Ask HN: Are you PCI DSS compliant?
pcisecuritystandards.org
pcisecuritystandards.org
The short answer to "how should my startup deal with PCI DSS" is "don't accept cardholder information". Outsource the handling and processing of credit card information. There is a "self-attestation" questionairre the PCI-powers-that-be apparently want you to fill out even though you're not handling credit cards. Uh, fill it out.
What you should not do is pay for consultants to checklist your app if you're not taking credit card numbers directly. If you are collecting cards, you already knew you were in for a whole big bucket of drama.
The codebase was close to a decade old, and a lot of customers were subscribed via a recurring payment feature where our payment processor held their CC#. So transitioning away from ever seeing cardholder data was the least economic option for us.
If you're storing credit card numbers, things get much more complicated.
* I don't store process or transmit any cardholder data on my premises, but rely entirely on third party services to handle these functions.
* The third parties I use for handling storage, processing, and transmission of cardholder data is PCI certified.
* I don't store any cardholder data in electronic format.
* What physical cardholder data I store is only paper reports and copies of receipts and is never received electronically?
Yes? Then you can self-attest (presumably at any time, such as when asked, but dont' quote me) compliance. You'll sign a document that says:
* I read the PCI DSS (sorry).
* The above conditions about not handling cardholder data are true.
* (9.6) All paper and electronic media that contain cardholder data is physically secure.
* (9.7a) Strict control is maintained over internal and external distribution of any media containing cardholder information.
* (9.7b) Controls include (9.7.1) such media being "classified" so everyone knows its confidential and (9.7.2) when transported it's sent by courier or other trackable secure carrier.
* (9.8) Processes and procedures are in place to ensure management approval before moving any media containing cardholder data from a secure area.
* (9.9) Strict control is maintained over storage and access of media containing cardholder data.
* (9.10) Cardholder-carrying media is destroyed as soon as it is no longer need for legal or business reasons, and (9.10.1) hardcopy material is cross-cut shredded, incinerated, staked through the heart, chained in silver, buried under a full moon in a Scottish peat bog, and pulped so that cardholder data cannot be reconstructed.
* (12.8) Cardholder data once shared with service providers are secured with policies and procedures that:
* (12.8.1) Include keeping (yes wait for it) a list of service providers
* (12.8.2) You have written agreements with those providers that say "yes we know what PCI means"
* (12.8.3) You have some due diligence process for choosing providers that know what PCI is.
* (12.8.4) You have a policy for monitoring those providers PCI compliance so if they suddenly decide PCI is a big joke you'll stop funnelling cards to them.
That's it. No app pentests required. No firewalls installed. More than half of it is about physical storage of cardholder records which you aren't doing because that's crazy.
I think you'll be fine.
Lots of people on this forum seem to misread this one.
If cardholder data is POSTed to your server, and then you send it on to a third party, then you're receiving and transmitting, and you've got to be in compliance.
Don't touch credit card numbers. Not even to hot-potato it. If it touches you, it leaves a stain, and removing it will cost you high tens of thousands of dollars.
It's sort of like speeding, but with bigger tickets. Most people do it, but it's risky.
Why isn't anyone offering a thin wrapper service that lets you host a payment form yourself (giving you complete control of the page), and then POST the result to the service which just forwards to one of the major processors?
You get full control of the form, and your server never transmits CC data, so it's out of scope for PCI compliance.
My thought process was that it would work like this:
Merchant - Hosts a a payment form, but it POSTs to the service's server basically <form method="post" action="https ://someservice.com">
Service - Receives the POST and forwards it on to Auth.NET, Paypal Pro, or whoever the Merchant is using to process transactions. The user is redirected back to merchantwebsite.com with appropriate response data.
Are you saying the merchant website would still need to be PCI compliant or just the Service's?
I definitely understand that the service would have to be PCI compliant. But it seems like it'd be a valuable service for a number of small e-commerce providers to essentially outsource online PCI compliance with minimal downside.
EDIT: While I haven't used them, my understanding is that Braintree offers pretty much exactly this service, except that they require that they provide your merchant account and act as your payment processor.
Having said that:
The technical risk of you hosting HTML that POST's via HTTPS somewhere else is that any input that influences any dynamic component of the page on which the form is hosted could alter the "action" attribute of the form to point somewhere else, without it even being detectable in the page source.
You can say that about any chain of pages, including in-app page flows all the way through Google SERPs, but it's a particularly severe risk on the actual page that asks for the credit card number, since there are no macro-level cues a user has as to whether the page is valid or not.
OWASP is making more noise about things like "insecure redirects" for, among other things, this exact scenario. Expect the "host the HTML FORM that asks for the credit card number and send it to the payment processor" technique to run afoul of PCI DSS any year now.