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Financial Services Law Insights and Observations

Payment Card Group Refines Data Security Standards

Payment Systems Privacy/Cyber Risk & Data Security

Privacy, Cyber Risk & Data Security

On November 7, the PCI Security Standards Council (PCI SSC), an organization that develops standard for payment card security, released updated data security standards. One standard applies to entities involved in payment card processing—merchants, processors, acquirers, issuers, and service providers, as well as all other entities that store, process or transmit cardholder data. The other standard applies to software vendors and others who develop payment applications that store, process, or transmit cardholder data as part of authorization or settlement, where these payment applications are sold, distributed, or licensed to third parties. PCI SSC updates the standards every three years. This most recent update includes, among other things, requirements that payment card processors: (i) evaluate evolving malware threats for any systems not considered to be commonly affected; (ii) control physical access to sensitive areas for onsite personnel, including a process to authorize access, and revoke access immediately upon termination; (iii) protect devices that capture payment card data via direct physical interaction with the card from tampering and substitution; (iv) implement a methodology for penetration testing; (v) implement a process to respond to any alerts generated by the change-detection mechanism; and (vi) maintain information about which security requirements are managed by each service provider, and which are managed by the entity.

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