PCI Compliance

The Payment Card Industry Data Security Standard (PCI-DSS) is a set of requirements designed to ensure that ALL companies who process, store or transmit credit card information maintain a secure environment for customer data. This essentially applies to any merchant that has a Merchant ID (MID). The Payment Card Industry Security Standards Council (PCI-SSC) is an independent body created by the major credit card brands (Visa, MasterCard, American Express, Discover and JCB), and was launched on September 7, 2006 to manage the ongoing evolution of Payment Card Industry (PCI) security standards, with a focus on improving payment account security throughout the transaction process. The PCI-DSS is administered and managed by the PCI-SSC (www.pcisecuritystandards.org). It is important to note that the individual payment brands and acquirers are responsible for enforcing compliance, not the PCI council. A copy of the PCI-DSS is available here.

PCI applies to ANY organization or merchant – regardless of their size or number of transactions – that accepts, transmits or stores any cardholder data. To put it another way: if any customer of that organization or merchant ever pays them directly using a credit or debit card, then the PCI-DSS requirements apply.

The current PCI-DSS documents can be found on the PCI Security Standards Council Website.

All merchants will fall into one of four merchant levels based on Visa transaction volume over a 12-month period. Transaction volume is based on the aggregate number of Visa transactions (inclusive of credit, debit and prepaid cards) from a merchant Doing Business As (DBA). In cases where a merchant corporation has more than one DBA, Visa acquirers must consider the aggregate volume of transactions stored, processed or transmitted by the corporate entity to determine the validation level. If data is not aggregated – i.e. the corporate entity does not store, process or transmit cardholder data on behalf of multiple DBAs – acquirers will continue to consider the DBA’s individual transaction volume to determine the validation level.

The merchant levels as defined by Visa are:

Yes. All business that store, process or transmit payment cardholder data must be PCI Compliant, regardless of how they acquire that data.

Yes. Merely using a third-party company does not exclude a company from PCI Compliance. It may cut down on their risk exposure and consequently reduce the effort to validate compliance. However, it does not mean they can ignore PCI.

If your business locations process transactions under the same Tax ID, then typically you are only required to validate once annually for all locations. You must also submit quarterly passing network scans by an PCI-SSC Approved Scanning Vendor (ASV), if applicable.

The PCI-SSC defines “cardholder data” as the full Primary Account Number (PAN) or the full PAN along with any of the following elements:

• Cardholder name
• Expiration date
• Service code

Sensitive Authentication Data (SAN), which must also be protected, includes full magnetic stripe data, CAV2, CVC2, CVV2, CID, PINs, PIN blocks and more.

The payment brands may, at their discretion, fine an acquiring bank $5,000 to $100,000 per month for PCI Compliance violations. The banks will most likely pass this fine along until it eventually hits the merchant. Furthermore, the bank will most likely either terminate your relationship or increase transaction fees. Penalties are not openly discussed nor widely publicized, but they can be catastrophic to a small business.

It is important to be familiar with your merchant account agreement, which should outline your exposure to violations.