Re: PCI Gurus?

[Venkatesh Selvaraju <venkatesh.selvaraju () gmail com>]

Transactions of credit card or cardholder data that're taking place
within the company private network need not be encrypted in transit.
It however, should be encrypted in rest. Transactions that take place
over the WAN or over the public network should be encrypted using
ciphers such as HTTPs, FTPS and SFTP etc.

If company A sells a networking appliance such a router or switch to
company B and company B installs and places the appliance in a segment
of network where creditcard processing servers and applications are
hosted, company A is not in scope of PCI. If company A sells an
equipment to company B which will be used by company B for swiping and
accepting the credit card payments, then company A's equipment should
be certified and approved by PCI or should be PA-DSS certified.

Thanks,
V



On Fri, Jan 14, 2011 at 11:36 AM,  <shankl () hotmail com> wrote:
> Heres a little scenario that I wanted to throw out there and get an opinion on by someone who knows PCI. I am 
> starting to learn but couldn't help with this problem because I've never assisted in a PCI audit...
>
> (I would think this problem has been encountered by many small companies that make network appliances)
>
> ====== Background =======
>
> 1) Company A is a small company (only 5 employees)
>
> 2) They provide a service which requires their customer, Company B, to install a small network appliance on their LAN 
> in order to collect data from their onsite mechanical equipment.
>
> 3) Operating data is then pulled from these mechanical systems and then dumped to a remote server which processes the 
> data and provides a dashboard for the customer to view (via SSL).
>
> 4) Company B bought a license for this service and was also handed over the keys to administer accounts and decide 
> which employees it would like to give access to.
>
> 5) Now let’s say that Company B typically processes credit card payments locally and sends transaction data through 
> their local LAN on its way out to their payment processor.
>
> ====== Problems =======
>
> 1) Company A does not take credit cards and is not required to be PCI compliant however they do provide a service 
> which requires their network appliance to be installed on Company B’s network.
>
> 2) In recent days Company A has come to the conclusion that in some of Company B’s newly acquired satellite offices, 
> credit card data is being forwarded across the LAN in a variety of ways (some of which do not look to be 
> secure/encrypted).
>
> 3) In addition, several of these satellite offices are running consumer grade routers (ie: Linksys, Netgear) 
> providing little in the way of segmentation.
>
> 4)Company A would like to avoid being “In Scope” and having to charge the client for consulting fees.
>
> ====== Questions =======
>
> 1) For the smaller satellite offices what might be a simple fix?
>
> 2) Does segregation provide an easy way to kick devices out of scope for PCI audits?
>
> 3) Would it be recommended/possible to have a firm produce a report which could be handed to an auditor and prove 
> “Out of Scope” prior to being dragged into one of these audits?
>
> 4) Could the network appliance be designed/situated in such a way as to be “out of scope” or at least easily 
> verifiable as compliant even if it was sitting on the same logical subnet where the card data traffic was moving 
> across?
>
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