Information Security Policy

Purpose:

To establish a credit card Payment Card Industry (PCI) Security Incident Response Plan

I. Credit Card (PCI) Security Incident Response Plan:

The Washington State School for the Blind (WSSB) PCI Security Incident Response Team (PCI Response Team) is comprised of the IT Manager (Information Security Officer), Counsel, Superintendent, Risk Manager, the Director of Business and Finance, Collections & Merchant Services. WSSB’s PCI security incident response plan is as follows:

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.

II. WSSB’s PCI Security Incident Response Team:

• Director of Business and Finance
• IT Manager (Information Security Officer)
• Counsel
• Superintendent
• Collections & Merchant Services
• Risk Manager

III. Information Security PCI Incident Response Procedures:

A department that reasonably believes it may have an account breach, or a breach of card holder information or of systems related to the PCI environment in general, must inform WSSB’s PCI Incident Response Team. After being notified of a compromise, the PCI Response Team, along with other designated staff, will implement the PCI Incident Response Plan to assist and augment departments’ response plans.

IV. Incident Response Notification

Escalation Members:

Escalation-First Level

• Information Security Officer
• Director of Business & Finance and Merchant Services
• Legal Counsel
• Risk Manager

Escalation-Second Level

• Superintendent
• Auxiliary members as needed

External Contacts (as needed)

• Merchant Provider Card
• Internet Service Provider (if applicable)
• Internet Service Provider of Intruder (if applicable)
• Insurance Carrier
• External Agencies as applicable in local jurisdiction

V. 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.

VI. 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.

VII. VISA Steps

If the data security compromise involves credit card account numbers, implement the following procedures:

1. Immediately contain and limit the exposure. Minimize data loss and prevent the further loss of data by conducting a thorough investigation of the suspected or confirmed compromise of information. Compromised entities should consult with their internal incident response team. To preserve evidence and facilitate the investigation:
   - Do not access or alter compromised system(s) (i.e., do not log on at all to the compromised system(s) and change passwords; do not log in as ROOT). Visa highly recommends compromised system(s) not be used to avoid losing critical volatile data.
   - Do not turn the compromised system(s) off. Instead, isolate compromised systems(s) from the network (i.e., unplug network cable).
   - Preserve evidence and logs (i.e., original evidence, security events, web, database, firewall, etc.)
   - Document all actions taken.
   - If using a wireless network, change the Service Set Identifier (SSID) on the wireless access point (WAP) and other systems that may be using this connection (with the exception of any systems believed to be compromised).
   - Be on high alert and monitor traffic on all systems with cardholder data.
2. Alert all necessary parties immediately:
   - Your internal incident response team and information security group.
   - If you are a merchant, contact your acquirer.
   - If you do not know the name and/or contact information for your acquirer, notify Visa Incident Response Manager immediately: US U.S. (650) 432-2978 or usfraudcontrol@visa.com
3. Notify the appropriate law enforcement agency. Contact the Visa Incident Response Manager above for assistance in contacting local law enforcement agency.
4. Consult with your legal department to determine if notification laws are applicable.
5. Review Visa’s communication guideline for compromised entities on how to respond to a data breach. There are some good basic communications principles that can be applied to most data breach situations. This guideline is intended to provide some best-practice guidance for compromised entities on how to think about, prepare for and respond to data breaches. You can download a copy of the guideline at www.visa.com in the Merchant Resource library.
6. Provide all compromised Visa, Interlink, and Plus accounts to your acquirer or to Visa within ten business days. All potentially compromised accounts must be provided and transmitted as instructed by the Visa acquiring bank and Visa. Visa will distribute the compromised Visa account numbers to card issuers.
7. Within three business days of the reported compromise, provide an Incident Report to the acquirer or to Visa.
   Note: If Visa deems necessary, an independent forensic investigation by a PCI Forensic Investigator (PFI) will be initiated on the compromised entity. For the PFI listing, go to: https://www.pcisecuritystandards.org/approved_companies_providers/pci_forensic_investigator.php for a list of approved PFIs.

VIII. Visa Incident Report Template

This report must be provided to VISA within 14 days after the 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 Ban.  Visa will classify the report as “VISA Secret”*.

8.1 Executive Summary

1. Include overview of the incident
2. Include RISK level (High, Medium, and Low)
3. Determine if compromise has been contained

8.2 Background

8.3 Initial Analysis

8.4 Investigative Procedures

1. Include forensic tools used during investigation

8.5 Findings

1. Number of accounts at risk. Identify those stores and compromised
2. Type of account information at risk
3. Identify ALL systems analyzed include the following:
   a. DNS names
   b. IP addresses
   c. Function of System(s)

8.6 Timeframe of compromise

8.7 Any data exported by intruder

8.8 Establish how and source of compromise

8.9 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 back up tables or databases, databases used in development, stage or testing environments, data on software engineers’ machines, etc.)

8.10 If applicable, review Visa Net endpoint security and determine risk

8.11 Compromised Entity Action

8.12 Recommendations

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

IX. MasterCard Steps:

1. Within 24 hours of an account compromise event, notify the MasterCard Compromised Account Team via phone at 1-636-722-4100.
2. Provide a detailed written statement of fact about the account compromise (including the    contributing circumstances) via secured e-mail to: Compromised_account_team@mastercard.com.
3. Provide the MasterCard Merchant Fraud Control Department with a complete list of all known compromised account numbers.
4. 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).
5. Provide weekly written status reports to MasterCard, addressing open questions and issues until the audit is complete to the satisfaction of MasterCard.
6. Promptly furnish updated lists of potential or known compromised account numbers, additional documentation, and other information that MasterCard may request.
7. 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.
8. 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 WSSB will be expected to report to the security officer any security related issues. The role of the security officer is to effectively communicate all security policies and procedures to employees within the company and contractors. In addition to this, the security officer will oversee the scheduling of security training sessions, monitor and enforce the security policies outlined in both this document and at the training sessions and finally, oversee the implantation of the incident response plan in the event of a sensitive data compromise.

X. Discover Card Steps

1. Within 24 hours of an account compromise event, notify Discover Fraud Prevention at (800) 347-3102
2. Prepare a detailed written statement of fact about the account compromise including the contributing circumstances
3. Prepare a list of all known compromised account numbers
4. Obtain additional specific requirements from Discover Card

XI. Transfer of Sensitive Information Policy

All third-party companies providing hosting facilities must comply with the Agency’s Physical Security and Access Control Policy.  All third-party companies which have access to Card Holder information must.

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.