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PCI and the IBM i: If You're Not Paying Attention, You Should Be

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Does your company accept credit-card payments? If so, you're responsible for Payment Card Industry (PCI) mandates.

 

Just because you run the world's most secure and reliable computing platform (the IBM i, System i, iSeries, AS/400), you're not exempt from the requirements of the international security council that dictates merchant security. Although the many best practices we employ on the IBM midrange platform generally keep the system out of the news, you still must be compliant with the industry standards.

 

We will refrain from listing the recent data breaches, knowing that you're aware of the risk you take when you store cardholder data. So, in this short article, we will address the following questions:

  • Who must comply?
  • What are the levels of compliance?
  • Where are the i-specific resources?
  • Is this an ongoing process?
  • How do I get started?

Who Must Comply?

If you touch credit card account numbers in any way, you are required to be PCI-compliant. Your other clue is that your organization has a formal "Merchant Agreement" with a bank and an acquirer, a network, or a processor. The federally-chartered bank that is in the background handling your transactions may be hidden by an agreement with an "Independent Sales Organization," many of which specialize in industry verticals. But that bank is there, and it's shouldering the risk of your cardholder data-handling practices. We generally refer to the entity with which you have the agreement as the "acquirer," as it acquires the transactions from you, then acquires the funds from the card-issuing bank of your customer, and finally deposits those funds, minus their fee, into your "merchant depository account."

 

Regardless of the bank's responsibilities, if you have a Merchant Agreement to allow you to submit card transactions for payment, you are, by the content of the Agreement, responsible to be PCI-compliant. The level of compliance is technically controlled by the acquirer, and you must at least do what they require.

 

Regrettably, some acquirers require only a bare minimum from their merchants. Since this author is not a lawyer or a PCI Qualified Security Assessor, the following opinions should be validated independently. Suppose a merchant follows only the minimal requirements of the acquirer and suffers a data loss. If they cannot document that they are adhering to the Industry Best Practices, as defined in the PCI Data Security Standard (current Version 3.0), they are certainly ethically negligent. The documents can be found here.

 

Understand, the PCI Data Security Standard (DSS) is accepted as the definitive best practices documentation and is a shield behind which merchants can defend their IT operations. Were you to attempt to have the standards written for you by an independent security auditor, you would be spending many tens of thousands for something the PCI provides for free. More on that later.

 

020915Chandler 1

Figure 1: These are the PCI's 12 mandates.

 

Of particular interest in the table of mandates is number 10, requiring that merchants track and monitor all access to cardholder data. That means that just encrypting the cardholder data is not compliance. This dovetails with the other details not shown in this high-level chart, which require you to monitor the systems that touch the cardholder data.

 

Additionally, according to the PCI and the banking industry definition, if you "process, store, or transmit" credit card data, you are "in scope" and required to be PCI-compliant. Note the use of the "or." If you do any one or more of the three, you are in scope. And the word "process" refers to the handling, in any fashion, of the card datameaning if you key it into a green-screen app, if you swipe it into a green-screen Point-of-Sale program, or if you key it into a browser application. All handling of the card data, in any way, is considered "processing."

 

What Are the Levels of Compliance?

To insure that the PCI has the greatest impact on security in the real world, the organization has targeted the highest-volume merchants with the most stringent requirements. The following table shows the Visa merchant levels that are generally accepted as the governing standard.

 

 

Level / Tier1

Merchant Criteria

Validation Requirements

1

Merchants processing over 6 million Visa transactions annually (all channels) or Global merchants identified as Level 1 by any Visa region 2

  • Annual Report on Compliance ("ROC") by Qualified Security Assessor ("QSA") or Internal Auditor if signed by officer of the company
  • The internal auditor is highly recommended to obtain the PCI SSC Internal Security Assessor ("ISA") certification
  • Quarterly network scan by Approved Scan Vendor ("ASV")
  • Attestation of Compliance Form

2

Merchants processing 1 million to 6 million Visa transactions annually (all channels)

  • Annual Self-Assessment Questionnaire ("SAQ")
  • Quarterly network scan by ASV
  • Attestation of Compliance Form

3

Merchants processing 20,000 to 1 million Visa e-commerce transactions annually

  • Annual SAQ
  • Quarterly network scan by ASV
  • Attestation of Compliance Form

4

Merchants processing less than 20,000 Visa e-commerce transactions annually and all other merchants processing up to 1 million Visa transactions annually

  • Annual SAQ recommended
  • Quarterly network scan by ASV if applicable
  • Compliance validation requirements set by merchant bank

1 - Compromised entities may be escalated at regional discretion 
2 – Merchant meeting Level 1 criteria in any Visa country/region that operates in more than one country/region is considered a global Level 1 merchant. Exception may apply to global merchants if no common infrastructure and if Visa data is not aggregated across borders; in such cases merchant validates according to regional levels.

 

Note that at level 4, the very minimum for any merchant, an Annual Self-Assessment Questionnaire (SAQ) is recommended. Would you want to be standing up in court after a data loss and defending your decision to not perform an Annual SAQ when it is clearly "recommended"? Would it cast doubt on you and your organization that you chose to not adhere to the Industry Best Practices? Do you think you could make a compelling argument that ignoring that recommendation had nothing to do with your data loss?

 

Where Are the i-Specific Resources?

In the previous topic, we referred to the Annual Self-Assessment Questionnaire. Two authoritative documents are the basis for your compliance effort. They're available here.

  • PCI DSS V3.0
  • PCI SAQ "D" The SAQ "D" is provided in a Word doc format so you can fill it in and use it to establish your compliance on the 300+ items it covers.

PCI is smart enough to provide multiple SAQ versions, based on your actual involvement with the card data. The "D" in the second item above indicates an assumption that you touch the card data in a workstation, over your network, and/or on your servers. The full delineation of SAQ appropriateness is available here. Check that document to determine the one that covers your specific card data handling methods. For this article, we will continue with the assumption that you handle the card data in your infrastructure that is connected to the System i.

 

Now, to the meat of the issue. If you completely read the documents from the PCI, you will find them surprisingly PC-centric. Yes, most of the world is grappling with security on the insanely insecure Windows, and many are on the only incrementally more secure Linux. Luckily, we are on a "real" computer. However, in our experience, we find that many iSeries/System i/IBM i shops don't take full advantage of the security that runs in the veins of our fabled platform.

 

Often, very basic rules of PCI DSS are violated in common practice. If you think that merely encrypting a card number in your Order Entry system is adequate, think again. Using a group UserID is prohibited, for instance. Password security must be enforced, and periodic change enforced. In fact, there are so many things we could write a book about it. But, why reinvent the wheel? Luckily, Carol Woodbury, one of the original architects of security in i5/OS, actually did write a book about it. Our company has incorporated it into our formal "PCI Implementation Documentation" and included a copy with every purchase of our software. This document, incorporating her book, has been approved by multiple QSAs over the course of our nine years of distributing a secure credit card application.

 

In this wonderful book are many specific tips to implement to bring you up to Carol Woodbury's "Best Practices" standards. She even provides the rationale as to why to do it and what the considerations are.

 

020915Chandler 2 

Figure 2: This is the industry's best book on i security.

 

One area that receives way too little discussion is monitoring. The PCI DSS is very clear that we need to not only secure the systems, but also monitor them and then review the monitoring for anomalies daily. Most people fail to perform that part of the process. PCI says that a monitoring system that can detect anomalies is no good unless some human actually reviews the results. Read about the Target breach for a textbook example of this failure. Just having stuff reported to SNMP, SYSLOG, QSYSOPR MSGQ, or elsewhere is not enough.

 

Luckily, several companies have risen to the challenge and provide excellent monitoring tools that report exceptions. This is a key element of your PCI security strategy. Following are a few of the excellent products available for the task of monitoring and reporting.

Monitoring and Reporting Products

To complete this abbreviated list of applications, we want to point out two that are not IBM i-specific, but they're so valuable that they deserve consideration. Splunk and LogRhythm are two analysis tools that allow you to extract meaningful exception reports from huge volumes of otherwise indecipherable data. This means that if your enterprise contains many systems of different platforms, all within PCI scope, let's say, and they all generate monitoring data in different forms (SYSLOG, SNMP, etc.), you can consolidate that data into one system and generate valuable reports. These reports can even contain exception reporting that was automatically identified by the software. These software programs can learn what good data looks like and automatically notify you of data or activity out of the ordinary.

 

Other i-specific Resources

Is This an Ongoing Process?

Yes, just like painting the Golden Gate Bridge. No, they do not paint the bridge from one end to the other and then start again. They use a three-step process to maintain the bridge. They assess the areas that are in need of paint, they remediate the damage with a team of 34 painters applying 10–30,000 gallons of paint, and then they report on what has been completed. The bridge has been painted completely only three timesin 1937 (when built), in 1965, and in the 1980s.

 

020915Chandler 3

Figure 3: PCI's Continuous Process

 

And, surprisingly, the PCI specifies the same three-step process.

 

  1. Assess — identifying all locations of cardholder data, taking an inventory of your IT assets and business processes for payment card processing and analyzing them for vulnerabilities that could expose cardholder data.
  2. Remediate— fixing identified vulnerabilities, securely removing any unnecessary cardholder data storage, and implementing secure business processes.
  3. Report — documenting assessment and remediation details, and submitting compliance reports to the acquiring bank and card brands you do business with.

Once you engage in the process of securing, you will see it requires ongoing work. For instance, on a non-i topic, each piece of hardware in your organization is required to run the latest firmware, and that constant updating must be performed and documented. That is just one great example of the ongoing process. In "i" terms, this could refer to the requirement to keep your operating system up to date by applying PTFs as they are released by IBM. This process must be documented as to who does it, when, and what was updated. Obviously, the initial step is critical, to assess the need to update, based on maintaining a constant awareness of what is available from IBM FixCentral.

 

How Do I Get Started?

Once you have been sufficiently overwhelmed by the depth and breadth of the SAQ and resolved that there's not enough time in the day/week/year/career to complete it, take comfort in the PCI "Prioritized Approach." That's covered in these two documents:

 

These two fantastic offerings will guide you through the process of completing the SAQ and generally becoming PCI DSS 3.0 compliant with an emphasis on the tasks that yield the greatest security the fastest. Thank you, PCI.

 

Reference Materials

­

Ira Chandler

Ira Chandler is the founder of Curbstone Corporation and has been programming communications software since 1981. Ira wrote the first commercial credit card processing software for the IBM AS/400 in 1993.

 

Currently, more than 300 companies, universities, and government entities have selected the IBM i operating system and Curbstone Card, Ira's company's PCI-security-validated payment server, including MIT, Harvard, WW Norton Publishing, Fisher Scientific, Campbell Hausfeld, Sunbelt Rentals, AdoramaCamera.com, Penn State University, Beneteau Yachts, Hornady, and the U.S. Space & Rocket Center.

 

While Curbstone software is primarily written in RPGLE, Curbstone was the first to publish a commercial PHP application for the System i, the Shopping Cart Pipeline, and remains committed to the PHP language.

 

Ira Chandler can be contacted at 888-844-8533 or ira@curbstone.com (Curbstone.com).

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    Don't miss this chance to take your knowledge of IBM i security beyond the basics.

     

     

  • 5 IBM i Security Quick Wins

    SB PowerTech WC GenericIn today’s threat landscape, upper management is laser-focused on cybersecurity. You need to make progress in securing your systems—and make it fast.
    There’s no shortage of actions you could take, but what tactics will actually deliver the results you need? And how can you find a security strategy that fits your budget and time constraints?
    Join top IBM i security expert Robin Tatam as he outlines the five fastest and most impactful changes you can make to strengthen IBM i security this year.
    Your system didn’t become unsecure overnight and you won’t be able to turn it around overnight either. But quick wins are possible with IBM i security, and Robin Tatam will show you how to achieve them.

  • How to Meet the Newest Encryption Requirements on IBM i

    SB PowerTech WC GenericA growing number of compliance mandates require sensitive data to be encrypted. But what kind of encryption solution will satisfy an auditor and how can you implement encryption on IBM i? Watch this on-demand webinar to find out how to meet today’s most common encryption requirements on IBM i. You’ll also learn:

    • Why disk encryption isn’t enough
    • What sets strong encryption apart from other solutions
    • Important considerations before implementing encryption

     

     

  • Security Bulletin: Malware Infection Discovered on IBM i Server!

    SB PowerTech WC GenericMalicious programs can bring entire businesses to their knees—and IBM i shops are not immune. It’s critical to grasp the true impact malware can have on IBM i and the network that connects to it. Attend this webinar to gain a thorough understanding of the relationships between:

    • Viruses, native objects, and the integrated file system (IFS)
    • Power Systems and Windows-based viruses and malware
    • PC-based anti-virus scanning versus native IBM i scanning

    There are a number of ways you can minimize your exposure to viruses. IBM i security expert Sandi Moore explains the facts, including how to ensure you're fully protected and compliant with regulations such as PCI.

     

     

  • Fight Cyber Threats with IBM i Encryption

    SB PowerTech WC GenericCyber attacks often target mission-critical servers, and those attack strategies are constantly changing. To stay on top of these threats, your cybersecurity strategies must evolve, too. In this session, IBM i security expert Robin Tatam provides a quick recap of IBM i security basics and guides you through some advanced cybersecurity techniques that can help you take data protection to the next level. Robin will cover:

    • Reducing the risk posed by special authorities
    • Establishing object-level security
    • Overseeing user actions and data access

     

     

     

  • 10 Practical IBM i Security Tips for Surviving Covid-19 and Working From Home

    SB PowerTech WC GenericNow that many organizations have moved to a work from home model, security concerns have risen.

    During this session Carol Woodbury will discuss the issues that the world is currently seeing such as increased malware attacks and then provide practical actions you can take to both monitor and protect your IBM i during this challenging time.

     

  • How to Transfer IBM i Data to Microsoft Excel

    SB_HelpSystems_WC_Generic3 easy ways to get IBM i data into Excel every time
    There’s an easy, more reliable way to import your IBM i data to Excel? It’s called Sequel. During this webinar, our data access experts demonstrate how you can simplify the process of getting data from multiple sources—including Db2 for i—into Excel. Watch to learn how to:

    • Download your IBM i data to Excel in a single step
    • Deliver data to business users in Excel via email or a scheduled job
    • Access IBM i data directly using the Excel add-in in Sequel

    Make 2020 the year you finally see your data clearly, quickly, and securely. Start by giving business users the ability to access crucial business data from IBM i the way they want it—in Microsoft Excel.

     

     

  • HA Alternatives: MIMIX Is Not Your Only Option on IBM i

    SB_HelpSystems_WC_GenericIn this recorded webinar, our experts introduce you to the new HA transition technology available with our Robot HA software. You’ll learn how to:

    • Transition your rules from MIMIX (if you’re happy with them)
    • Simplify your day-to-day activities around high availability
    • Gain back time in your work week
    • Make your CEO happy about reducing IT costs

    Don’t stick with a legacy high availability solution that makes you uncomfortable when transitioning to something better can be simple, safe, and cost-effective.

     

     

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  • Backup and Recovery on IBM i: Your Strategy for the Unexpected

    SB HelpSystems SC 5413Robot automates the routine tasks of iSeries backup and recovery, saving you time and money and making the process safer and more reliable. Automate your backups with the Robot Backup and Recovery Solution. Key features include:
    - Simplified backup procedures
    - Easy data encryption
    - Save media management
    - Guided restoration
    - Seamless product integration
    Make sure your data survives when catastrophe hits. Try the Robot Backup and Recovery Solution FREE for 30 days.

  • Manage IBM i Messages by Exception with Robot

    SB HelpSystems SC 5413Managing messages on your IBM i can be more than a full-time job if you have to do it manually. How can you be sure you won’t miss important system events?
    Automate your message center with the Robot Message Management Solution. Key features include:
    - Automated message management
    - Tailored notifications and automatic escalation
    - System-wide control of your IBM i partitions
    - Two-way system notifications from your mobile device
    - Seamless product integration
    Try the Robot Message Management Solution FREE for 30 days.

  • Easiest Way to Save Money? Stop Printing IBM i Reports

    SB HelpSystems SC 5413Robot automates report bursting, distribution, bundling, and archiving, and offers secure, selective online report viewing.
    Manage your reports with the Robot Report Management Solution. Key features include:

    - Automated report distribution
    - View online without delay
    - Browser interface to make notes
    - Custom retention capabilities
    - Seamless product integration
    Rerun another report? Never again. Try the Robot Report Management Solution FREE for 30 days.

  • Hassle-Free IBM i Operations around the Clock

    SB HelpSystems SC 5413For over 30 years, Robot has been a leader in systems management for IBM i.
    Manage your job schedule with the Robot Job Scheduling Solution. Key features include:
    - Automated batch, interactive, and cross-platform scheduling
    - Event-driven dependency processing
    - Centralized monitoring and reporting
    - Audit log and ready-to-use reports
    - Seamless product integration
    Scale your software, not your staff. Try the Robot Job Scheduling Solution FREE for 30 days.

  • ACO MONITOR Manages your IBM i 24/7 and Notifies You When Your IBM i Needs Assistance!

    SB DDL Systems 5429More than a paging system - ACO MONITOR is a complete systems management solution for your Power Systems running IBM i. ACO MONITOR manages your Power System 24/7, uses advanced technology (like two-way messaging) to notify on-duty support personnel, and responds to complex problems before they reach critical status.

    ACO MONITOR is proven technology and is capable of processing thousands of mission-critical events daily. The software is pre-configured, easy to install, scalable, and greatly improves data center efficiency.