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Under pressure

Many retailers will have breathed a sigh of relief after the race to achieve chip PIN compliance. However, as Duncan Jefferies discovers, there’s no time to rest now that the Payment Card Industry Data Security Standard is on its way

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Like cockroaches, fraudsters are an adaptable and hard to destroy species. Now that chip and PIN rollout is complete, they have been busy pursuing new ways of stealing card holder data, and Card Not Present fraud has risen as a result. A number of high profile cases in the US has led the card companies to implement a new method of pest control, the Payment Card Industry Data Security Standard (PCI: DSS), which looks set to have just as big an impact on the retail sector as chip and PIN.

The PCI standard draws together the security requirements and guidelines developed individually by the card schemes into a single standard designed to protect cardholder identity and transaction information. Prior to the merger the individual card schemes were known as:

•MasterCard SDP (Site Data Protection) security certification
•Visa AIS (Account Information Security)
•Visa CISP (Cardholder Information Security Program)
•American Express DSOP (Data Security Operating Policy)
•Discover DISC (Information Security and Compliance)

“It’s a much bigger issue than people have been led to believe,” says Paul Makin, sales director at K3. “It’s not just a process change, it will involve software changes at the expense of the retailers.” PCI: DSS is a wide ranging standard that covers people, processes and technology. All parties that are involved in the card payment system must adhere to the requirements. This includes all acquirers, merchants, retailers, and payment service providers.

The compliance requirements of PCI: DSS, as set out by Visa and MasterCard, not only apply at entity level but also at system components level. This includes any network components, servers, or applications included in, or connected to, the cardholder data environment. Although the 30 June 2007 compliance deadline is fast approaching, the number of retailers actively working toward compliance remains low. The original deadline for compliance was set as 30 June 2005 until an extension was granted (the UK is the only country in Europe where it has been extended).

One of the main aims of the PCI standard is putting a stop to cases of internal fraud, a long-term problem for organisations handling cardholder data. According to a recent DTI Security Breaches Survey, 64 per cent of large companies reported staff misuse of IT systems, 39 per cent reported unauthorised access by outsiders (including hacking attempts) and 49 per cent reported computer-related theft or fraud. The average cost to a large company of a serious security incident is in the region of £120,000.

The security of the internal network has long been underestimated as an entry point for theft or attack according to Steve Mulhearn, technical director at Arbor Networks. PCI compliance requires a shift of attention to the interior of the network and demands network security managers know the established network conversation patterns of every employee who has access to servers, know how data is encrypted and ensure access to sensitive data is restricted. Despite rumours that some retailers see PCI as little more than a money making scheme by the card companies, Mulhearn maintains its importance to the retail sector. “PCI is definitely necessary and I think Visa MasterCard would have had to implement it sooner or later due to the sheer volume of transactions now occurring in business, particularly online.”

PCI compliance is made up of 12 main requirements. The standard applies to all systemcomponents throughout the transaction process, such as the use of data encryption, user access control, both physical and system log-on and secure networks. Procedural requirements are also covered, such as the need to implement formal information security policies and the ongoing risk assessments of the vulnerability of the system to malicious attack.

“Having notable levels of security and protection in their systems can give retailers more confidence that this data isn’t literally lying around, which to be fair in the past it probably was,” says Paul Makin, sales director at K3.

PCI compliance holds the added benefit of identifying the business as one that upholds standards of best business practice. The standard also aims to improve consumer confidence in card transactions and reduce cardholder disputes and the costs resulting from fraudulent transactions from compromised data.

Compliance takes place over several stages. A pre-compliance assessment analyses the businesses existing infrastructure to identify potential compliance violations. A set of reports are produced that show PCI compliance status throughout the business, allowing merchants to identify and deal with compliance issues prior to the auditors arrival. Retailers must then demonstrate their compliance to auditors prior to achieving full PCI certification.

While all companies handling card data must comply with the same PCI: DSS rules, the extent of audit required to prove compliance varies according to the size of the company. The smallest merchants may only have to self-certify, whereas the members, larger merchants and payment service providers must arrange an annual external audit and quarterly external network scans of their hosts with a Visa-approved Qualified Security Assessor (QSA). In other words, PCI: DSS is not a one-off requirement; it involves continuous monitoring and review as the card industry moves toward a more regulated environment.

“We’ve only just got our own compliance and its cost us around half a million and we’re nowhere near the size of a retail operation,” says Gareth Wokes, chairman of The Logic Group. “So you’re talking about a lot of money, but more importantly you’re talking about a long time. You’re talking about a remediation programme that’s going to take six months to a year. Those we’re working with at the moment will be in time, those in the next three to six months may well be in time, somebody leaving this until next year, even with the best will in the world, they’re going to be right up against the deadline,” he adds.

Chip and PIN implementation was a costly process for many retailers, but due to its focus solely on PoS systems it was a manageable one. However, as Wokes says, “PCI affects far more than the store, it affects all of their operations so in that sense it’s huge. Personally I think most retailers aren’t in the frame of mind to think about this.”

A survey by the Logic Group revealed that not one of almost 100 merchants questioned had achieved full accreditation despite the original 30 June 2005 deadline having passed. Indeed, 55 per cent were not even aware of the data security process and a further 73 per cent have put no measures in place to ensure compliance in time.

The survey also highlighted that 57 per cent of those questioned had received no support or guidance on PCI. Many companies providing PCI compliance packages to retailers believe poor take-up of PCI thus far could be due to a lack of understanding throughout the industry concerning what needs to be done in order to achieve compliance.

“There’s a lack of clarity, there hasn’t been a good job done in explaining the need for this. Because of that lack of clarity it has caused a lot of confusion. That coupled with the fact that it’s coming just after chip and PIN makes it a hard pill to swallow for many retailers.” Paul Makin, sales director at K3.

Counting the cost
Retailers failing to comply with the standard face the prospect of substantial fines imposed by the card schemes or alternatively, being permanently barred from accepting card payments should a security breach occur.

“I think it’s going to be expensive and some retailers will certainly struggle financially when implementing it. The system of fines works on individual transactions and these can quickly add up to become very costly for those retailers failing to comply,” says Arbor Networks’ Mulhearn.

Seeing that the regulation is met and enforced falls to the card companies. However, the card schemes’ members – such as the banks that sign merchants up as Visa retailers – also have a role to play in ensuring that their sponsored merchants are PCI: DSS certified. In addition, these members and merchants should only buy payment related services from PCI: DSS certified service providers.

“I’m sure they will be a whole a raft of people in the mid-tier space that won’t be compliant in time. There will be a lack of resources as we saw with chip and PIN; the banks just didn’t have enough people to accredit everybody,” says K3’s Makin.

Despite confusion among retailers as to what is required of them, one thing is clear – PCI compliance is essential. With time running out and auditors and experts sure to be thin on the ground come early next year, all those involved in the card transaction process must begin taking steps to gain certification immediately. Otherwise they may find themselves facing a hefty bill from the pest controllers should they suffer a fraudster infestation post 30 June 2007.

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