Information Security Policy 

 Web Buster UK Limited

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Web Buster UK Limited

     

 15 March 2017

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Contents

Introduction. 3

Information Security Policy. 3

1.      Network Security. 4

2.      Acceptable Use Policy. 4

3.      Protect Stored Data. 4

4.      Information Classification. 5

5.      Access to the Sensitive Cardholder Data. 5

6.      Physical Security. 6

7.      Protect Data in Transit. 6

8.      Disposal of Stored Data. 7

9.      Security Awareness and Procedures. 7

10.         Credit Card (PCI) Security Incident Response Plan. 8

11.         Transfer of Sensitive Information Policy. 12

12.         User Access Management. 12

13.        Access Control Policy. 13

Appendix A – Agreement to Comply Form – Agreement to Comply With Information Security Policies. 15

Appendix B – List of Devices. 16


Introduction

This Policy document encompasses all aspects of security surrounding confidential company information and must be distributed to all company employees. All company employees must read this document in its entirety and sign the form confirming they have read and fully understand this policy. This document will be reviewed and updated by Management on an annual basis or when relevant to include newly developed security standards into the policy and re-distributed to all employees and contractors where applicable.

Information Security Policy

Web Buster UK Limited handles sensitive cardholder information daily.  Sensitive Information must have adequate safeguards in place to protect the cardholder data, cardholder privacy, and to ensure compliance with various regulations, along with guarding the future of the organisation.

Web Buster UK Limited commits to respecting the privacy of all its customers and to protecting any customer data from outside parties.  To this end management are committed to maintaining a secure environment in which to process cardholder information so that we can meet these promises.

Employees handling sensitive cardholder data should ensure:

l     Handle Company and cardholder information in a manner that fits with their sensitivity and classification;

l     Limit personal use of Web Buster UK Limited information and telecommunication systems and ensure it doesn’t interfere with your job performance;

l     Web Buster UK Limited reserves the right to monitor, access, review, audit, copy, store, or delete any electronic communications, equipment, systems and network traffic for any purpose;

l     Do not use e-mail, internet and other Company resources to engage in any action that is offensive, threatening, discriminatory, defamatory, slanderous, pornographic, obscene, harassing or illegal;

l     Do not disclose personnel information unless authorised;

l     Protect sensitive cardholder information;

l     Keep passwords and accounts secure;

l     Request approval from management prior to establishing any new software or hardware, third party connections, etc.;

l     Do not install unauthorised software or hardware, including modems and wireless access unless you have explicit management approval;

l     Always leave desks clear of sensitive cardholder data and lock computer screens when unattended;

l     Information security incidents must be reported, without delay, to the individual responsible for incident response locally – Please find out who this is.

We each have a responsibility for ensuring our company’s systems and data are protected from unauthorised access and improper use.  If you are unclear about any of the policies detailed herein you should seek advice and guidance from your line manager.

  1. Network Security

A high-level network diagram of the network is maintained and reviewed on a yearly basis.  The network diagram provides a high level overview of the cardholder data environment (CDE), which at a minimum shows the connections in and out of the CDE.  Critical system components within the CDE, such as POS devices, databases, web servers, etc., and any other necessary payment components, as applicable should also be illustrated.

In addition, ASV should be performed and completed by a PCI SSC Approved Scanning Vendor, where applicable.  Evidence of these scans should be maintained for a period of 18 months.

  1. Acceptable Use Policy

Management’s intentions for publishing an Acceptable Use Policy are not to impose restrictions that are contrary to Web Buster UK Limited’s established culture of openness, trust and integrity. Management is committed to protecting the employees, partners and the Company from illegal or damaging actions, either knowingly or unknowingly by individuals. Web Buster UK Limited will maintain an approved list of technologies and devices and personnel with access to such devices as detailed in Appendix B.

  1. Protect Stored Data

It is strictly prohibited to store:

  1. The contents of the payment card magnetic stripe (track data) on any media whatsoever. 
  2. The CVV/CVC (the 3 or 4 digit number on the signature panel on the reverse of the payment card) on any media whatsoever. 
  3. The PIN or the encrypted PIN Block under any circumstance.

  1. Information Classification

Data and media containing data must always be labelled to indicate sensitivity level.

  1. Access to the Sensitive Cardholder Data

All Access to sensitive cardholder should be controlled and authorised. Any job functions that require access to cardholder data should be clearly defined.

  1. Physical Security

Access to sensitive information in both hard and soft media format must be physically restricted to prevent unauthorised individuals from obtaining sensitive data.

  1. Protect Data in Transit

All sensitive cardholder data must be protected securely if it is to be transported physically or electronically.

  1. Disposal of Stored Data

  1. Security Awareness and Procedures

The policies and procedures outlined below must be incorporated into company practice to maintain a high level of security awareness. The protection of sensitive data demands regular training of all employees and contractors.


  1. Credit Card (PCI) Security Incident Response Plan

  1. Each department must report an incident to the Information Security Officer (preferably) or to another member of the PCI Response Team.
  2. That member of the team receiving the report will advise the PCI Response Team of the incident.
  3. The PCI Response Team will investigate the incident and assist the potentially compromised department in limiting the exposure of cardholder data and in mitigating the risks associated with the incident.
  4. The PCI Response Team will resolve the problem to the satisfaction of all parties involved, including reporting the incident and findings to the appropriate parties (credit card associations, credit card processors, etc.) as necessary.
  5. The PCI Response Team will determine if policies and processes need to be updated to avoid a similar incident in the future, and whether additional safeguards are required in the environment where the incident occurred, or for the institution.

Web Buster UK Limited PCI Security Incident Response Team (or equivalent in your organisation):

CIO

Communications Director

Compliance Officer

Counsel

Information Security Officer

Collections & Merchant Services

Risk Manager

Information Security PCI Incident Response Procedures:

Incident Response Notification

Escalation Members (or equivalent in your company):

Escalation – First Level:

Information Security Officer Controller

Executive Project Director for Credit Collections and Merchant Services Legal Counsel

Risk Manager

Director of Web Buster UK Limited Communications

Escalation – Second Level:

Web Buster UK Limited President

Executive Cabinet

Internal Audit

Auxiliary members as needed

      External Contacts (as needed)

Merchant Provider Card Brands

Internet Service Provider (if applicable)

Internet Service Provider of Intruder (if applicable) Communication Carriers (local and long distance) Business Partners

Insurance Carrier

External Response Team as applicable (CERT Coordination Center 1, etc) Law Enforcement Agencies as applicable inn local jurisdiction

In response to a systems compromise, the PCI Response Team and designees will:

  1. Ensure compromised system/s is isolated on/from the network.
  2. Gather, review and analyze the logs and related information from various central and local safeguards and security controls
  3. Conduct appropriate forensic analysis of compromised system.
  1. Contact internal and external departments and entities as appropriate.
  2. Make forensic and log analysis available to appropriate law enforcement or card industry security personnel, as required.
  3. Assist law enforcement and card industry security personnel in investigative processes, including in prosecutions.

The credit card companies have individually specific requirements that the Response Team must address in reporting suspected or confirmed breaches of cardholder data. See below for these requirements.

Incident Response notifications to various card schemes 

  1. In the event of a suspected security breach, alert the information security officer or your line manager immediately. 
  2. The security officer will carry out an initial investigation of the suspected security breach. 
  3. Upon confirmation that a security breach has occurred, the security officer will alert management and begin informing all relevant parties that may be affected by the compromise.  

 VISA Steps

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

Visa Incident Report Template

This report must be provided to VISA within 14 days after initial report of incident to VISA. The following report content and standards must be followed when completing the incident report. Incident report must be securely distributed to VISA and Merchant Bank. Visa will classify the report as “VISA Secret”*.

  1. Executive Summary

  1. Include overview of the incident
  2. Include RISK Level(High, Medium, Low)
  3. Determine if compromise has been contained
  4. Background
  5. Initial Analysis
  6. Investigative Procedures

  1. Include forensic tools used during investigation
  2. Findings
    1. Number of accounts at risk, identify those stores and compromised

  1. Type of account information at risk
  2. Identify ALL systems analyzed. Include the following:

  1. Identify ALL compromised systems. Include the following:

  1. Timeframe of compromise

  1. Any data exported by intruder
  2. Establish how and source of compromise
  3. Check all potential database locations to ensure that no CVV2, Track 1 or Track 2 data is stored anywhere, whether encrypted or unencrypted (e.g., duplicate or backup tables or databases, databases used in development, stage or testing environments, data on software engineers’ machines, etc.)
  4. If applicable, review VisaNet endpoint security and determine risk
  5. Compromised Entity Action
  6. Recommendations

  1. Contact(s) at entity and security assessor performing investigation

*This classification applies to the most sensitive business information, which is intended for use within VISA. Its unauthorized disclosure could seriously and adversely impact VISA, its employees, member banks, business partners, and/or the Brand.

MasterCard Steps:

  1. Within 24 hours of an account compromise event, notify the MasterCard Compromised Account Team via phone at 1-636-722-4100.
  2. Provide a detailed written statement of fact about the account compromise (including the contributing circumstances) via secured e-mail to This email address is being protected from spambots. You need JavaScript enabled to view it..

  1. Provide the MasterCard Merchant Fraud Control Department with a complete list of all known compromised account numbers.
  2. Within 72 hours of knowledge of a suspected account compromise, engage the services of a data security firm acceptable to MasterCard to assess the vulnerability of the compromised data and related systems (such as a detailed forensics evaluation).

  1. Provide weekly written status reports to MasterCard, addressing open questions and issues until the audit is complete to the satisfaction of MasterCard.
  2. Promptly furnish updated lists of potential or known compromised account numbers, additional documentation, and other information that MasterCard may request.

  1. Provide finding of all audits and investigations to the MasterCard Merchant Fraud Control department within the required time frame and continue to address any outstanding exposure or recommendation until resolved to the satisfaction of MasterCard.

Once MasterCard obtains the details of the account data compromise and the list of compromised account numbers, MasterCard will:

  1. Identify the issuers of the accounts that were suspected to have been compromised and group all known accounts under the respective parent member IDs.

  1. Distribute the account number data to its respective issuers.

Employees of the company will be expected to report to the security officer for any security related issues. The role of the security officer is to effectively communicate all security policies and procedures to employees within the company and contractors. In addition to this, the security officer will oversee the scheduling of security training sessions, monitor and enforce the security policies outlined in both this document and at the training sessions and finally, oversee the implantation of the incident response plan in the event of a sensitive data compromise.

Discover Card Steps

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

  1. Obtain additional specific requirements from Discover Card

American Express Steps

  1. Within 24 hours of an account compromise event, notify American Express Merchant Services at (800) 528-5200 in the U.S.
  2. Prepare a detailed written statement of fact about the account compromise including the contributing circumstances
  3. Prepare a list of all known compromised account numbers Obtain additional specific requirements from American Express

  1. Transfer of Sensitive Information Policy
  1. Adhere to the PCI DSS security requirements.
  2. Acknowledge their responsibility for securing the Card Holder data.
  3. Acknowledge that the Card Holder data must only be used for assisting the completion of a transaction, supporting a loyalty program, providing a fraud control service or for uses specifically required by law.
  4. Have appropriate provisions for business continuity in the event of a major disruption, disaster or failure.
  5. Provide full cooperation and access to conduct a thorough security review after a security intrusion by a Payment Card industry representative, or a Payment Card industry approved third party.

  1. User Access Management

Name of person making request;

Job title of the newcomers and workgroup;

Start date;

Services required (default services are: MS Outlook, MS Office and Internet access).

  1. Access Control Policy