Property of the University of Notre Dame Navigating the Regulatory Maze: Notre Dame’s PCI DSS Solution EDUCAUSE Midwest Regional Conference March 17, 2008

Property of the University of Notre Dame Agenda PCI DSS Background Notre Dame’s Environment Payment Card Environment Design Networking Infrastructure Deployment: Departments and Decentralized IT 2

Property of the University of Notre Dame 3 Payment Card Industry Data Security Standard (PCI DSS) Visa Cardholder Information Security Program (CISP) PCI DSS History Mastercard Site Data Protection Program (SDP) Discover Information Security Compliance Program (DISC) American Express Data Security Standard (DSS)

Property of the University of Notre Dame 4 Introducing the Digital Dozen Build and Maintain a Secure Network Install and maintain a firewall configuration to protect cardholder data Do not use vendor-supplied defaults for system passwords and other security parameters Protect Cardholder Data Protect stored cardholder data Encrypt transmission of cardholder data across open, public networks Maintain a Vulnerability Management Program Use and regularly update anti-virus software Develop and maintain secure systems and applications Implement Strong Access Control Measures Restrict access to cardholder data by business need-to-know Assign a unique ID to each person with computer access Restrict physical access to cardholder data Regularly Monitor and Test Networks Track and monitor all access to network resources and cardholder data Regularly test security systems and processes Maintain an Information Security Policy Maintain a policy that addresses information security

Property of the University of Notre Dame 5 Who Must Comply? “Payment Card Industry (PCI) Data Security requirements apply to all Members, merchants, and service providers that store, process or transmit cardholder data.” “Additionally, these security requirements apply to all system components which is defined as any network component, server, or application included in, or connected to, the cardholder data environment.” That Probably Means You

Property of the University of Notre Dame 6 Merchant Levels Merchant Level Description 1Any merchant who processes over 6,000,000 transactions annually. Any merchant designated Level 1 by Visa 2Any merchant who processes between 1,000,000 and 6,000,000 transactions annually. 3Any merchant who processes between 20,000 and 150,000 e-commerce transactions annually. 4Anyone else

Property of the University of Notre Dame 7 Merchant Levels All merchants, regardless of level, must comply with all elements of the PCI DSS standard! Merchants at different levels have different validation requirements

Property of the University of Notre Dame 8 Consequences Reputational Risk – What will the impact be on your institution’s brand? – Mandatory involvement of federal law enforcement in investigation Financial Risk – Merchant banks may pass on substantial fines – Up to $500,000 per incident from Visa alone – Civil liability and cost of providing ID theft protection

Property of the University of Notre Dame 9 Consequences Compliance Risk – Exposure to Level 1 validation requirements Operational Risk – Visa-imposed operational restrictions – Potential loss of card processing privileges

Property of the University of Notre Dame Agenda PCI DSS Background Notre Dame’s Environment Payment Card Environment Design Networking Infrastructure Deployment: Departments and decentralized IT 10

Property of the University of Notre Dame 11 Notre Dame’s Environment, Circa 2006 Over 70 merchant accounts, 15 applications No central oversight One day all of that changed…

Property of the University of Notre Dame 12

Property of the University of Notre Dame 13 Notre Dame’s Approach Conducted a risk assessment in conjunction with a PCI consulting firm From that, launched a credit card security program – First Goal: Minimize on-campus card processing – Second Goal: Migrate existing systems to a dedicated, isolated network First, reduce our footprint and then secure that footprint to the greatest degree possible

Property of the University of Notre Dame Agenda PCI DSS Background Notre Dame’s Environment Payment Card Environment Design Networking Infrastructure Deployment: Departments and decentralized IT 14

Property of the University of Notre Dame Design: ND’s PCI Architecture 15

Property of the University of Notre Dame System and Security Components Firewall and VPN Two factor authentication to infrastructure Tripwire server integrity assurance Juniper IDS POS clients and servers Infrastructure – NTP, DC, ePO, monitoring, KVM, central logging, etc. Device configuration standards

Property of the University of Notre Dame Firewall and IDS design Firewall isolates all PCI traffic Single External Physical interface Single Internal interface with multiple VLANs Zones organized by function Some special zones for campus systems Remote Sites connected through VPN concentrator Passive IDS (tried IPS) monitors all internal traffic

Property of the University of Notre Dame Sidewinder Firewall Application Proxy firewall Default deny inbound and outbound Group based VPN, access restricted by job function Least privilege rule base All access explicitly controlled

Property of the University of Notre Dame Key Internal Zones

Property of the University of Notre Dame Key Internal Zones

Property of the University of Notre Dame Key Internal Zones

Property of the University of Notre Dame Isolating Systems

Property of the University of Notre Dame Isolating Systems

Property of the University of Notre Dame Agenda PCI DSS Background Notre Dame’s Environment Payment Card Environment Design Networking Infrastructure Deployment: Departments and decentralized IT 24

Property of the University of Notre Dame Network Design From the PCI Standards Document: 1.Encryption of data over open, public networks 2.Follow change control procedures 3.Review logs for all system components daily

Property of the University of Notre Dame Challenges Encryption of data over open, public networks. Required over ‘secure’ vlans?

Property of the University of Notre Dame Challenges Follow change control procedures. – Initial design thoughts incorporated ‘secure’ vlans that we present at each endpoint on campus. – This would have involved implementing change control on more than 150 network devices, including access layer switches. Review logs for all system components daily. – On > 150 devices?

Property of the University of Notre Dame Devices requiring change control with ‘secure’ vlan

Property of the University of Notre Dame Our solution: Remote site VPN’s Utilizes Cisco 3015 VPN concentrator with Cisco 851 VPN routers for endpoints. Extends the PCI network where we need it. We provide user subnet space based on customer need: – Stand-alone credit card terminals – POS devices – Single use computers

Property of the University of Notre Dame Additional Benefits of VPN The VPN tunnel provides a secure method of managing network devices. Provides a means of remote access for system administrators Fewer devices to manage. Provides for easier additions to the PCI network.

Property of the University of Notre Dame Agenda PCI DSS Background Notre Dame’s Environment Payment Card Environment Design Networking Infrastructure Deployment: Departments and decentralized IT 31

Property of the University of Notre Dame Deployment: Departments and Decentralized IT 32

Property of the University of Notre Dame Two Types of Support Central IT – Fewer technical users. – Existing payment solutions are often inherited. – Responsibility for payment system is often not clearly defined. Departmental IT – Internal processes and procedures. – Often very small staff, broad responsibilities. – Payment solutions are often provided by external vendors. – Responsibility for payment system is often inherited. 33

Property of the University of Notre Dame Existing systems Food Services – Many terminals – Other services blended in: vending machines, food service displays, and campus “Domer Dollars” – Many locations – Blend of commercial and custom software – Departmental IT Theater Ticketing and Events – Single location – Mobile and static workstations – Web driven – Single commercial software package – Only standard transactions – Central IT 34

Property of the University of Notre Dame Deployment Steps Review existing architecture Design solution Build required resources Test Migrate into production – Often in phases – Often unexpected hurdles due to legacy systems and applications 35

Property of the University of Notre Dame Challenges Process: creating a controlled system for adding new systems and handling changes. Lack of vendor documentation of protocols – many large high port groupings, reliance local broadcast for discovery, etc. Split system administration DR for systems designed without DR capabilities. 36

Property of the University of Notre Dame Lessons Learned Review vendor documentation and current implementation. – Historic designs are often still in use. Dataflow diagrams are crucial. Provide a fast troubleshooting process and a defined support team. Provide a single point of responsibility with backup for migrations. 37

Property of the University of Notre Dame Questions 38