Re: Faxing and PCI DSS compliance

["rajat swarup" <rajats () gmail com>]

On Jan 24, 2008 3:15 PM, jw <rx.jeff () yahoo com> wrote:
> Well, let me be more specific.  Let's say your company
> utilizes another company's service where you can
> receive faxes via email in the form of PDF sent to
> you.
>
> So let's say your customer faxes you full 16 digit cc#
> with expiration on their regular fax machine.  What is
> your company's PCI liability on this as that fax, with
> cc info gets to you in the following manner:
>
> customer fax cc# --> 3rd party fax service --> to your
> company in PDF via email
>
> So in essence, should your company be liable for
> non-compliance even though this is not something you
> can control?
The requirement 3 is about "sending" PAN and not about receiving.
Your responsibility would be to abide by all PCI requirements unless
you destroy the e-mails according to the PCI DSS requirements (i.e.,
military wiping stuff).
> cwright () bdosyd com au wrote:
> JW,
> Your first problem will stem from having to encrypt
> the numbers in transit. The fax to email gateway will
> have to sign these emails.
>
> A set of competating controls could be implemented for
> this (protected network with firewalls, IDS etc which
> could take the place of encrption, but this would be a
> significant investment in itself. The PCI-DSS
> requirement 3 states "not sending PAN in unencrypted
> e-mails". 4.2 also specifically states "4.2 Never send
> unencrypted PANs by e-mail".
>
> So as I said, there are possible compensating
> controls, but I believe that they are going to be far
> more of an investment then encryption.
>
> Next in this case the fax server and email system
> would have to be on a firewalled segment and not (as
> is common) on the same network as all the users.
>
> With physical faxes, 9.6 applies "Physically secure
> all paper and electronic media (including computers,
> electronic media, networking and communications
> hardware, telecommunication lines, paper receipts,
> paper reports, and faxes) that contain cardholder
> data."
>
> You would have to have a minimum level of security on
> the virtualised process as for paper handling. So this
> would cover (as with the above) encryption,
> destruction after use etc.
These things are required if at all you store the CC data.  You cannot
control the actions of others who decide to send you their CC numbers.
 Your responsibility is to handle the data responsibility.

Hope it helps,
Rajat.
-- 
Rajat Swarup

http://rajatswarup.blogspot.com/

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