City of Portland Audit: Follow-Up on Compliance with Payment Card Industry Data Security Standard BY ALEXANDRA FERCAK SENIOR MANAGEMENT AUDITOR
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1 City of Portland Audit: Follow-Up on Compliance with Payment Card Industry Data Security Standard BY ALEXANDRA FERCAK SENIOR MANAGEMENT AUDITOR
2
3 Examples of Government data breaches in 2016, listing number of records exposed
4 Includes health records, personal data, and payment card data Source: Identity Theft Resource Center
5 What is PCI DSS? Payment Card Industry Data Security Standard Standard created and maintained by the PCI Security Standards Council, representing the major card brands network (Visa, MC, Amex, Discover, etc.) Ensures that merchants appropriately protect cardholder data Covers all forms of payment cards Not law (except Washington, Nevada, Minnesota) Enforced by the major card brands network
6 What is PCI DSS? If you process, transmit or store payment cards, you must comply with the standard. Helps protect merchants/customers from data breaches and fraud. Includes 12 requirements for a secure payments environment.
7 Payment Card Industry Data Security Standard for Merchants & Processors Goals 12 Requirements (with over 200 sub-controls) - Reporting responsibility to the bank and credit card network Build and maintain a Secure Network 1. Install and maintain a firewall configuration to protect cardholder data 2. Do not use vendor-supplied defaults for system passwords and other security parameters Protect Cardholder Data Maintain a Vulnerability Management Program Implement Strong Access Control Measures Regularly Monitor and Test Networks 3. Protect stored cardholder data 4. Encrypt transmission of cardholder data across open, public networks 5. Use and regularly update anti-virus software or programs 6. Develop and maintain secure systems and applications 7. Restrict access to cardholder data by business need to know 8. Assign a unique ID to each person with computer access 9. Restrict physical access to cardholder data 10. Track and monitor all access to network resources and cardholder data 11. Regularly test security systems and processes Maintain an Information Security Policy Source: Payment Card Industry Security Standards Council 12. Maintain a policy that addresses information security for all personnel
8 Passing the PCI DSS Review Organizations with less than 6 million transaction/year can do self-assessment. All others require annual onsite audit by external auditors. Audit verifies organization is compliant with 12 requirements and over 200 sub-controls. Must comply with all requirements: Failing one sub-control leads to failing the related requirement and the audit.
9 City of Portland PCI DSS Compliance PCI Compliance identified in a risk assessment City policy and contract with City s Bank require 100% compliance External IT Auditors conduct annual onsite audits (since 2009) Assumption was the City is PCI DSS compliant Performance measure reported 100% compliance every year since 2009 Source: City of Portland FY Adopted Budget
10 City s Payment Card Transactions In 2015, City processed over 10 million payment card transactions. Includes payments for parking in City-owned garages, utility services, and participating in Parks and Recreation classes.
11 Who is responsible for PCI Compliance? Merchant: City of Portland - Treasurer/CAO - Info Security Officer/CTO - Bureau Directors City policy requires full compliance City s Bank: requires compliance City s Merchant Services Contract Major Card Brands Network: requires the City to send signed annual Attestation of Compliance to the City s bank
12 Risks of Non-Compliance Increased risk for fraud and breach Penalties for non-compliance (up to $500,000/year) Loose ability to process payment cards High costs for data breach ( average cost/breach $4million) Loss of revenue and public trust
13 November 2014 Audit Results City has never complied with PCI DSS (since 2009) Each year City Treasurer submitted Attestation of Compliance to City s bank (reporting non-compliance) No follow-up to PCI DSS remediation steps and deadlines City did not enforce compliance with the standard Governance and responsibilities over compliance not clearly defined Did not designate sufficient resources to compliance City flew under the bank and card network s compliance radar
14 What has the City done after the audit? FY Budget identified PCI compliance as major issue to address Dedicated significant resources to reach compliance by Nov 2015 Started migrating payments to external PCI compliant processors Removed payment card data from the City s technology network Implemented payment card data security training Discontinued non-compliant payment processing systems: Customer s automatic water/sewer payments Building permit fees over-the-phone payments
15 City clarified roles and responsibilities regarding compliance with PCI standard Payment card transactions/assets/processes and procedures are documented Governance for standard-related policy/processes reside with City Treasurer Administration/auditing/monitoring of standard-related services reside within the Information Security Office Bureaus are accountable to City Treasurer and Information Security Office for compliance with the standard Technology Services provides assets, services and controls to securely maintain cardholder data Information Security Officer s responsibilities have been expanded
16 FY compliance is an effectiveness measure - inaccurately reported full compliance with standard - FY compliance is a key performance measure - accurately reported % of standard requirements satisfied FY Performance measure was removed
17 Timeline to Compliance November 2014 City Auditor releases audit report stating non-compliance Sept/Oct External auditors conducted annual PCI audit Dec 2015 PCI audit completed with remediation steps to implement; compliance report was not issued Dec City Auditor requests follow-up to 2014 audit recommendations Spring External Auditors return to reassess compliance March/May External Auditors determine City is fully compliant with PCI May City Auditor releases follow-up audit Sept Water automatic payments back online Sept/Oct PCI annual audit conducted
18 November 2014 May 2016
19 Lessons Learned Learn about your organization s policies on PCI compliance Review your bank contract and PCI related requirements Even if external auditors conduct compliance testing, verify the process and compliance with the standard Determine whether there is follow-up on remediation steps Verify remediation steps are implemented by the deadline Each year review the PCI audit reports
20 RESOURCES PCI DSS website: Portland Auditor s PCI Audit Report: Nov May Verizon 2015 report: PCI Compliance and Security Ponemon Institute & IBM Cost of Data Breach Study: United States Identity Theft Resource Center - Annual Data Breach Summary Data Breach Report:
21 Contact Information Alexandra Fercak Senior Management Auditor Office of City Auditor Audit Services Division 1221 SW 4th Avenue, Room 310 Portland, OR Ph: (503)
22 QUESTIONS?
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