Re: PCI compliance question

[Joel Rosenblatt <joel () COLUMBIA EDU>]

I am not a PCI expert, but I have been up to my eye balls in PCI stuff for a while :-)

If you are not accepting CC, then the fact that the miss guided person sticks his card in your device does not put that 
device in scope for PCI.

If someone were to swipe their Visa card in your controlled access door swipes, and this were the case, then every door on your campus would suddenly become in 
scope for PCI.

The ultimate responsibility for PCI belongs to the organization that owns the MID for the account that will receive the income from that transaction - since 
there is no MID (Merchant ID) attached to your vending machines, there can be no PCI compliance.

In my opinion, I believe, and any other disclaimer :-)

My 2 cents

Joel Rosenblatt

Joel Rosenblatt, Manager Network & Computer Security
Columbia Information Security Office (CISO)
Columbia University, 612 W 115th Street, NY, NY 10025 / 212 854 3033
http://www.columbia.edu/~joel


--On Thursday, July 08, 2010 2:46 PM -0400 "Smith, Bob" <smithrj () LONGWOOD EDU> wrote:

> We are struggling with a PCI compliance issue and have been asked to query this list.  We have vending machines (drink, 
> snack, laundry, etc.) on our network
> that are being setup for use with our university "one card" system.  The readers on these machines will transmit and 
> process our cards just fine.  However,
> when someone uses a CC it is transmitted to the card system/server, but the system ignores it and does not process the 
> transaction.
>
> The big question:  are the vending machines considered in-scope for PCI?  If so, that means a lot of other things will 
> be too.
>
> Thanks.
>
> Bob Smith
> AVP IITS & Information Security Officer
> Longwood University



Joel Rosenblatt, Manager Network & Computer Security
Columbia Information Security Office (CISO)
Columbia University, 612 W 115th Street, NY, NY 10025 / 212 854 3033
http://www.columbia.edu/~joel