To be in compliance with the Graham Leach Bliley (GLB) Act as well as maintain compliance with requirements imposed by the Payment Card Industry Data Security Standard (PCI-DSS), Tulane University entities processing credit card payments must take appropriate measures to prevent the loss or disclosure of customer information including credit card numbers. Failure to protect the privacy of our customers may result in financial loss for many customers, fines imposed on the unit, suspension of credit card processing privileges and damage to the reputation of the unit and the university. This document provides guidelines for all computer systems handling credit card numbers at Tulane University.
A. System Security Requirement
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
3. Protect stored cardholder data
4. Encrypt transmission of cardholder data across open, public networks
5. Protect all systems against malware and regularly update anti-virus software or programs
6. Develop and maintain secure systems and applications Implement
7. Restrict access to cardholder data by business need to know
8. Identify and authenticate access to system components
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
12. Maintain a policy that addresses information security for all personnel
B. Connectivity Security Requirement (Wired/Wireless)
1. A network-based firewall preventing inappropriate/unauthorized access from outside the academic/business unit or specific authorized computers.
2. An intrusion detection system (IDS) that monitors for unauthorized access attempts.
3. Continuous monitoring for network-based firewall and IDS systems for potential penetrations.
4. Specific authorization for wireless connections. All wireless connections must be approved and audited by Technology Services before being implemented.
5. All data transfers and administrative access must be in an encrypted channel (e.g. TLS v1.2, SSH, IPSEC).
C. Credit card number storage requirement
1. It is prohibited to store sensitive cardholder data [i.e., full account number, expiration date, PIN, and card validation value] in any University system and/or departmental server, third-party software, personal computer, cash register system, e-mail account, portable electronic device (including, but not limited to, laptop, flash drive, floppy disc, CD, PDA, and external or portable hard drive), or on paper.
2. All legacy, retained or other documentation containing card account numbers must be stored in a secure environment until processed. Secure environments include locked drawers and safes, with limited access to only individuals who are processing the credit card transaction.
3. Employees shall not disclose or acquire any information concerning a cardholder’s account without the cardholder’s consent.
4. The entire credit card number must not be printed on either the merchant copy or customer copy of any receipts or reports. Old documents with the entire credit card number should have all but the last four digits redacted (blacked out) or be shredded with a cross-cut shredder.
5. All media used for credit card numbers must be destroyed when retired from use. 6. Any paper receipts stored by merchants must adhere to the PCI DSS, especially requirement 9 regarding physical security.
D. Physical Security Requirement
1. The server must be in one of Technology Services secured data centers.
2. All access to servers by anyone except employees specifically approved for access to the cardholder systems must be escorted continuously.
3. All backup media must be secured on site, off site, and in transit. All transportation must be handled by Institute employees or bonded couriers.
Cardholder Data: Credit card numbers (in full or in part)
Encryption: Is the process of encoding messages or information in such a way that only authorized parties can read it.
Firewall: A network device or host-based software implementation designed to restrict network access to a computer.
Graham Leach Bliley (GLB) Act: A US law containing provisions that require all financial institutions including our university to disclose to consumers and customers their policies and practices for protecting the privacy of nonpublic personal information. This law is also known as the Financial Modernization Act of 1999.
Hashing: The process used to map digital data of arbitrary size to digital data of fixed size.
Intrusion Detection System (IDS): A network monitoring device for recognition of attempts to compromise monitored systems.
Payment Card Industry Data Security Standard (PCI-DSS) : The unified standard data protection program mandated by VISA, MasterCard, American Express, Diners Club, Discover and JCB.
Site Data Protection Program (SDP): The formal data protection program mandated by MasterCard.
Payment Card Industry Self-Assessment Questionnaires A and A-EP v3.1
Payment Card Industry Security Standard v3.1