Middlebury

MDRP Responsibilities

Any department accepting credit card and/or electronic payments on behalf of Middlebury for gifts, goods or services (“Merchant Department”) must designate an individual (staff or faculty member) within that department who will have primary authority and responsibility for eCommerce and credit card transaction processing within that department. This individual will be referred to in the remainder of this policy statement as the Merchant Department Responsible Person or “MDRP”.
 
All MDRPs must:
  • Execute on behalf of the relevant Merchant Department the Process to Implement Acceptance of Credit Cards for Payment detailed below.
  • Ensure that all employees (including the MDRP), contractors and agents with access to payment card data (within the relevant Merchant Department) complete the PCI Security Awareness Training & Agreement, at http://go.middlebury.edu/pcidss.  The training consists of a security awareness video, review of Middlebury PCI Policy and electronically sign the PCI Confidentiality Statement.  Training must be completed upon hire and at least annually.  The MDRP should forward the PCI Confidentiality Statement to PCI Compliance Team upon request.  
  • Ensure that all credit card data collected by the relevant Merchant Department, in the course of performing Middlebury business, is secured. 
  • Ensure all Point of Sales (POS) devices, including cellular based stand-alone swipe terminals and point of sale systems, are maintained under a state of consistent control and supervision. **The Cashiers Office has a cellular card swipe terminal for loan to staff/departments that have completed the PCI Training & Confidentiality Agreement.  
  • Ensure Point of Sale devices/terminals (cash registers, stand-alone swipe terminals etc.) are physically secured.  Complete a Terminal Characteristics form, Monthly Physical Inspection checklist, for tampering or substitution. Systems not in use must be secured in a locked facility and regularly inventoried. Retain inspection log for a minimum of one year.  **Please see Physical Inspection of PoS-Skimming Prevention.
  • Ensure all Point of Sale (POS) devices have updated patches and anti-virus with up to date logging.  Retain logging and audit trail history for a minimum of one year. 
  • Verify and collect PCI DSS Compliance Certificate or PA-DSS Validation certificate (POS systems) on all service providers within the relevant Merchant Department on an annual basis.  The MDRP should retain a copy of the certificates and submit a copy to the PCI DSS Compliance Operations Team upon receipt.  
  • Ensure user access to cardholder data environment, within the relevant Merchant Department, is revoked when the individual’s job no longer requires access to the CDE. Maintain an audit log of user access to cardholder data environment for a minimum of one year. 

Please read the PCI Policy for additional responsibilities.

PCI DSS

CLICK HERE FOR THE MIDDLEBURY PCI POLICY

CLICK HERE FOR THE PCI DSS V3.0

PCI DSS

The Payment Card Industry Data Security Standard (PCI DSS v3.0) is a standard that has been implemented by the major payment card brands.  We are contractually obligated, with our acquirer, to abide by these standards if we choose to accept payment cards as a form of payment.

The PCI DSS v3.0 Standards:

PCI DSS is broken into 12 requirements; each focusing on a different domain of security.

1.0: Install and maintain a firewall configuration to protect cardholder data.

This requirement talks about segmentation of the network at a physical and logical level. It also talks about protections placed between the systems that contain cardholder information and the open or public networks.

2.0: Do not use vendor supplied defaults for system passwords and other security parameters.

This requirement talks about modifying systems from their factory settings so that they have strong security settings that are unique to both the organization and to the system.

3.0: Protect cardholder data.

This requirement points out that other security measures can be circumvented and that cardholder data must be protected and masked. It talks about who should have access to the data and that methods such as encryption should be employed. It emphasizes that account number should be masked and that only essential persons should have access to that information. It also mentions that information in the magnetic strip may not be stored.

4.0: Encrypt transmission of cardholder data across open, public networks.

This requirement states that encryption must be used to transmit data over networks that are out of scope for PCI. If data is unencrypted than that part of the network becomes in scope for PCI and must be protected accordingly.

5.0: Use and regularly update anti-virus software and programs.

6.0: Develop and maintain secure systems and applications.

Requirement 6.0 speaks to application development as well as change control and project management. It also speaks to patch management and system update control. This requirement is about project and system life-cycle management through change control. It also talks about incorporating secure programming practices to ensure error checking, validation controls and other measures.

7.0: Restrict access to cardholder data by business need to know.

This requirement sets guidelines for building business processes and systems that restrict access to cardholder data to only those individuals that need to have access for business critical functions. It speaks of access by user ids, setting rights to deny all, and other configurations.

8.0: Assign a unique ID to each person with a computer access.

This requirement is about accountability and access control. With the use of unique ID’s each user can be held accountable for his or her own actions on the systems. Also control to cardholder data can be controlled by user id. This standard also talks about password policies and control.

9.0: Restrict physical access to cardholder data.

This requirement talks about physical access in terms of access to switches and routers, server rooms and networking closets. It talks about the use of surveillance and locks. It also speaks to the destruction of media and what constitutes media.

10.0: Track and monitor all access to network resources and cardholder data.

This requirement looks at monitoring systems for both user access as well as user activity. It looks at how people manipulate data and also when users access systems. This is about creating audit trails and managing those logs.

11.0: Regularly test security systems and processes.

This requirement speaks to the use of vulnerability scans as well as the use of IDS/IPS solutions. It also speaks to the checking of rogue wireless systems in your in-scope network. This requirement is looking for the presence of testing against current threats on your systems and what measures are in place to test for those threats.

12.0: Maintain a policy that addresses information security for all personnel.

This requirement calls for the creation of a security policy and an education program on that policy for all employees of the organization. The policy should outline the PCI standards and what the expectations are for different individuals and roles under the PCI DSS as it has been implemented across the organization.

Common Practices: These are some common practices that help to protect cardholder information.

1)      Do not write down or distribute credit card information in any unencrypted format.

2)      Do not access files to which you have not been granted explicit permission to by the owner.

3)      Ensure that you have appropriate training on the applications which you use.

4)      If you find an error or unsecured cardholder data, notify a manager or the helpdesk.

5)      Protect your own information as well as others.