Re: PCI Wireless Question for other colleges/universities

[Brad Judy <brad.judy () CU EDU>]

That depends, are you 100% confident that whatever contract that was signed did not even slightly imply that your 
institution is a PCI service provider to the vendor?  

Brad Judy

Information Security Officer
Office of Information Security
University of Colorado 
1800 Grant Street, Suite 300
Denver, CO  80203
Office: (303) 860-4293
Fax: (303) 860-4302
www.cu.edu




-----Original Message-----
From: The EDUCAUSE Security Constituent Group Listserv [mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Kevin 
Reedy
Sent: Monday, January 25, 2016 2:09 PM
To: SECURITY () LISTSERV EDUCAUSE EDU
Subject: Re: [SECURITY] PCI Wireless Question for other colleges/universities

Hi Tim,

I'm a little curious why you feel you have any PCI burden with a vendor that is not affiliated?  Any exposure would be 
on them, with possible backlash being negative press for you because of selecting them.

I don't see how the PCI burden transfers from vendor to host, that would be like an ISP being held responsible for a 
breach that occurred over the internet.

-Kevin



From:   "Carroll, Tim" <Carrolltd () ROANESTATE EDU>
To:     SECURITY () LISTSERV EDUCAUSE EDU,
Date:   01/25/2016 03:53 PM
Subject:        Re: [SECURITY] PCI Wireless Question for other
            colleges/universities
Sent by:        The EDUCAUSE Security Constituent Group Listserv
            <SECURITY () LISTSERV EDUCAUSE EDU>



The previous advice you received is all correct.  The only thing I would add is how you handle vendors who come on 
campus temporarily and want to use your network to process their payments.  We handled this by requiring them (by 
policy and language on contracts) to use their own networks such as a cellular wireless point.

Regards,

Tim
Tim Carroll
Assistant Vice President and Chief Information Officer Information Technology Roane State Community College carrolltd 
() roanestate edu
865-882-4560

From: The EDUCAUSE Security Constituent Group Listserv [ mailto:SECURITY () LISTSERV EDUCAUSE EDU] On Behalf Of Paul 
Chauvet
Sent: Monday, January 25, 2016 1:05 PM
To: SECURITY () LISTSERV EDUCAUSE EDU
Subject: [SECURITY] PCI Wireless Question for other colleges/universities

Hello all,

I’m wondering how other colleges/universities handled a specific PCI requirement, 11.1.2, regarding unauthorized 
wireless access points.  We have a few areas with payments going over wireless, but even if we changed things to not 
use wireless for payments, it appears that this requirement is applicable.

We have taken appropriate steps to secure the terminals/computers, and had a skilled penetration testing company that 
was completely unable to break through to the payment terminals (or even through the network segmentation).  We also 
have scanning in place that can detect rogue access points.  I believe that the systems are secure but security isn’t 
compliance.

In this day and age where anyone can turn their phone into an access point, there are always a number of them, most of 
them being transient.  What have other colleges done when faced with these situations?  We’re not a huge school that 
can afford the staff that it would take to go hunt the transient access points down.

I’d appreciate anything you can share on- or off-list about this scenario.

Thanks,

Paul Chauvet
Information Security Officer
State University of New York at New Paltz chauvetp () newpaltz edu
845-257-3828
emlogo





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