic­u­larly for processes that have to be repeated regularly, it happens from time to time that one instance is delayed, e.g. within the imple­men­tation of 

  • security awareness trainings,
  • inspection of payment devices,
  • vulner­a­bility scans, or
  • instal­lation of patches.

It is best to consider in advance how you can design your processes in such a way that you adhere to the prescribed time periods and notice delays immedi­ately.

For further questions feel free to contact Mrs Jana Ehlers.

PCI DSS v4.0
Janine Wolff

PCI DSS v4.0 blog entry for September

Timeline for PCI DSS v4.0 migration – What are the next steps?

With March 31, 2024, the end of PCI DSS v3.2.1 is approaching. All merchants accepting payments with cards of the inter­na­tional payment brands Visa, Mastercard, American Express, Discover, JCB, or UnionPay, and all service providers supporting them, should be prepared for PCI DSS v4.0.

But what should be done in particular, and when?

Gap analysis

The first step should be a gap analysis. Anyone who has not yet checked which new require­ments come up to them with PCI DSS v4.0 should do so as soon as possible! The reasons are obvious:

  • Imple­menting new require­ments will require time and resources.
  • PCI DSS profes­sionals who can advise on imple­men­tation are already well booked.

During the gap analysis, the new require­ments must be read, under­stood, and aligned with the existing landscape of controls. To under­stand the require­ments, it is extremely helpful to read not only the requirement itself, but also the extensive guidance that the PCI SSC has provided alongside each requirement within the standard:

  • The “Guidance” column (to the right of the requirement),
  • the objective being pursued by the requirement (below the requirement),
  • and, if available, the applic­a­bility note (below the requirement).

The intro­ductory chapters of PCI DSS v4.0 and the glossary in Appendix G can also support in under­standing termi­nology and applicability.

If you work with a PCI DSS expert at present, feel free to draw on their expertise and experience within this step already.

Priori­ti­sation

When all open items have been identified, timeframes and respon­si­bil­ities should be assigned. When assigning timeframes, the following should be considered:

  1. How long will the imple­men­tation take?

The imple­men­tation of new technical solutions often takes a long time due to internal depen­dencies. Often this comes together with low human resources. Issues that are expected to take a long time to implement need to be addressed earlier than those where a quick completion is expected.

  1. Are targeted risk analyses required?

In v4.0, for many regular tasks the frequency of perfor­mance is no longer prede­fined, but is to be deter­mined by a targeted risk analysis. The imple­men­tation of such targeted risk analyses must be coordi­nated inter­nally and hence requires time.

  1. Are there periods that are partic­u­larly good or bad for implementation?
    g. for policy changes, it can make sense to consider document review cycles. For technical changes, it makes sense to consider any freeze periods or release periods that have already been planned.
  2. Is the PCI DSS v4.0 deadline for this requirement 2024 or 2025?

For many funda­men­tally new require­ments in PCI DSS v4.0, the applic­a­bility notes state that the requirement is considered best practice until 31 March 2025, after which it is mandatory.

Require­ments without this note must be imple­mented by 31 March 2024 and might therefore require a higher prioritisation

Decisions

For some new require­ments, there are different ways to implement them. Examples are:

  • Requirement 3.4.2 calls for preventing copying/moving of PAN when accessing remotely (except for personnel with appro­priate business need). There can be several ways to implement this, too — e.g. via a setting in RDP when using the remote connection, or by preventing highlight­ing/­copy­ing/­mouse-right-clicking on PAN displays on according web pages.
  • Requirement 8.4.2 requires multi-factor authen­ti­cation (MFA) when accessing the Cardholder Data Environment (CDE).Depending on how the access towards the CDE takes place, it may make sense to enforce MFA at network level, at system level, or at appli­cation level. This decision must be well weighed with the various parties involved. Several parties may even have to work together on the solution.

Weigh up the impact of different solutions at an early stage!

Tracking and Assessing

Once you have priori­tised your tasks and decided on imple­men­tation paths: please do not sit back! The person or team respon­sible for maintaining PCI DSS compliance should stay in contact with the teams respon­sible for the implementation.

  • Are there any enquiries/comprehension issues?
  • Do any problems with the imple­men­tation arise?
  • Is the agreed target date at risk?

As soon as a new solution has been imple­mented, it should be checked whether it meets the corre­sponding PCI DSS requirement. External PCI DSS experts can also support with small interim pre-assess­ments in order to be on the safe side for the next official annual assessment.

Continuous Process

Once a requirement is met, there is no guarantee that it will remain so. Card data usage, technologies and attack vectors change. Already today, PCI DSS v3.2.1 comprises regular tasks for maintaining PCI DSS compliance. With PCI DSS v4.0, this is becoming even more of an ongoing process.

Therefore, get into the habit of putting your controls to the test repeatedly, and of adhering to the timeframes for recurring activ­ities (now precisely defined in chapter 7 of the PCI DSS). This will also make it easier for you to comply with new corre­sponding require­ments, such as e.g.

  • 2.4 / 7.2.5.1 Review of user accounts and assigned access rights,
  • 3 Review of risk assess­ments and review of the appro­pri­ateness and security of crypto­graphic algorithms, hardware and software technologies used,
  • 5 Validate the PCI DSS appli­cation scope; and
  • 6.2 Review of the security awareness programme.

Above All: Start!

This is the most important step. If you haven’t started yet, today is the best day to do so. Assemble a team and schedule time.

Should you need any assis­tance do not hesitate to contact Jana Ehlers via email.

Janine Wolff

PCI DSS v4.0 approaches – we support your preparation

PCI DSS is a mature standard that defines require­ments for secure processing of card data of the inter­na­tional payment brands.
Version 3 of PCI DSS, which has been valid since 2014 — with various updates -, will finally expire at the end of March 2024 and will be replaced by the new version 4.0.

We take the final steps to PCI DSS v4.0 migration with you. Please make use of our offers:

1. Monthly blog articles highlighting one PCI DSS v4.0 topic at a time

2. Free webinars summa­rizing the changes from PCI DSS v3.2.1 to v4.0 again

  • Webinar on the full PCI DSS scope (January 2023)
  • Webinar for card-present merchants with SAQ B‑IP or P2PE scope (January 2023)
  • Webinar for e‑commerce merchants with SAQ A scope (January 2023)

As soon as the exact dates are fixed and the regis­tration is activated, you will find the corre­sponding links here.

3. PCI DSS v4.0 workshops tailored to your needs, in which we specif­i­cally present and discuss the require­ments that are relevant to you.

4. A gap-analysis of your environ­ments and processes. You will receive a list of all open items for PCI DSS v4.0 compliance in your company.

5. Consul­tancy packages of your choice. You can call up quotas at any time if you have specific queries — by telephone, e‑mail, web conference, or in meetings on site.

Please feel free to contact Mrs Jana Ehler via e‑mail for further inquiries.

 

Homepage Admin

SRC goes GEAR (Global Executive Assessor Roundtable)!

PCI SSC and SRC

The Payment Card Industry Security Standards Council (PCI SSC) is a global forum that develops and promotes the use of infor­mation security standards for secure payments. It is respon­sible for 15 globally recog­nized and widely used standards for securing electronic payment processes — from payment card production and issuance to payment at the point of interest or in web & app, to the processing of payments in the background.

SRC has been assessing the use of those infor­mation security standards since PCI SSC was founded by means of corre­sponding assess­ments and product evalu­a­tions. The PCI SSC attaches great impor­tance to the exchange between different stake­holders and uses various committees and activ­ities for this purpose. SRC has so far partic­i­pated in Special Interest Groups and Task Forces as well as in Community Meetings and Request for Comment phases.

Global Executive Assessor Roundtable

The PCI SSC has been giving experi­enced assessor companies the oppor­tunity to advise its senior management since 2018 through the Global Executive Assessor Round­table (GEAR). We are excited that our company has been selected this year to be part of the inter­faces between leadership of the PCI SSC itself and leadership of the assessment companies by this respon­sible membership. This will enable us to contribute our years of experience in a direct way. The nomination is valid for the next two years and gives us the oppor­tunity to play an influ­ential role in the further devel­opment of speci­fi­ca­tions for assessment proce­dures, new training programs and quali­fi­cation require­ments for future assessors. Other GEAR respon­si­bil­ities include finding ways to promote assessors’ engagement in emerging and new markets, and optimizing assessors’ skills to add value for payments companies

We are proud to be included in this circle and see it as a recog­nition of our past perfor­mance and relevance in the payments security market. At the same time, we are aware of our respon­si­bility to act as a repre­sen­tative for a large community of assessment companies and take this as an additional incentive for the future.

Link to GEAR: https://www.pcisecuritystandards.org/about_us/global_executive_assessor_roundtable/

Janine Wolff

8 digit BINs and PCI DSS

On April 1, 2022, the payment brands Visa and Mastercard will expand the BIN (Bank Identi­fi­cation Number) of their cards worldwide from 6 to 8 digits. In future, the first 8 digits of a 16-digit credit card number (Primary Account Number, PAN) will be used to identify the card issuer. The BIN is used in many occasions where the use of the full PAN is not necessary — e.g. for routing of trans­ac­tions, or for reporting.

BINs and PCI DSS 

Wherever a full PAN is used, the systems, environ­ments, processes and people must meet the require­ments of the data security standard PCI DSS (Payment Card Industry Data Security Standard). As useful as the protection of the PAN by the PCI DSS is – it is not necessary for the BIN. The PCI DSS therefore describes the condi­tions under which parts of the PAN do not require the same protection as the full PAN. If not the full PAN is stored, processed or trans­mitted, but only parts of it, the PCI DSS refers to “truncation”. If the full PAN is stored in the background, but not all digits are displayed in an appli­cation, the PCI DSS refers to the display as “masking”. In everyday life, the term “crossing out” is also used for the two different measures; from PCI DSS point of view, however, they have to be differentiated.

The following rules previ­ously applied to truncation and masking:

  • Masking: PCI DSS Requirement 3.3 states that a maximum of the first six and last four digits (“first 6, last 4”) of the PAN may be displayed, as long as there is no business need to view the full PAN.
  • Truncation: PCI DSS Requirement 3.4 lists truncation as an example of rendering PANs unreadable, but does not define it. The permitted formats are rather defined by the inter­na­tional payment card organi­za­tions and get summa­rized by the PCI SSC in FAQ entry #1091. Most of them had agreed on the rule “first 6, any other 4”, which had lasted for many years.

Changed rules for truncation and masking 

However, due to the switch to 8‑digit BINs and the need for many companies to process them, the payment brands have now changed their speci­fi­ca­tions. The current summary in the PCI SSC FAQ entry now defines that “first 8, any other 4” is permitted for truncation for 16-digit PANs. The (test) card number 4012888888881881 is then allowed to be stored and processed in the form 40128888xxxx1881, for example — it is suffi­cient if any four digits are crossed out after the BIN. Only for shorter PANs, the existing rules “first 6, any other 4” (Discover) or “first 6, last 4” (American Express) remain in place. A corre­sponding adjustment of the PCI DSS requirement for masking is expected with the change to PCI DSS v4.0.

From a security point of view, removing so few digits is not an improvement — but from a business perspective, the change is probably necessary. It is to be hoped that, overall, this will be offset by other security measures.
In any case, the require­ments of the PCI DSS will not prevent the use of 8‑digit BIN in the future.

Caution when combining different formats 

Regardless of the length of the BIN, merchants and service providers who work with truncated card data should take care not to weaken the protection by mixing different formats.

  • It must be considered that the extended truncation formats only apply to 16-digit PANs. The length of the PAN must therefore be taken into account for truncation during storage.
  • Truncation formats such as “first 6, any other 4” theoret­i­cally allow the existence of different truncated versions of the same PAN. The above card number might be stored as 40128888xxxx1881 in one system and 401288888888xxxx in another. This is not prohibited — but it must be ensured that no one without an according business need can merge the two versions and thus recon­struct further digits of the PAN — right down to the complete card number.
    This also applies if different formats are used for masking and truncation.
  • If both truncated PANs and the hash values of PANs are stored in an environment, the two values themselves are initially uncritical. However, if the truncated PANs and their hash values can be related, the original full PAN can be easily recon­structed using rainbow tables. In this case, additional measures must also be taken to prevent the two versions from being merged.
Janine Wolff

PCI DSS v4.0 is coming — an overview

The PCI DSS (Payment Card Industry Data Security Standard) is well known as a compre­hensive data security standard for payment card data of the inter­na­tional payment brands. The Payment Card Industry Security Standards Council (PCI SSC) keeps revising the standard throughout the years to address evolving risks and threats to payment data, to keep pace with the ever changing IT and payment landscape, and to reinforce security.
The PCI SSC has been working on the new, funda­men­tally revised version 4.0 of the standard for a long time now. After three RFC phases throughout the years, the new version will now be officially published on the PCI SSC website in March 2022.
Several changes have already been announced and are listed hereafter.

New validation options 

PCI SSC plans to add more flexi­bility to the standard. Tradi­tionally, the intended way of fulfilling a PCI DSS requirement is to follow it word by word. Now, the PCI SSC plans to add a choice: For nearly each requirement, an entity can either choose the tradi­tional way of fulfilling it word by word, or they can use a customized validation.
For each requirement in the standard, the objective that is intended to be reached with it will be given. If an entity thinks that they want to use another way of meeting this intention than following the requirement word by word, they can document how they do this. This includes a risk assessment to verify the appro­pri­ateness of the customized way. This documen­tation, including the risk assessment, is then provided to the assessor, and the assessor identifies suitable testing proce­dures to verify the imple­men­tation of the customized controls.

Requirement changes

To make sure PCI DSS compliance is kept up throughout the year, additional require­ments are announced by the PCI SSC, e.g. the necessity for

  • Defin­ition of roles and respon­si­bil­ities for all PCI DSS relevant topics; and for
  • Regular verifi­cation of PCI DSS scope.

In addition, existing require­ments will be adapted to threat and security evolvement. Changes to require­ments on the following topics are forecasted:

  • Authen­ti­cation requirements,
  • Detection mechanism and awareness measures for ongoing threats, and
  • Risk assess­ments.

Also the use of 8‑digit BINs will need to be addressed (see our blog entry).
Of course, the exact details of changes can only be given after the final publication.

Transition process

The PCI SSC has announced a transition period of two years, plus additional transition time for completely new requirements.

So after publi­cation in March 2022, take your time to read the new PCI DSS version, identify the changes, and under­stand the impact on your environment. Use this year to plan migration to PCI DSS v4.0 and decide when is the right moment for your entity to switch from version 3.2.1 to 4.0.

Your PCI DSS consultant or assessor can help you under­standing the intention of changes, your need for migration, and the validation require­ments. Please do not hesitate to contact them. If you do not have direct contact to a PCI DSS expert, please contact SRC’s PCI DSS respon­sible.

To get a first overview of the changes to the standard, you can also join our free PCI DSS v4.0 webinar on 20th of April: Register here.

PCI DSS v4.0 release delayed
Homepage Admin

PCI DSS v4.0 release delayed

The publi­cation of a new, funda­men­tally revised version of the payment trans­action standard PCI DSS has been announced since 2019. We are eagerly awaiting the changes that the new version will bring.

After PCI DSS v4.0 had already undergone two RFC phases in 2019 and 2020, the PCI Security Standards Council has now decided to also initiate an RFC phase for supporting documents, in particular for

  • the template for the Report on Compliance (ROC),
  • the template for the Attes­tation of Compliance (AOC), and
  • the self-assessment question­naires (SAQs)

in June 2021. However, this will also delay the publi­cation of PCI DSS v4.0.

Instead of the announced release period in Q2 2021, the aimed period of final­ization is now Q4 2021. The actual release date has not yet been specified.

We must therefore be patient a little longer before we can properly plan the migration. With the shift of the publi­cation date, the planned transition periods from PCI DSS v3.2.1 to v4.0 have also been postponed. We are therefore also postponing our PCI DSS v4.0 webinars to 2022.

SRC-Expertin Ehlers: Standards of the Payment Card Industry (PCI)
Homepage Admin

SRC-Expert Ehlers: Standards of the Payment Card Industry (PCI)

“PCI compliance requires know-how and resources.” SRC expert Jana Ehlers explains the different PCI security standards in an article which has just been published on the profes­sional platform “All About Security”.

In view of the increasing number of card payments in pandemic times, the protection of payment card data is a very current topic.

All PCI standards aim at protecting payment card data of inter­na­tional payment systems. The most well-known standard alone, PCI DSS, has around 250 individual require­ments. If these are already taken into account when setting up networks and struc­tures, there is often no need for complex and expensive retrofits. But also the permanent mainte­nance of PCI DSS conformity poses challenges for companies.

SRC examines and advises on PCI standards since their emergence in 2006. This experience can be used to correctly under­stand and consider the inten­tions of the PCI standards. SRC accom­panies through the whole process. Thus, not only PCI-conformity can be achieved in an under­standable way, but also a great deal more security for the customers’ payment card data worthy of protection.

SRC recognized as SPoC/CPoC Lab by the PCI SSC
Homepage Admin

SRC recog­nized by PCI SSC as SPoC and CPoC Security Lab

Today, the worldwide operating PCI Security Standards Council has recog­nized SRC as the fourth laboratory for the perfor­mance of security tests for SPoC and CPoC solutions.

With SPoC solutions (Secure PIN Entry on Commercial-off-the-Shelf devices) a merchant can accept payments with commer­cially available mobile devices.

While the SPoC program describes solutions with PIN entry, the CPoC program is aimed exclu­sively at contactless solutions that do not require PIN entry.

A SPoC solution consists of four core components

  • a Secure Card Reader for PIN (SCRP), an external and PCI PTS approved card reader,
  • a tested PIN CVM App for secure PIN entry on the merchant’s standard mobile device,
  • the retailer’s mobile device (COTS device) such as a smart­phone or tablet, and
  • a background system that contributes signif­i­cantly to the security of the overall system by means of attes­tation, monitoring and processing.

With CPoC, the PCI SSC has developed require­ments for solutions for processing contactless payments without PIN entry (“Tap and Go”) on commer­cially available mobile devices (commercial off-the-shelf, COTS), such as smart­phones or other mobile commercial off-the-shelf (COTS) devices with NFC interface.

With the SPoC and CPoC programs, the PCI SSC meets the increasing demand for new and secure accep­tance solutions and ensures security in the accep­tance of payments via mobile phones and tablets. The corre­sponding tests are now also carried out by SRC.

The recog­nition of SRC as a lab for the programmes SPoC and CPoC is an important signal to the market. Customers from this innov­ative environment can now also make use of SRC’s expertise for the devel­opment of secure payment solutions.

PCI DSS guidance for Large Organizations
Homepage Admin

PCI DSS best practices guidance for large organi­za­tions published

SRC Security Research & Consulting GmbH contributed to the most recent PCI (Payment Card Industry) Security Standards Council Special Interest Group (SIG). The resulting guidance on PCI DSS for Large Organi­za­tions is now published.

Complex organi­za­tions, corpo­ra­tions and companies often face specific challenges when imple­menting PCI DSS (Payment Card Industry Data Security Standard) require­ments: the hetero­geneity of their infra­struc­tures and processes, the constant change of corporate struc­tures, and dealing with diverse require­ments, respon­si­bil­ities and management tasks.
The new guidance on PCI DSS for Large Organi­za­tions helps large and/or complex organi­za­tions coordinate and manage their PCI DSS activ­ities across multiple environments.

  • PCI DSS guidance for Large Organi­za­tions //document.