Information Security Policy
1. Introduction 4
2. Information Security Policy 4
1. Network Security 5
2. Acceptable Use Policy 5
3. Protect Stored Data 5
4. Information Classification 6
5. Access to the Sensitive Cardholder Data 6
6. Physical Security 7
7. Protect Data in Transit 7
8. Disposal of Stored Data 8
9. Security Awareness and Procedures 8
10. Credit Card (PCI) Security Incident Response Plan 9
11. Transfer of Sensitive Information Policy 13
12. User Access Management 13
13. Access Control Policy 14
Appendix A – Agreement to Comply Form – Agreement to Comply With Information Security Policies 16
Appendix B – List of Devices 17
This Policy document encompasses all aspects of security surrounding confidential company information and must be distributed to all company employees. All company employees must read this document in its entirety and sign the form confirming they have read and fully understand this policy. This document will be reviewed and updated by Management on an annual basis or when relevant to include newly developed security standards into the policy and re-
Information Security Policy
Employees handling sensitive cardholder data should ensure:
l Handle Company and cardholder information in a manner that fits with their sensitivity and classification;
l Limit personal use of E-
l Do not use e-
l Do not disclose personnel information unless authorised;
l Protect sensitive cardholder information;
l Keep passwords and accounts secure;
l Request approval from management prior to establishing any new software or hardware, third party connections, etc.;
l Do not install unauthorised software or hardware, including modems and wireless access unless you have explicit management approval;
l Always leave desks clear of sensitive cardholder data and lock computer screens when unattended;
l Information security incidents must be reported, without delay, to the individual responsible for incident response locally – Please find out who this is.
We each have a responsibility for ensuring our company’s systems and data are protected from unauthorised access and improper use. If you are unclear about any of the policies detailed herein you should seek advice and guidance from your line manager.
1. Network Security
In addition, ASV should be performed and completed by a PCI SSC Approved Scanning Vendor, where applicable. Evidence of these scans should be maintained for a period of 18 months.
2. Acceptable Use Policy
Management’s intentions for publishing an Acceptable Use Policy are not to impose restrictions that are contrary to E-
• Employees are responsible for exercising good judgment regarding the reasonableness of personal use.
• Employees should take all necessary steps to prevent unauthorized access to confidential data which includes card holder data.
• Keep passwords secure and do not share accounts. Authorized users are responsible for the security of their passwords and accounts.
• All PCs, laptops and workstations should be secured with a password-
• All POS and PIN entry devices should be appropriately protected and secured so they cannot be tampered or altered.
• The List of Devices in Appendix B will be regularly updated when devices are modified, added or decommissioned. A stock take of devices will be regularly performed and devices inspected to identify any potential tampering or substitution of devices.
• Users should be trained in the ability to identify any suspicious behaviour where any tampering or substitution may be performed. Any suspicious behaviour will be reported accordingly.
• Information contained on portable computers is especially vulnerable, special care should be exercised.
• Postings by employees from a Company email address to newsgroups should contain a disclaimer stating that the opinions expressed are strictly their own and not necessarily those of E-
• Employees must use extreme caution when opening e-
3. Protect Stored Data
• All sensitive cardholder data stored and handled by E-
• If there is no specific need to see the full PAN (Permanent Account Number), it has to be masked when displayed.
• PAN'S which are not protected as stated above should not be sent to the outside network via end user messaging technologies like chats, ICQ messenger etc.,
It is strictly prohibited to store:
1. The contents of the payment card magnetic stripe (track data) on any media whatsoever.
2. The CVV/CVC (the 3 or 4 digit number on the signature panel on the reverse of the payment card) on any media whatsoever.
3. The PIN or the encrypted PIN Block under any circumstance.
4. Information Classification
Data and media containing data must always be labelled to indicate sensitivity level.
• Confidential data might include information assets for which there are legal requirements for preventing disclosure or financial penalties for disclosure, or data that would cause severe damage to E-
• Internal Use data might include information that the data owner feels should be protected to prevent unauthorized disclosure.
• Public data is information that may be freely disseminated.
5. Access to the Sensitive Cardholder Data
All Access to sensitive cardholder should be controlled and authorised. Any job functions that require access to cardholder data should be clearly defined.
• Any display of the card holder should be restricted at a minimum to the first 6 and the last 4 digits of the cardholder data.
• Access to sensitive cardholder information such as PAN’s, personal information and business data is restricted to employees that have a legitimate need to view such information.
• No other employees should have access to this confidential data unless they have a genuine business need.
• If cardholder data is shared with a Service Provider (3rd party) then a list of such Service Providers will be maintained as detailed in Appendix C.
6. Physical Security
Access to sensitive information in both hard and soft media format must be physically restricted to prevent unauthorised individuals from obtaining sensitive data.
• Media is defined as any printed or handwritten paper, received faxes, floppy disks, back-
• Media containing sensitive cardholder information must be handled and distributed in a secure manner by trusted individuals.
• Visitors must always be escorted by a trusted employee when in areas that hold sensitive cardholder information.
• Procedures must be in place to help all personnel easily distinguish between employees and visitors, especially in areas where cardholder data is accessible. “Employee” refers to full-
• A list of devices that accept payment card data should be maintained.
• The list should include make, model and location of the device.
• The list should have the serial number or a unique identifier of the device
• The list should be updated when devices are added, removed or relocated
• POS devices surfaces are periodically inspected to detect tampering or substitution.
• Personnel using the devices should be trained and aware of handling the POS devices
• Personnel using the devices should verify the identity of and=y third party personnel claiming to repair or run maintenance tasks on the devices, install new devices or replace devices.
• Personnel using the devices should be trained to report suspicious behaviour and indications of tampering of the devices to the appropriate personnel. E-
• Strict control is maintained over the external or internal distribution of any media containing card holder data and has to be approved by management
• Strict control is maintained over the storage and accessibility of media
• All computer that store sensitive cardholder data must have a password protected screen saver enabled to prevent unauthorised use.
7. Protect Data in Transit
All sensitive cardholder data must be protected securely if it is to be transported physically or electronically.
• Card holder data (PAN, track data, etc.) must never be sent over the internet via email, instant chat or any other end user technologies.
• If there is a business justification to send cardholder data via email or by any other mode then it should be done after authorization and by using a strong encryption mechanism (i.e. – AES encryption, PGP encryption, SSL, TLS, IPSEC, etc.).
• The transportation of media containing sensitive cardholder data to another location must be authorised by management, logged and inventoried before leaving the premises. Only secure courier services may be used for the transportation of such media. The status of the shipment should be monitored until it has been delivered to its new location.
8. Disposal of Stored Data
• All data must be securely disposed of when no longer required by E-
• An automatic process must exist to permanently delete on-
• All hard copies of cardholder data must be manually destroyed when no longer required for valid and justified business reasons. A quarterly process must be in place to confirm that all non-
o All cardholder data on electronic media must be rendered unrecoverable when deleted e.g. through degaussing or electronically wiped using military grade secure deletion processes or the physical destruction of the media;
o If secure wipe programs are used, the process must define the industry accepted standards followed for secure deletion.
• All cardholder information awaiting destruction must be held in lockable storage containers clearly marked “To Be Shredded” -
9. Security Awareness and Procedures
The policies and procedures outlined below must be incorporated into company practice to maintain a high level of security awareness. The protection of sensitive data demands regular training of all employees and contractors.
• Review handling procedures for sensitive information and hold periodic security awareness meetings to incorporate these procedures into day to day company practice.
• Distribute this security policy document to all company employees to read. It is required that all employees confirm that they understand the content of this security policy document by signing an acknowledgement form (see Appendix A).
• All employees that handle sensitive information will undergo background checks (such as criminal and credit record checks, within the limits of the local law) before they commence their employment with E-
• All third parties with access to credit card account numbers are contractually obligated to comply with card association security standards (PCI/DSS).
• Company security policies must be reviewed annually and updated as needed.
10. Credit Card (PCI) Security Incident Response Plan
1. Each department must report an incident to the Information Security Officer (preferably) or to another member of the PCI Response Team.
2. That member of the team receiving the report will advise the PCI Response Team of the incident.
3. The PCI Response Team will investigate the incident and assist the potentially compromised department in limiting the exposure of cardholder data and in mitigating the risks associated with the incident.
4. The PCI Response Team will resolve the problem to the satisfaction of all parties involved, including reporting the incident and findings to the appropriate parties (credit card associations, credit card processors, etc.) as necessary.
5. The PCI Response Team will determine if policies and processes need to be updated to avoid a similar incident in the future, and whether additional safeguards are required in the environment where the incident occurred, or for the institution.
Information Security Officer
Collections & Merchant Services
Information Security PCI Incident Response Procedures:
• A department that reasonably believes it may have an account breach, or a breach of cardholder information or of systems related to the PCI environment in general, must inform E-
Incident Response Notification
Escalation – First Level:
Information Security Officer Controller
Executive Project Director for Credit Collections and Merchant Services Legal Counsel
Director of E-
Escalation – Second Level:
Auxiliary members as needed
External Contacts (as needed)
Merchant Provider Card Brands
Internet Service Provider (if applicable)
Internet Service Provider of Intruder (if applicable) Communication Carriers (local and long distance) Business Partners
External Response Team as applicable (CERT Coordination Centre 1, etc) Law Enforcement Agencies as applicable inn local jurisdiction
In response to a systems compromise, the PCI Response Team and designees will:
1. Ensure compromised system/s is isolated on/from the network.
2. Gather, review and analyze the logs and related information from various central and local safeguards and security controls
3. Conduct appropriate forensic analysis of compromised system.
4. Contact internal and external departments and entities as appropriate.
5. Make forensic and log analysis available to appropriate law enforcement or card industry security personnel, as required.
6. Assist law enforcement and card industry security personnel in investigative processes, including in prosecutions.
The credit card companies have individually specific requirements that the Response Team must address in reporting suspected or confirmed breaches of cardholder data. See below for these requirements.
Incident Response notifications to various card schemes
1. In the event of a suspected security breach, alert the information security officer or your line manager immediately.
2. The security officer will carry out an initial investigation of the suspected security breach.
3. Upon confirmation that a security breach has occurred, the security officer will alert management and begin informing all relevant parties that may be affected by the compromise.
If the data security compromise involves credit card account numbers, implement the following procedure:
• Shut down any systems or processes involved in the breach to limit the extent, and prevent further exposure.
• Alert all affected parties and authorities such as the Merchant Bank (your Bank), Visa Fraud Control, and the law enforcement.
• Provide details of all compromised or potentially compromised card numbers to Visa Fraud Control within 24 hrs.
• For more Information visit: http://usa.visa.com/business/accepting_visa/ops_risk_management/cisp_if_ compromised.html
Visa Incident Report Template
This report must be provided to VISA within 14 days after initial report of incident to VISA. The following report content and standards must be followed when completing the incident report. Incident report must be securely distributed to VISA and Merchant Bank. Visa will classify the report as “VISA Secret”*.
I. Executive Summary
a. Include overview of the incident
b. Include RISK Level(High, Medium, Low)
c. Determine if compromise has been contained
III. Initial Analysis
IV. Investigative Procedures
a. Include forensic tools used during investigation
a. Number of accounts at risk, identify those stores and compromised
b. Type of account information at risk
c. Identify ALL systems analyzed. Include the following:
• Domain Name System (DNS) names
• Internet Protocol (IP) addresses
• Operating System (OS) version
• Function of system(s)
d. Identify ALL compromised systems. Include the following:
• DNS names
• IP addresses
• OS version
• Function of System(s)
e. Timeframe of compromise
f. Any data exported by intruder
g. Establish how and source of compromise
h. Check all potential database locations to ensure that no CVV2, Track 1 or Track 2 data is stored anywhere, whether encrypted or unencrypted (e.g., duplicate or backup tables or databases, databases used in development, stage or testing environments, data on software engineers’ machines, etc.)
i. If applicable, review VisaNet endpoint security and determine risk
VI. Compromised Entity Action
VIII. Contact(s) at entity and security assessor performing investigation
*This classification applies to the most sensitive business information, which is intended for use within VISA. Its unauthorized disclosure could seriously and adversely impact VISA, its employees, member banks, business partners, and/or the Brand.
Master Card Steps:
I. Within 24 hours of an account compromise event, notify the MasterCard Compromised Account Team via phone at 1-
II. Provide a detailed written statement of fact about the account compromise (including the contributing circumstances) via secured e-
III. Provide the MasterCard Merchant Fraud Control Department with a complete list of all known compromised account numbers.
IV. Within 72 hours of knowledge of a suspected account compromise, engage the services of a data security firm acceptable to MasterCard to assess the vulnerability of the compromised data and related systems (such as a detailed forensics evaluation).
V. Provide weekly written status reports to MasterCard, addressing open questions and issues until the audit is complete to the satisfaction of MasterCard.
VI. Promptly furnish updated lists of potential or known compromised account numbers, additional documentation, and other information that MasterCard may request.
VII. Provide finding of all audits and investigations to the MasterCard Merchant Fraud Control department within the required time frame and continue to address any outstanding exposure or recommendation until resolved to the satisfaction of MasterCard.
Once MasterCard obtains the details of the account data compromise and the list of compromised account numbers, MasterCard will:
1. Identify the issuers of the accounts that were suspected to have been compromised and group all known accounts under the respective parent member IDs.
2. Distribute the account number data to its respective issuers.
Employees of E-
Discover Card Steps
I. Within 24 hours of an account compromise event, notify Discover Fraud Prevention at (800) 347-
II. Prepare a detailed written statement of fact about the account compromise including the contributing circumstances
III. Prepare a list of all known compromised account numbers
IV. Obtain additional specific requirements from Discover Card
American Express Steps
I. Within 24 hours of an account compromise event, notify American Express Merchant Services at (800) 528-
II. Prepare a detailed written statement of fact about the account compromise including the contributing circumstances
III. Prepare a list of all known compromised account numbers Obtain additional specific requirements from American Express
11. Transfer of Sensitive Information Policy
• All third-
• All third-
• All third-
1. Adhere to the PCI DSS security requirements.
2. Acknowledge their responsibility for securing the Card Holder data.
3. Acknowledge that the Card Holder data must only be used for assisting the completion of a transaction, supporting a loyalty program, providing a fraud control service or for uses specifically required by law.
4. Have appropriate provisions for business continuity in the event of a major disruption, disaster or failure.
5. Provide full cooperation and access to conduct a thorough security review after a security intrusion by a Payment Card industry representative, or a Payment Card industry approved third party.
12. User Access Management
• Access to Company is controlled through a formal user registration process beginning with a formal notification from HR or from a line manager.
• Each user is identified by a unique user ID so that users can be linked to and made responsible for their actions. The use of group IDs is only permitted where they are suitable for the work carried out.
• There is a standard level of access; other services can be accessed when specifically authorized by HR/line management.
• The job function of the user decides the level of access the employee has to cardholder data
• A request for service must be made in writing (email or hard copy) by the newcomer’s line manager or by HR. The request is free format, but must state:
Name of person making request;
Job title of the newcomers and workgroup;
Services required (default services are: MS Outlook, MS Office and Internet access).
• Each user will be given a copy of their new user form to provide a written statement of their access rights, signed by an IT representative after their induction procedure. The user signs the form indicating that they understand the conditions of access.
• Access to all E-
• As soon as an individual leaves E-
• As part of the employee termination process HR (or line managers in the case of contractors) will inform IT operations of all leavers and their date of leaving.
13. Access Control Policy
• Access Control systems are in place to protect the interests of all users of E-
• Generic or group IDs shall not normally be permitted, but may be granted under exceptional circumstances if sufficient other controls on access are in place.
• The allocation of privilege rights (e.g. local administrator, domain administrator, super-
• Access rights will be accorded following the principles of least privilege and need to know.
• Every user should attempt to maintain the security of data at its classified level even if technical security mechanisms fail or are absent.
• Users electing to place information on digital media or storage devices or maintaining a separate database must only do so where such an action is in accord with the data’s classification.
• Users are obligated to report instances of non-
• Access to E-
• No access to any E-
• Password issuing, strength requirements, changing and control will be managed through formal processes. Password length, complexity and expiration times will be controlled through Windows Active Directory Group Policy Objects.
• Access to Confidential, Restricted and Protected information will be limited to authorised persons whose job responsibilities require it, as determined by the data owner or their designated representative. Requests for access permission to be granted, changed or revoked must be made in writing.
• Users are expected to become familiar with and abide by E-
• Access for remote users shall be subject to authorization by IT Services and be provided in accordance with the Remote Access Policy and the Information Security Policy. No uncontrolled external access shall be permitted to any network device or networked system.
• Access to data is variously and appropriately controlled according to the data classification levels described in the Information Security Management Policy.
• Access control methods include logon access rights, Windows share and NTFS permissions, user account privileges, server and workstation access rights, firewall permissions, IIS intranet/extranet authentication rights, SQL database rights, isolated networks and other methods as necessary.
• A formal process shall be conducted at regular intervals by system owners and data owners in conjunction with IT Services to review users’ access rights. The review shall be logged and IT Services shall sign off the review to give authority for users’ continued access rights.
Appendix A – Agreement to Comply Form – Agreement to Comply With Information Security Policies
I agree to take all reasonable precautions to assure that company internal information, or information that has been entrusted to E-
I have access to a copy of the Information Security Policies, I have read and understand these policies, and I understand how it impacts my job. As a condition of continued employment, I agree to abide by the policies and other requirements found in E-
I also agree to promptly report all violations or suspected violations of information security policies to the designated security officer.
Appendix B – List of Devices
Asset/Device Name Description Owner/Approved User Location
Appendix C -
Name of Service Provider Contact Details Services Provided PCI DSS Compliant PCI DSS Validation Date 26/03/15
Manufacturing Electronic Cigarettes since 2007