As part of Theatre Manager's PA-DSS implementation process, creating a policy guide will be brought to the attention of venues desiring to be PCI compliant
Section | PCI Requirement | Comments | Responsibilities on Artsman Cloud |
12.1 | Establish, publish, maintain, and disseminate a security policy. | This relates to practices surrounding PCI Card data | Artsman: Network Security Policy for Employees/cloud (ams/network-security) Customer: employees & workstations |
12.1.1 | Review the security policy at least annually and update the policy when the environment changes. |
Artsman: cloud
Customer: workstations |
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12.2 | Implement a risk-assessment process that:
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Artsman: cloud
Customer: Review own document |
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12.3 | Develop usage policies for critical technologies and define proper use of these technologies.
Note: Examples of critical technologies include, but are not limited to, remote access and wireless technologies, laptops, tablets, removable electronic media, e-mail usage and Internet usage. Ensure these usage policies require the following: |
Artsman: cloud
Customer: workstations |
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12.3.1 | Explicit approval by authorized parties |
Artsman: cloud
Customer: workstations |
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12.3.2 | Authentication for use of the technology |
Artsman: cloud
Customer: workstations |
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12.3.3 | A list of all such devices and personnel with access | Arts Management allows only tools approved for use by Management on workstations. The customer is responsible for tools on their machines. |
Artsman: cloud
Customer: workstations |
12.3.4 | A method to accurately and readily determine owner, contact information, and purpose (for example, labeling, coding, and/or inventorying of devices) |
Artsman: cloud
Customer: workstations |
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12.3.5 | Acceptable uses of the technology |
Artsman: cloud
Customer: workstations |
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12.3.6 | Acceptable network locations for the technologies |
Artsman: cloud
Customer: workstations |
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12.3.7 | List of company-approved products |
Artsman: cloud
Customer: workstations |
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12.3.8 | Automatic disconnect of sessions for remote access technologies after a specific period of inactivity |
Artsman: cloud
Customer: Workstations have limited login time per System Preferences. |
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12.3.9 | Activation of remote access technologies for vendors only when needed by vendors, with immediate deactivation after use | Team Viewer is designed in exactly this manner.
| Customer: workstations |
12.3.10 | For personnel accessing cardholder data via remote-access technologies, prohibit the copying, moving, and storage of cardholder data onto local hard drives and removable electronic media, unless explicitly authorized for a defined business need.
Where there is an authorized business need, the usage policies must require the data be protected in accordance with all applicable PCI DSS Requirements. |
All card data in the database at rest is encrypted or shredded. All card data in motion is encrypted via TLS 1.2 between machines and enforced by database connection. Reports do not show complete PAN, per PCI compliance
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Customer: responsible for local policies secure storage of paper copies of PAN data and not transmitting to patrons via email. |
12.4 | Ensure that the security policy and procedures clearly define information security responsibilities for all personnel. |
Artsman: cloud
Customer: workstations |
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12.5 | Assign to an individual or team the following information security management responsibilities |
Artsman: cloud
Customer: workstations |
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12.5.1 | Establish, document, and distribute security policies and procedures. | ||
12.5.2 | Monitor and analyze security alerts and information, and distribute to appropriate personnel. | ||
12.5.3 | Establish, document, and distribute security incident response and escalation procedures to ensure timely and effective handling of all situations. | ||
12.5.4 | Administer user accounts, including additions, deletions, and modifications | ||
12.5.5 | Monitor and control all access to data. | ||
12.6 | Implement a formal security awareness program to make all employees aware of the importance of cardholder data security. |
Artsman: this document and staff training
Customer: own staff training |
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12.6.1 | Educate employees upon hire and at least annually.
Note: Methods can vary depending on the role of the personnel and their level of access to the cardholder data. |
Artsman: cloud
Customer: workstations |
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12.6.2 | Require personnel to acknowledge at least annually that they have read and understood the security policy and procedures. | This can be a signed document that they have reviewed the security policy |
Artsman: cloud
Customer: workstations |
12.7 | Screen potential personnel prior to hire to minimize the risk of attacks from internal sources. (Examples of background checks include previous employment history, criminal record, credit history, and reference checks.)
Note: For those potential personnel to be hired for certain positions such as store cashiers who only have access to one card number at a time when facilitating a transaction, this requirement is a recommendation only. |
Artsman: cloud
Customer: workstations |
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12.8 | Maintain and implement policies and procedures to manage service providers with whom cardholder data is shared, or that could affect the security of cardholder data, as follows: | Theatre Manager is designed so that cardholder data cannot be shared with any body. Staff do not have access to card data. | Customer: workstations- inform staff not to share card data |
12.8.1 | Maintain a list of service providers. | We suggest placing them in Theatre Manager and adding them to a mail list called PCI Compliance contacts |
Artsman: cloud
Customer: workstations |
12.8.2 | Maintain a written agreement that includes an acknowledgement that the service providers are responsible for the security of cardholder data the service providers possess or otherwise store, process or transmit on behalf of the customer, or to the extent that they could impact the security of the customer's cardholder data environment.
Note: The exact wording of an acknowledgement will depend on the agreement between the two parties, the details of the service being provided, and the responsibilities assigned to each party. The acknowledgement does not have to include the exact wording provided in this requirement. |
Artsman: cloud
Customer: workstations |
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12.8.3 | Ensure there is an established process for engaging service providers including proper due diligence prior to engagement. |
Artsman: cloud
Customer: workstations |
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12.8.4 | Maintain a program to monitor service providers' PCI DSS compliance status at least annually. | Arts Management is responsible to ensure Theatre Manager is audited for PCI-DSS and approved by the PCI council. |
Artsman: vendor PCI DSS annually
Customer: merchant responsibilities |
12.8.5 | Maintain information about which PCI DSS requirements are managed by each service provider, and which are managed by the entity. | Customer: this document describes areas which Artsman is responsible | |
12.9 | Additional requirement for service providers only: Service providers acknowledge in writing to customers that they are responsible for the security of cardholder data the service provider possesses or otherwise stores, processes, or transmits on behalf of the customer, or to the extent that they could impact the security of the customer's cardholder data environment.
Note: The exact wording of an acknowledgement will depend on the agreement between the two parties, the details of the service being provided, and the responsibilities assigned to each party. The acknowledgement does not have to include th |
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Customer |
12.10 | Implement an incident response plan. Be prepared to respond immediately to a system breach. |
Artsman: cloud
Customer: workstation |
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12.10.1 | Create the incident response plan to be implemented in the event of system breach. Ensure the plan addresses the following, at a minimum:
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12.10.2 | Test the plan at least annually. | ||
12.10.3 | Designate specific personnel to be available on a 24/7 basis to respond to alerts. | ||
12.10.4 | Provide appropriate training to staff with security breach response responsibilities. | ||
12.10.5 | Include alerts from security monitoring systems, including but not limited to intrusion-detection, intrusion- prevention, firewalls, and file-integrity monitoring systems. | ||
12.10.6 | Develop a process to modify and evolve the incident response plan according to lessons learned and to incorporate industry developments. |