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Card_Prod_Security_Rqrmts_FAQs_v1_March_2015.pdf
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Card_Prod_Security_Rqrmts_FAQs_v1_July_2015.pdf
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Content Changes
64 content changes. 25 administrative changes (dates, page numbers) hidden.
Added
p. 9
Section 8
• Key Management: Secret Data 8.4.1 General Requirements 8.4.1.a) The vendor must define procedures for the transfer of key-management roles between individuals.
Q 16 July 2015: The vendor must define procedures for the transfer of key-management roles between individuals. Does "roles" mean custodian A holder versus a custodian B holder? A No. This is not intended for transfer of roles between existing custodians if it results in a custodian collectively having access to sufficient key components or shares of a secret or private key to reconstruct a cryptographic key. For example, in an m-of-n scheme (which must use a recognized secret-sharing scheme such as Shamir), where only two of any three components are required to reconstruct the cryptographic key, a custodian must not have current or prior knowledge of more than one component. If a custodian was previously assigned component A, which was then reassigned, the custodian must not then …
• Key Management: Secret Data 8.4.1 General Requirements 8.4.1.a) The vendor must define procedures for the transfer of key-management roles between individuals.
Q 16 July 2015: The vendor must define procedures for the transfer of key-management roles between individuals. Does "roles" mean custodian A holder versus a custodian B holder? A No. This is not intended for transfer of roles between existing custodians if it results in a custodian collectively having access to sufficient key components or shares of a secret or private key to reconstruct a cryptographic key. For example, in an m-of-n scheme (which must use a recognized secret-sharing scheme such as Shamir), where only two of any three components are required to reconstruct the cryptographic key, a custodian must not have current or prior knowledge of more than one component. If a custodian was previously assigned component A, which was then reassigned, the custodian must not then …
Added
p. 12
Background check results Verification of aliases (when applicable) List of previous employers and referral follow-up results Education history Social security number or appropriate national identification number Signed document confirming that the employee has read and understands the vendor’s security policies and procedures Fingerprints and results of search against national and regional criminal records Gathered as part of the hiring process and periodically thereafter:
Added
p. 13
Q 3 July 2015: Does the card vendor have to use fingerprints to conduct a search against criminal records as part of the background check process? A A criminal background search must be conducted. That search may use fingerprints or any other method or means of identification.
Added
p. 16
Q 14 December 2013
• Separate rooms within the HSA must meet all of the requirements in
• Separate rooms within the HSA must meet all of the requirements in
Added
p. 18
Q 26 January 2015 - Is it permissible to have an emergency exit from the vault to the HSA if the emergency door meets the strength requirement for a vault door, is alarmed and was not openable from outside?
Q 27 July 2015: Can security mesh be used for vault construction in lieu of reinforced concrete as equivalent to the Underwriters Laboratories (UL) Class 1 Burglary Certification Standard, which provides for at least 30 minutes of penetration resistance? A A) Security mesh is unacceptable unless direct evidence can be provided that it meets the UL 608 Standard for Burglary Resistant Vault Doors and Modular Panels Class 1 criteria. Other UL certifications, such as for fire resistance, are not acceptable as equivalent.
Q 27 July 2015: Can security mesh be used for vault construction in lieu of reinforced concrete as equivalent to the Underwriters Laboratories (UL) Class 1 Burglary Certification Standard, which provides for at least 30 minutes of penetration resistance? A A) Security mesh is unacceptable unless direct evidence can be provided that it meets the UL 608 Standard for Burglary Resistant Vault Doors and Modular Panels Class 1 criteria. Other UL certifications, such as for fire resistance, are not acceptable as equivalent.
Modified
p. 6
Q 9 December 2013
• Section 5.6.2 stipulates criteria that VPNs must meet. Under what circumstances does this criteria apply, and is there differentiation between mobile VPNs and site-to-site VPNs? A The VPN requirements are part of the Remote Access requirements in Section 5.6.Therefore, they apply to the remote administration of networks and system components that comprise the HSA and do not apply to VPNs that are used for other purposes. For example, the VPN requirements apply to administration of …
• Section 5.6.2 stipulates criteria that VPNs must meet. Under what circumstances does this criteria apply, and is there differentiation between mobile VPNs and site-to-site VPNs? A The VPN requirements are part of the Remote Access requirements in Section 5.6.
Q 9 December 2013
• Section 5.6.2 stipulates criteria that VPNs must meet. Under what circumstances does this criteria apply, and is there differentiation between mobile VPNs and site-to-site VPNs? A The VPN requirements are part of the Remote Access requirements in Section 5.6.
• Section 5.6.2 stipulates criteria that VPNs must meet. Under what circumstances does this criteria apply, and is there differentiation between mobile VPNs and site-to-site VPNs? A The VPN requirements are part of the Remote Access requirements in Section 5.6.
Modified
p. 9
Q 16 July 2014 - If the key manager is also a key custodian, can other key custodians report to the key manager? A Other key custodians must not report to the key manager if in conjunction with the key manager that would form a threshold to create a key.
Q 17 July 2014 - If the key manager is also a key custodian, can other key custodians report to the key manager? A Other key custodians must not report to the key manager if in conjunction with the key manager that would form a threshold to create a key.
Modified
p. 9
Q 17 December 2013
• Are there any alternatives to meet this requirement for when the authorized custodian is unavailable? Yes, if the primary custodian is unavailable, a pre-designated and authorized backup custodian can receive the package. Alternatively, drop boxes can be used for the courier to leave the package in a locked container that is only accessible by the primary and backup custodians.
• Are there any alternatives to meet this requirement for when the authorized custodian is unavailable? Yes, if the primary custodian is unavailable, a pre-designated and authorized backup custodian can receive the package. Alternatively, drop boxes can be used for the courier to leave the package in a locked container that is only accessible by the primary and backup custodians.
Q 18 December 2013
• Are there any alternatives to meet this requirement for when the authorized custodian is unavailable? Yes, if the primary custodian is unavailable, a pre-designated and authorized backup custodian can receive the package. Alternatively, drop boxes can be used for the courier to leave the package in a locked container that is only accessible by the primary and backup custodians.
• Are there any alternatives to meet this requirement for when the authorized custodian is unavailable? Yes, if the primary custodian is unavailable, a pre-designated and authorized backup custodian can receive the package. Alternatively, drop boxes can be used for the courier to leave the package in a locked container that is only accessible by the primary and backup custodians.
Modified
p. 9 → 10
Q 18 October 2014 - What specifically is the requirement regarding the signature of a custodian being placed on the access logs? Does it require the full name (first and last) or can the signature be first initial and last name or only be the initials of the custodians? A Signatures must be sufficient to identify each custodian. Full names or initials or any combination are acceptable as long as it can be positively affirmed who provided the signature.
Q 19 October 2014 - What specifically is the requirement regarding the signature of a custodian being placed on the access logs? Does it require the full name (first and last) or can the signature be first initial and last name or only be the initials of the custodians? A Signatures must be sufficient to identify each custodian. Full names or initials or any combination are acceptable as long as it can be positively affirmed who provided the signature.
Modified
p. 10
Q 19 July 2014
•Can vendor and issuer keys exist at another site, such as for subcontracted card production activities, or for disaster recovery purposes? A Copies of keys at another site (e.g. Issuer keys or personalization keys) may exist if there is a contract with that site e.g., if they are subcontracting the personalization activity to that site. This subcontracting needs the written permission of the issuer(s) impacted. For disaster recovery purposes, the same conditions apply. There must be a …
•Can vendor and issuer keys exist at another site, such as for subcontracted card production activities, or for disaster recovery purposes? A Copies of keys at another site (e.g. Issuer keys or personalization keys) may exist if there is a contract with that site e.g., if they are subcontracting the personalization activity to that site. This subcontracting needs the written permission of the issuer(s) impacted. For disaster recovery purposes, the same conditions apply. There must be a …
Q 20 July 2014
•Can vendor and issuer keys exist at another site, such as for subcontracted card production activities, or for disaster recovery purposes? A Copies of keys at another site (e.g. Issuer keys or personalization keys) may exist if there is a contract with that site e.g., if they are subcontracting the personalization activity to that site. This subcontracting needs the written permission of the issuer(s) impacted. For disaster recovery purposes, the same conditions apply. There must be a …
•Can vendor and issuer keys exist at another site, such as for subcontracted card production activities, or for disaster recovery purposes? A Copies of keys at another site (e.g. Issuer keys or personalization keys) may exist if there is a contract with that site e.g., if they are subcontracting the personalization activity to that site. This subcontracting needs the written permission of the issuer(s) impacted. For disaster recovery purposes, the same conditions apply. There must be a …
Modified
p. 10
Q 20 July 2013
• Can the same transport keys be used between the card vendor and separate locations of another organization? A No, each location would constitute a separate key zone and therefore different transport keys must be used. The same is true for a card vendor with multiple locations communicating to one or more locations of another organizational entity.
• Can the same transport keys be used between the card vendor and separate locations of another organization? A No, each location would constitute a separate key zone and therefore different transport keys must be used. The same is true for a card vendor with multiple locations communicating to one or more locations of another organizational entity.
Q 21 July 2013
• Can the same transport keys be used between the card vendor and separate locations of another organization? A No, each location would constitute a separate key zone and therefore different transport keys must be used. The same is true for a card vendor with multiple locations communicating to one or more locations of another organizational entity.
• Can the same transport keys be used between the card vendor and separate locations of another organization? A No, each location would constitute a separate key zone and therefore different transport keys must be used. The same is true for a card vendor with multiple locations communicating to one or more locations of another organizational entity.
Modified
p. 10 → 11
Q 21 December 2013
• Does 8.9.g apply to all IC keys? A No, it does not apply to manufacturer or founder keys. It does apply to other keys such as those used for pre-personalization.
• Does 8.9.g apply to all IC keys? A No, it does not apply to manufacturer or founder keys. It does apply to other keys such as those used for pre-personalization.
Q 22 December 2013
• Does 8.9.g apply to all IC keys? A No, it does not apply to manufacturer or founder keys. It does apply to other keys such as those used for pre-personalization.
• Does 8.9.g apply to all IC keys? A No, it does not apply to manufacturer or founder keys. It does apply to other keys such as those used for pre-personalization.
Modified
p. 10 → 11
Q 22 July 2014
• Does the HSM FIPS/PCI certification include customization of native HSM firmware if the FIPS/PCI mode is not impacted. A If firmware is modified it impacts the approval. However, HSMs may allow customers or integrators to install additional applications where the vendor can show that by permitting this:
• Does the HSM FIPS/PCI certification include customization of native HSM firmware if the FIPS/PCI mode is not impacted. A If firmware is modified it impacts the approval. However, HSMs may allow customers or integrators to install additional applications where the vendor can show that by permitting this:
Q 23 July 2014
• Does the HSM FIPS/PCI certification include customization of native HSM firmware if the FIPS/PCI mode is not impacted. A If firmware is modified it impacts the approval. However, HSMs may allow customers or integrators to install additional applications where the vendor can show that by permitting this:
• Does the HSM FIPS/PCI certification include customization of native HSM firmware if the FIPS/PCI mode is not impacted. A If firmware is modified it impacts the approval. However, HSMs may allow customers or integrators to install additional applications where the vendor can show that by permitting this:
Removed
p. 12
• Background check results
• Verification of aliases (when applicable)
• List of previous employers and referral follow-up results
• Social security number or appropriate national identification number
• Signed document confirming that the employee has read and understands the vendor’s security policies and procedures
• Fingerprints and results of search against national and regional criminal records Gathered as part of the hiring process and periodically thereafter:
• Record of any arrests or convictions, updated annually
• Annual credit checks
• Verification of aliases (when applicable)
• List of previous employers and referral follow-up results
• Social security number or appropriate national identification number
• Signed document confirming that the employee has read and understands the vendor’s security policies and procedures
• Fingerprints and results of search against national and regional criminal records Gathered as part of the hiring process and periodically thereafter:
• Record of any arrests or convictions, updated annually
• Annual credit checks
Modified
p. 12
Current photograph, updated at least every three years Record of any arrests or convictions, updated annually Annual credit checks
Removed
p. 13
• Agent’s role or responsibility
Modified
p. 13
Q 3 December 2013
• Requirement 2.4.1 states that all third-party service providers (for example, suppliers, repair and maintenance staff, and any other external service providers) must meet the same requirements as employees of the card vendor who have access to card products, components, and the high security area (HSA). This includes pre-employment testing, screening, training, termination checks, etc. Does the card vendor have to directly conduct these reviews? A No. The intent of this objective is to ensure that service …
• Requirement 2.4.1 states that all third-party service providers (for example, suppliers, repair and maintenance staff, and any other external service providers) must meet the same requirements as employees of the card vendor who have access to card products, components, and the high security area (HSA). This includes pre-employment testing, screening, training, termination checks, etc. Does the card vendor have to directly conduct these reviews? A No. The intent of this objective is to ensure that service …
Q 4 December 2013
• Requirement 2.4.1 states that all third-party service providers (for example, suppliers, repair and maintenance staff, and any other external service providers) must meet the same requirements as employees of the card vendor who have access to card products, components, and the high security area (HSA). This includes pre-employment testing, screening, training, termination checks, etc. Does the card vendor have to directly conduct these reviews? A No. The intent of this objective is to ensure that service …
• Requirement 2.4.1 states that all third-party service providers (for example, suppliers, repair and maintenance staff, and any other external service providers) must meet the same requirements as employees of the card vendor who have access to card products, components, and the high security area (HSA). This includes pre-employment testing, screening, training, termination checks, etc. Does the card vendor have to directly conduct these reviews? A No. The intent of this objective is to ensure that service …
Modified
p. 13
Agent’s name, address, and telephone numbers Agent’s role or responsibility
Modified
p. 13
Q 4 July 2014
• In the context of this requirement, what are card-related activities and what activities are allowed for agents or third parties? A Card related activities such as sales and marketing activities are allowed. Agents and third parties must never produce, own or handle cards.
• In the context of this requirement, what are card-related activities and what activities are allowed for agents or third parties? A Card related activities such as sales and marketing activities are allowed. Agents and third parties must never produce, own or handle cards.
Q 5 July 2014
• In the context of this requirement, what are card-related activities and what activities are allowed for agents or third parties? A Card related activities such as sales and marketing activities are allowed. Agents and third parties must never produce, own or handle cards.
• In the context of this requirement, what are card-related activities and what activities are allowed for agents or third parties? A Card related activities such as sales and marketing activities are allowed. Agents and third parties must never produce, own or handle cards.
Modified
p. 13 → 14
Q 5 October 2014 - If a facility has a fence around the whole property, is a separate fence still required around the technical machinery? A Yes, separate access controls are still required. There will be many people who will have access beyond the fence (everyone entering the facility) but who will not be authorized to access the machinery nor do they need to have access to the technical machinery. In general, technical machinery is not protected by a fence …
Q 6 October 2014 - If a facility has a fence around the whole property, is a separate fence still required around the technical machinery? A Yes, separate access controls are still required. There will be many people who will have access beyond the fence (everyone entering the facility) but who will not be authorized to access the machinery nor do they need to have access to the technical machinery. In general, technical machinery is not protected by a fence …
Modified
p. 14
Q 6 December 2013: Are any methods of covering security control room windows allowed, other than those described in 3.3.2.2.q? A Yes. Other mechanisms may be used as long as they achieve the same result of preventing observation to inside the security control room to view the security equipment•e.g., CCTV images.
Q 7 December 2013: Are any methods of covering security control room windows allowed, other than those described in 3.3.2.2.q? A Yes. Other mechanisms may be used as long as they achieve the same result of preventing observation to inside the security control room to view the security equipment•e.g., CCTV images.
Modified
p. 14
Q 7 January 2015: Only card production-related activities shall take place within the HSA. Does this preclude the existence of test and non-production servers and HSMs from existing in the HSA? A Equipment that is purely associated with test activities is not allowed in the HSA. Test (non- production) keys and test (non-production) data cannot be used with production equipment. Cards used for testing that use production keys and/or data must be produced using production equipment.
Q 8 January 2015: Only card production-related activities shall take place within the HSA. Does this preclude the existence of test and non-production servers and HSMs from existing in the HSA? A Equipment that is purely associated with test activities is not allowed in the HSA. Test (non- production) keys and test (non-production) data cannot be used with production equipment. Cards used for testing that use production keys and/or data must be produced using production equipment.
Modified
p. 14
Q 8 December 2013
• Areas in production facilities where card products, components, or data are stored or processed are called high security areas. Section 3.3.3 states that these HSAs must be contiguous if they are within the same building. In some building designs these areas are non-contiguous and retrofitting is prohibitively expensive. Are there any other options? A Yes. HSAs in the same building that are not contiguous may exist provided they are treated physically and logically as separate facilities•i.e., …
• Areas in production facilities where card products, components, or data are stored or processed are called high security areas. Section 3.3.3 states that these HSAs must be contiguous if they are within the same building. In some building designs these areas are non-contiguous and retrofitting is prohibitively expensive. Are there any other options? A Yes. HSAs in the same building that are not contiguous may exist provided they are treated physically and logically as separate facilities•i.e., …
Q 9 December 2013
• Areas in production facilities where card products, components, or data are stored or processed are called high security areas. Section 3.3.3 states that these HSAs must be contiguous if they are within the same building. In some building designs these areas are non-contiguous and retrofitting is prohibitively expensive. Are there any other options? A Yes. HSAs in the same building that are not contiguous may exist provided they are treated physically and logically as separate facilities•i.e., …
• Areas in production facilities where card products, components, or data are stored or processed are called high security areas. Section 3.3.3 states that these HSAs must be contiguous if they are within the same building. In some building designs these areas are non-contiguous and retrofitting is prohibitively expensive. Are there any other options? A Yes. HSAs in the same building that are not contiguous may exist provided they are treated physically and logically as separate facilities•i.e., …
Modified
p. 14 → 15
Q 9 December 2013
• Does this requirement apply to chemical storage areas, cleaner cupboards, and other maintenance/supplies storage? A A space within the HSA may be defined as a cupboard or similar which does not require motion detection if it is not possible for an individual to walk into the space and no longer be visible.
• Does this requirement apply to chemical storage areas, cleaner cupboards, and other maintenance/supplies storage? A A space within the HSA may be defined as a cupboard or similar which does not require motion detection if it is not possible for an individual to walk into the space and no longer be visible.
Q 10 December 2013
• Does this requirement apply to chemical storage areas, cleaner cupboards, and other maintenance/supplies storage? A A space within the HSA may be defined as a cupboard or similar which does not require motion detection if it is not possible for an individual to walk into the space and no longer be visible.
• Does this requirement apply to chemical storage areas, cleaner cupboards, and other maintenance/supplies storage? A A space within the HSA may be defined as a cupboard or similar which does not require motion detection if it is not possible for an individual to walk into the space and no longer be visible.
Modified
p. 14 → 15
Q 10 January (update) 2015 - Is the Access Control Server located in the Security Control Room or in the Server Room? A The activities in the HSA are restricted to card production activities and therefore the access control server cannot be located in the HSA where the Server Room is required to be because for networked systems, only servers directly related to data preparation and personalization are allowed within the HSA.
Q 11 January (update) 2015 - Is the Access Control Server located in the Security Control Room or in the Server Room? A The activities in the HSA are restricted to card production activities and therefore the access control server cannot be located in the HSA where the Server Room is required to be because for networked systems, only servers directly related to data preparation and personalization are allowed within the HSA.
Modified
p. 15
Q 11 July 2013
• Requirement 3.3.4 specifies controls that must be applied to all rooms within the High Security Area (HSA), and Requirement 3.3.5 specifies the following as rooms that may exist within the HSA as:
• Requirement 3.3.4 specifies controls that must be applied to all rooms within the High Security Area (HSA), and Requirement 3.3.5 specifies the following as rooms that may exist within the HSA as:
Q 12 July 2013
• Requirement 3.3.4 specifies controls that must be applied to all rooms within the High Security Area (HSA), and Requirement 3.3.5 specifies the following as rooms that may exist within the HSA as:
• Requirement 3.3.4 specifies controls that must be applied to all rooms within the High Security Area (HSA), and Requirement 3.3.5 specifies the following as rooms that may exist within the HSA as:
Modified
p. 15
Q 12 December 2013: Local regulations or other safety considerations may require the presence of fire doors in the HSA. Are there any special considerations? A Yes. If the HSA contains fire doors and these doors are normally closed or can be manually closed, these doors are subject to the same access controls as any other door that provides access to a room.
Q 13 December 2013: Local regulations or other safety considerations may require the presence of fire doors in the HSA. Are there any special considerations? A Yes. If the HSA contains fire doors and these doors are normally closed or can be manually closed, these doors are subject to the same access controls as any other door that provides access to a room.
Modified
p. 15 → 16
• Separate rooms within the HSA must meet all of the requirements in
Section 3.3.4, with the exception of person-by-person access. If a room cannot or will not be made to meet these requirements, what options exist? A The card vendor has three options:
Modified
p. 15 → 16
Q 14 December 2013
• For purposes of 3.3.4, do elevators, stairwells, closets and glass- enclosed rooms (e.g., conference rooms or other room types) constitute a room? A If an elevator has a door, access to it must be controlled. Stairwells are not a room if they do not have doors. Closets would not be considered a room if a person could not physically enter. However, a storage room with a door is considered a room. Glass-enclosed rooms are also considered …
• For purposes of 3.3.4, do elevators, stairwells, closets and glass- enclosed rooms (e.g., conference rooms or other room types) constitute a room? A If an elevator has a door, access to it must be controlled. Stairwells are not a room if they do not have doors. Closets would not be considered a room if a person could not physically enter. However, a storage room with a door is considered a room. Glass-enclosed rooms are also considered …
Q 15 December 2013
• For purposes of 3.3.4, do elevators, stairwells, closets and glass- enclosed rooms (e.g., conference rooms or other room types) constitute a room? A If an elevator has a door, access to it must be controlled. Stairwells are not a room if they do not have doors. Closets would not be considered a room if a person could not physically enter. However, a storage room with a door is considered a room. Glass-enclosed rooms are also considered …
• For purposes of 3.3.4, do elevators, stairwells, closets and glass- enclosed rooms (e.g., conference rooms or other room types) constitute a room? A If an elevator has a door, access to it must be controlled. Stairwells are not a room if they do not have doors. Closets would not be considered a room if a person could not physically enter. However, a storage room with a door is considered a room. Glass-enclosed rooms are also considered …
Removed
p. 16
Q 17 October 2014 - Are any of these options acceptable to implement in lieu of implementing the controls for separate rooms under this section such as:
• Glass doors without locks and a fully lit room
• Clear plastic flaps hanging from the door
• Glass doors without locks and a fully lit room
• Clear plastic flaps hanging from the door
Modified
p. 16
Q 15 October 2014 - If curtains or similar are used to segment the HSA in subareas, do those subareas constitute rooms for purposes of these requirements. A If visibility into the segmented area is not impaired from the general HSA area (for example: use of clear curtains), then the sub area does not constitute a room and therefore, any requirements pertaining to rooms do not apply for these subareas. When visibility is obstructed (for example: use of opaque curtains) …
Q 16 October 2014 - If curtains or similar are used to segment the HSA in subareas, do those subareas constitute rooms for purposes of these requirements. A If visibility into the segmented area is not impaired from the general HSA area (for example: use of clear curtains), then the sub area does not constitute a room and therefore, any requirements pertaining to rooms do not apply for these subareas. When visibility is obstructed (for example: use of opaque curtains) …
Modified
p. 16
Q 16 October 2014 - If the walls and/or door (s) of the room are glass such that the view is not restricted, does that constitute a room? A Yes it is a room. While glass allows visibility it still restricts access
Q 17 October 2014 - If the walls and/or door (s) of the room are glass such that the view is not restricted, does that constitute a room? A Yes it is a room. While glass allows visibility it still restricts access
Modified
p. 16
Q 18 October 2014 - Are any of these options acceptable to implement in lieu of implementing the controls for separate rooms under this section such as: Glass doors without locks and a fully lit room Clear plastic flaps hanging from the door Swinging or sliding glass doors that do not have any type of closure mechanism A Glass doors without locks and swinging or sliding doors are not acceptable. Clear plastic flaps hanging from the door …
Modified
p. 16
Q 18 December (update) 2013
•What is the rationale for Requirement 3.3.5.b? A The intent is to prevent any single individual being unobserved while within any room within the HSA. This is not a new requirement and was in place under the prior individual payment brand requirements so there should be limited impact on card vendors previously held to payment brand criteria. Toilet rooms that are not fully enclosed and are accessible without opening the door (i.e., sufficient space exists above …
•What is the rationale for Requirement 3.3.5.b? A The intent is to prevent any single individual being unobserved while within any room within the HSA. This is not a new requirement and was in place under the prior individual payment brand requirements so there should be limited impact on card vendors previously held to payment brand criteria. Toilet rooms that are not fully enclosed and are accessible without opening the door (i.e., sufficient space exists above …
Q 19 December (update) 2013
•What is the rationale for Requirement 3.3.5.b? A The intent is to prevent any single individual being unobserved while within any room within the HSA. This is not a new requirement and was in place under the prior individual payment brand requirements so there should be limited impact on card vendors previously held to payment brand criteria. Toilet rooms that are not fully enclosed and are accessible without opening the door (i.e., sufficient space exists above …
•What is the rationale for Requirement 3.3.5.b? A The intent is to prevent any single individual being unobserved while within any room within the HSA. This is not a new requirement and was in place under the prior individual payment brand requirements so there should be limited impact on card vendors previously held to payment brand criteria. Toilet rooms that are not fully enclosed and are accessible without opening the door (i.e., sufficient space exists above …
Modified
p. 16 → 17
Q 19 October 2014 - In the Card Production Physical Security Requirements it states that card destruction must occur in a separate room within the HSA. Would the Vault be considered a separate room or does in need to be in a secured room within the Vault? A A dedicated room must be used for destruction. This room must be in the HSA and may optionally be a secured room within the vault. This room must meet all room requirements. …
Q 20 October 2014 - In the Card Production Physical Security Requirements it states that card destruction must occur in a separate room within the HSA. Would the Vault be considered a separate room or does in need to be in a secured room within the Vault? A A dedicated room must be used for destruction. This room must be in the HSA and may optionally be a secured room within the vault. This room must meet all room requirements. …
Removed
p. 17
• An outside wall of the building must not be used as a wall of the vault.
• No windows are permitted.
• There must be no access to the vault except through the vault door and gate configuration.
• The vault must be protected with sufficient number of shock detectors to provide full coverage of the walls, ceiling, and floor.
• The vault must be fitted with a main steel-reinforced door with a double mechanical or logical dual-locking mechanism that requires physical and simultaneous dual-control access. The access mechanism requires that access occurs under dual control and does not allow entry by a single individual
•i.e., it is not feasible for a single individual to use credentials belonging to someone else to simulate dual access.
• No windows are permitted.
• There must be no access to the vault except through the vault door and gate configuration.
• The vault must be protected with sufficient number of shock detectors to provide full coverage of the walls, ceiling, and floor.
• The vault must be fitted with a main steel-reinforced door with a double mechanical or logical dual-locking mechanism that requires physical and simultaneous dual-control access. The access mechanism requires that access occurs under dual control and does not allow entry by a single individual
•i.e., it is not feasible for a single individual to use credentials belonging to someone else to simulate dual access.
Modified
p. 17
Q 21 July 2014 - If PIN printing and mailing, and personalization, encoding and embossing take place in an open area, how can this requirement be met? A PIN printing must occur in a separate room except as delineated in PIN Printing and Packaging of Non-personalized Prepaid Cards. Documented procedures must exist that restrict personnel involved in PIN printing and mailing from being involved in the personalization, encoding and embossing of the related cards.
Q 22 July 2014 - If PIN printing and mailing, and personalization, encoding and embossing take place in an open area, how can this requirement be met? A PIN printing must occur in a separate room except as delineated in PIN Printing and Packaging of Non-personalized Prepaid Cards. Documented procedures must exist that restrict personnel involved in PIN printing and mailing from being involved in the personalization, encoding and embossing of the related cards.
Modified
p. 17
Q 22 October 2014 - Server processing and key management must be performed in a separate room within the personalization HSA. What is considered 'server processing'? A This applies to servers used for data preparation and personalization. It does not apply to DMZ based components.
Q 23 October 2014 - Server processing and key management must be performed in a separate room within the personalization HSA. What is considered 'server processing'? A This applies to servers used for data preparation and personalization. It does not apply to DMZ based components.
Modified
p. 17 → 18
Q 23 January (update) 2015 - Vaults are required to be constructed out of reinforced concrete with a minimum thickness of 6 inches, or materials that provide equivalent strength and durability. Does the use of Class 1 Certification Standards for the construction meet the equivalence factor, even though only 5 inch slabs may be used? A This requirement is under revision. Yes, the use of Underwriters Laboratories Class 1 Burglary Certification Standard which provides for at least 30 minutes of …
Q 24 January (update) 2015 - Vaults are required to be constructed out of reinforced concrete with a minimum thickness of 6 inches, or materials that provide equivalent strength and durability. Does the use of Class 1 Certification Standards for the construction meet the equivalence factor, even though only 5 inch slabs may be used? A This requirement is under revision. Yes, the use of Underwriters Laboratories Class 1 Burglary Certification Standard which provides for at least 30 minutes of …
Removed
p. 18
Q 25 January 2015 - Is it permissible to have an emergency exit from the vault to the HSA if the emergency door meets the strength requirement for a vault door, is alarmed and was not openable from outside? 3.3.6.d If the vault door is required to remain open during production hours, an inner grille must be used. The vault door or inner grille must remain closed and locked at all times, except when staff require access to the vault for example to store or remove items. The inner grille must be fitted with a dual-control locking mechanism or access reader.
Modified
p. 18
Q 24 January 2015 - Is it permissible to have more than one entry/exit to the vault from the HSA if each door meets the strength requirement for a vault door and is alarmed and meets all other required controls for a vault door, including anti-passback, etc. A Yes.
Q 25 January 2015 - Is it permissible to have more than one entry/exit to the vault from the HSA if each door meets the strength requirement for a vault door and is alarmed and meets all other required controls for a vault door, including anti-passback, etc. A Yes.
Modified
p. 18 → 19
Q 26 July 2014 - Where a vault door is required to remain open during production hours, an inner grille must be used. The inner grille must remain closed and locked at all times, except when staff require access to the vault. In this case the inner grille must be fitted with a dual-control locking mechanism or an access reader. However, access by use of physical keys means the access control system does not know who is in the vault …
Q 28 July 2014 - Where a vault door is required to remain open during production hours, an inner grille must be used. The inner grille must remain closed and locked at all times, except when staff require access to the vault. In this case the inner grille must be fitted with a dual-control locking mechanism or an access reader. However, access by use of physical keys means the access control system does not know who is in the vault …
Modified
p. 18 → 19
Q 27 July 2014 - Can a company have a badge access system that services multiple buildings on a single premises and/or multiple buildings throughout the world as long as the system is on its own segregated/dedicated network and all system changes are made on-site within a PCI compliant/secure room? A For multiple buildings within the same facility, a single central location can administer all buildings. However, a central facility cannot administer multiple separate facilities. The badge access system must …
Q 29 July 2014 - Can a company have a badge access system that services multiple buildings on a single premises and/or multiple buildings throughout the world as long as the system is on its own segregated/dedicated network and all system changes are made on-site within a PCI compliant/secure room? A For multiple buildings within the same facility, a single central location can administer all buildings. However, a central facility cannot administer multiple separate facilities. The badge access system must …
Modified
p. 19 → 20
Q 28 March (update) 2015 - For purposes of this requirement, can motion activation recording be used, such that if there is not any activity and associated motion, there is not any need to record? If motion activation is allowed, how long past cessation of motion must be recorded? A This requirement is under revision. The new text will state: CCTV cameras must record all activity, including recording events during dark periods through the use of infrared CCTV cameras or …
Q 30 March (update) 2015 - For purposes of this requirement, can motion activation recording be used, such that if there is not any activity and associated motion, there is not any need to record? If motion activation is allowed, how long past cessation of motion must be recorded? A This requirement is under revision. The new text will state: CCTV cameras must record all activity, including recording events during dark periods through the use of infrared CCTV cameras or …
Modified
p. 19 → 20
Q 29 July 2014
• Backups must be kept for at least 90 days and must occur daily. Does each daily back up need to occur for at least 90 days and does the 90 days only pertain to backups. A Standard back-up policies using full/incremental - daily/weekly/monthly
• can be used. Both primary and back-up copies must be kept for a minimum of the most recent 90 days.
• Backups must be kept for at least 90 days and must occur daily. Does each daily back up need to occur for at least 90 days and does the 90 days only pertain to backups. A Standard back-up policies using full/incremental - daily/weekly/monthly
• can be used. Both primary and back-up copies must be kept for a minimum of the most recent 90 days.
Q 31 July 2014
• Backups must be kept for at least 90 days and must occur daily. Does each daily back up need to occur for at least 90 days and does the 90 days only pertain to backups. A Standard back-up policies using full/incremental - daily/weekly/monthly
• can be used. Both primary and back-up copies must be kept for a minimum of the most recent 90 days.
• Backups must be kept for at least 90 days and must occur daily. Does each daily back up need to occur for at least 90 days and does the 90 days only pertain to backups. A Standard back-up policies using full/incremental - daily/weekly/monthly
• can be used. Both primary and back-up copies must be kept for a minimum of the most recent 90 days.
Modified
p. 19 → 20
Q 30 December 2013
• Are backups required to be stored in the same facility as the primary copies to meet Requirement 3.4.5.4.b? A This requirement is under revision. Meanwhile, backups may be stored in other facilities via techniques such as disk mirroring, provided the storage is secure in accordance with these requirements.
• Are backups required to be stored in the same facility as the primary copies to meet Requirement 3.4.5.4.b? A This requirement is under revision. Meanwhile, backups may be stored in other facilities via techniques such as disk mirroring, provided the storage is secure in accordance with these requirements.
Q 32 December 2013
• Are backups required to be stored in the same facility as the primary copies to meet Requirement 3.4.5.4.b? A This requirement is under revision. Meanwhile, backups may be stored in other facilities via techniques such as disk mirroring, provided the storage is secure in accordance with these requirements.
• Are backups required to be stored in the same facility as the primary copies to meet Requirement 3.4.5.4.b? A This requirement is under revision. Meanwhile, backups may be stored in other facilities via techniques such as disk mirroring, provided the storage is secure in accordance with these requirements.
Modified
p. 19 → 20
Q 31 December 2013
• Does the use of RAID technology meet the criteria for separate backup recordings? A No. RAID technology is a storage technique that divides and replicates data among multiple physical drive in order to provide reliability, availability, performance and capacity. It is not a mechanism for backing up data.
• Does the use of RAID technology meet the criteria for separate backup recordings? A No. RAID technology is a storage technique that divides and replicates data among multiple physical drive in order to provide reliability, availability, performance and capacity. It is not a mechanism for backing up data.
Q 33 December 2013
• Does the use of RAID technology meet the criteria for separate backup recordings? A No. RAID technology is a storage technique that divides and replicates data among multiple physical drive in order to provide reliability, availability, performance and capacity. It is not a mechanism for backing up data.
• Does the use of RAID technology meet the criteria for separate backup recordings? A No. RAID technology is a storage technique that divides and replicates data among multiple physical drive in order to provide reliability, availability, performance and capacity. It is not a mechanism for backing up data.
Modified
p. 20 → 21
Q 32 December 2013
• Does this requirement apply to core sheets used at the facility? It applies only to production quality core sheets printed with the payment system brand or issuer design and not to blank sheets.
• Does this requirement apply to core sheets used at the facility? It applies only to production quality core sheets printed with the payment system brand or issuer design and not to blank sheets.
Q 34 December 2013
• Does this requirement apply to core sheets used at the facility? It applies only to production quality core sheets printed with the payment system brand or issuer design and not to blank sheets.
• Does this requirement apply to core sheets used at the facility? It applies only to production quality core sheets printed with the payment system brand or issuer design and not to blank sheets.
Modified
p. 20 → 21
Q 33 December 2013
• Audit controls for manufacturing include tracking the number returned to the vault or WIP storage. Does this require that finished products that are already packed in containers or cartons prior to shipment be recounted before storage in the vault or WIP storage? A Finished products that have been previously counted in a controlled manner and sealed in tamper-evident packaging do not require recounting; however, they must still be part of the audit trail log.
• Audit controls for manufacturing include tracking the number returned to the vault or WIP storage. Does this require that finished products that are already packed in containers or cartons prior to shipment be recounted before storage in the vault or WIP storage? A Finished products that have been previously counted in a controlled manner and sealed in tamper-evident packaging do not require recounting; however, they must still be part of the audit trail log.
Q 35 December 2013
• Audit controls for manufacturing include tracking the number returned to the vault or WIP storage. Does this require that finished products that are already packed in containers or cartons prior to shipment be recounted before storage in the vault or WIP storage? A Finished products that have been previously counted in a controlled manner and sealed in tamper-evident packaging do not require recounting; however, they must still be part of the audit trail log.
• Audit controls for manufacturing include tracking the number returned to the vault or WIP storage. Does this require that finished products that are already packed in containers or cartons prior to shipment be recounted before storage in the vault or WIP storage? A Finished products that have been previously counted in a controlled manner and sealed in tamper-evident packaging do not require recounting; however, they must still be part of the audit trail log.
Modified
p. 21 → 22
Q 34 October 2014 - Section 4.7 is marked as valid only for Manufacturing, but 4.7.3 specifically refers to Personalization Audit Controls. Does 4.7.1.1 & 4.7.1.2 (logs) refer to only manufacturing logs and not to Personalization logs? Or are we to understand that only 4.7.1 (and not its sections 4.7.1.1 and 4.7.1.2) applies exclusively to Manufacturing while the rest apply to both Manufacturing and Personalization? A This requirement is mislabeled. It should say production rather than manufacturing as it applies …
Q 36 October 2014 - Section 4.7 is marked as valid only for Manufacturing, but 4.7.3 specifically refers to Personalization Audit Controls. Does 4.7.1.1 & 4.7.1.2 (logs) refer to only manufacturing logs and not to Personalization logs? Or are we to understand that only 4.7.1 (and not its sections 4.7.1.1 and 4.7.1.2) applies exclusively to Manufacturing while the rest apply to both Manufacturing and Personalization? A This requirement is mislabeled. It should say production rather than manufacturing as it applies …
Modified
p. 21 → 22
Q 35 January (update) 2015
• Section 4.7.3.d requires various counts for envelopes. Does this apply for all envelopes? A This requirement is under revision. Counts of envelopes that do not contain cards are not required. As a reminder though, personalized cards must be placed in envelopes that are nondescript (e.g., envelopes must not contain any brand marks).
• Section 4.7.3.d requires various counts for envelopes. Does this apply for all envelopes? A This requirement is under revision. Counts of envelopes that do not contain cards are not required. As a reminder though, personalized cards must be placed in envelopes that are nondescript (e.g., envelopes must not contain any brand marks).
Q 37 January (update) 2015
• Section 4.7.3.d requires various counts for envelopes. Does this apply for all envelopes? A This requirement is under revision. Counts of envelopes that do not contain cards are not required. As a reminder though, personalized cards must be placed in envelopes that are nondescript (e.g., envelopes must not contain any brand marks).
• Section 4.7.3.d requires various counts for envelopes. Does this apply for all envelopes? A This requirement is under revision. Counts of envelopes that do not contain cards are not required. As a reminder though, personalized cards must be placed in envelopes that are nondescript (e.g., envelopes must not contain any brand marks).
Modified
p. 22 → 23
Q 36 December 2013
• What happens if a supervisor or auditor is not available to sign off on the various required counts? A For purposes of this requirement, the terms “operator,” “supervisor,” and “auditor” do not mean a formal job title, but rather define a function. Specifically supervisor/auditor refers to the function of the individual who verifies the count, while operator refers to the individual who conducts the count.
• What happens if a supervisor or auditor is not available to sign off on the various required counts? A For purposes of this requirement, the terms “operator,” “supervisor,” and “auditor” do not mean a formal job title, but rather define a function. Specifically supervisor/auditor refers to the function of the individual who verifies the count, while operator refers to the individual who conducts the count.
Q 38 December 2013
• What happens if a supervisor or auditor is not available to sign off on the various required counts? A For purposes of this requirement, the terms “operator,” “supervisor,” and “auditor” do not mean a formal job title, but rather define a function. Specifically supervisor/auditor refers to the function of the individual who verifies the count, while operator refers to the individual who conducts the count.
• What happens if a supervisor or auditor is not available to sign off on the various required counts? A For purposes of this requirement, the terms “operator,” “supervisor,” and “auditor” do not mean a formal job title, but rather define a function. Specifically supervisor/auditor refers to the function of the individual who verifies the count, while operator refers to the individual who conducts the count.
Modified
p. 22 → 23
Q 37 October (update) 2014
• Many facilities use portable/mobile shredding equipment managed by third-party service providers. How is this accommodated to meet 4.8.2.a? A The HSA includes the loading bay. The used foil can be destroyed there using portable/mobile equipment provided any access points (e.g., doors) from outside the HSA are closed and properly secured. This can also be applied to other secure materials that require destruction, such as scrap cards, return mail cards, and vault destroy requests.
• Many facilities use portable/mobile shredding equipment managed by third-party service providers. How is this accommodated to meet 4.8.2.a? A The HSA includes the loading bay. The used foil can be destroyed there using portable/mobile equipment provided any access points (e.g., doors) from outside the HSA are closed and properly secured. This can also be applied to other secure materials that require destruction, such as scrap cards, return mail cards, and vault destroy requests.
Q 39 October (update) 2014
• Many facilities use portable/mobile shredding equipment managed by third-party service providers. How is this accommodated to meet 4.8.2.a? A The HSA includes the loading bay. The used foil can be destroyed there using portable/mobile equipment provided any access points (e.g., doors) from outside the HSA are closed and properly secured. This can also be applied to other secure materials that require destruction, such as scrap cards, return mail cards, and vault destroy requests.
• Many facilities use portable/mobile shredding equipment managed by third-party service providers. How is this accommodated to meet 4.8.2.a? A The HSA includes the loading bay. The used foil can be destroyed there using portable/mobile equipment provided any access points (e.g., doors) from outside the HSA are closed and properly secured. This can also be applied to other secure materials that require destruction, such as scrap cards, return mail cards, and vault destroy requests.
Modified
p. 22 → 23
Q 38 December 2013
• Considering Requirement 4.8.2.a, there may be circumstances where there is minimal material created that requires destruction. Can the destruction occur less frequently? A The requirement is under revision. Meanwhile, the destruction can occur as frequently as the vendor deems necessary, but in all cases, no less frequently than weekly. The vendor must maintain proper controls over these materials at all times prior to destruction, and the destruction must occur within the HSA.
• Considering Requirement 4.8.2.a, there may be circumstances where there is minimal material created that requires destruction. Can the destruction occur less frequently? A The requirement is under revision. Meanwhile, the destruction can occur as frequently as the vendor deems necessary, but in all cases, no less frequently than weekly. The vendor must maintain proper controls over these materials at all times prior to destruction, and the destruction must occur within the HSA.
Q 40 December 2013
• Considering Requirement 4.8.2.a, there may be circumstances where there is minimal material created that requires destruction. Can the destruction occur less frequently? A The requirement is under revision. Meanwhile, the destruction can occur as frequently as the vendor deems necessary, but in all cases, no less frequently than weekly. The vendor must maintain proper controls over these materials at all times prior to destruction, and the destruction must occur within the HSA.
• Considering Requirement 4.8.2.a, there may be circumstances where there is minimal material created that requires destruction. Can the destruction occur less frequently? A The requirement is under revision. Meanwhile, the destruction can occur as frequently as the vendor deems necessary, but in all cases, no less frequently than weekly. The vendor must maintain proper controls over these materials at all times prior to destruction, and the destruction must occur within the HSA.
Modified
p. 22 → 23
Q 39 January 2015 - What materials are required to be destroyed in the destruction room? A Remnants/residues of holograms from a post splitting process, signature panels and any materials required to be stored in the vault 4.8.3 Indent Printing Module 4.8.3.a The vendor must use indent-printing modules only for payment system cards.
Q 41 January 2015 - What materials are required to be destroyed in the destruction room? A Remnants/residues of holograms from a post splitting process, signature panels and any materials required to be stored in the vault 4.8.3 Indent Printing Module 4.8.3.a The vendor must use indent-printing modules only for payment system cards.
Modified
p. 22 → 23
Q 40 July (update) 2014
• How is this requirement applied? A Payment system proprietary typefaces within Indent-printing modules cannot be used for other purposes than payment cards. Proprietary indent printing characters are destroyed at the end of usage.
• How is this requirement applied? A Payment system proprietary typefaces within Indent-printing modules cannot be used for other purposes than payment cards. Proprietary indent printing characters are destroyed at the end of usage.
Q 42 July (update) 2014
• How is this requirement applied? A Payment system proprietary typefaces within Indent-printing modules cannot be used for other purposes than payment cards. Proprietary indent printing characters are destroyed at the end of usage.
• How is this requirement applied? A Payment system proprietary typefaces within Indent-printing modules cannot be used for other purposes than payment cards. Proprietary indent printing characters are destroyed at the end of usage.
Removed
p. 23
• Spoiled or waste card products
• Holographic materials
• Sample and test cards
• The vehicle is loaded using dual control and locked during transport
• Vehicle drivers do not have a key or access to contents
• Holographic materials
• Sample and test cards
• The vehicle is loaded using dual control and locked during transport
• Vehicle drivers do not have a key or access to contents
Modified
p. 23 → 24
Spoiled or waste card products Holographic materials Signature panels Sample and test cards Any other sensitive card component material or courier material related to any phase of the card production and personalization process.
Modified
p. 23 → 24
Destruction of chips, modules, or chip cards must ensure that the chip itself is destroyed.
Modified
p. 23 → 24
Q 41 July 2014 - 4.10 requires that materials must be destroyed on a batch basis. Does this mean materials must be destroyed at the conclusion of each job? A No, multiple jobs can be grouped together to form a batch.
Q 43 July 2014 - 4.10 requires that materials must be destroyed on a batch basis. Does this mean materials must be destroyed at the conclusion of each job? A No, multiple jobs can be grouped together to form a batch.
Modified
p. 23 → 24
Q 42 October 2014 - The acceptable methods of shipping personalized cards are:
Q 44 October 2014 - The acceptable methods of shipping personalized cards are:
Modified
p. 23 → 24
A GPS tracking device is used and monitored during transport from within the security control room.
Modified
p. 23 → 24
The contents are secured with tamper evident straps and checked upon delivery.
Modified
p. 23 → 24
The vehicle is loaded using dual control and locked during transport Vehicle drivers do not have a key or access to contents Two persons are in the vehicle equipped with a device to communicate with the security control room.