Quality of Security

The OpenPath Security team is always keeping its hardware and software up to date with the best security standards that exceed the typical certifications. Feel free to test any of our endpoints and API against your favorite scanning software. If you don't have one, feel free to run Qualys SSL Labs test at:

SSL Server Test: api.openpath.io (Powered by Qualys SSL Labs)

Certificate of PCI Validation

Sysnet Global Solutions empower businesses to be secure and compliant through award winning cyber security solutions and extraordinary services and support. Established in 1989, Sysnet Global Solutions provides payment card industry, cyber security and compliance solutions that help businesses to improve security and acquiring organizations to reduce risk.

Attestation of Compliance

The following document lays out our PCI Attestation of Compliance:

All other SAQ-Eligible Merchants
For use with PCI DSS Version 3.2.1
Revision 1.0
June 2018
Payment Card Industry (PCI)
Data Security Standard
Self-Assessment Questionnaire
D
and Attestation Of Compliance
June 2018
Page 2
PCI DSS v3.2.1 SAQ D, Rev. 1.0
© 2006-2018 PCI Security Standards Council, LLC. All Rights Reserved.
Document changes
Date PCI DSS
Version
SAQ
Revision
Description
October
2008
1.2 To align content with new PCI DSS v1.2 and to implement minor changes noted since
original v1.1.
October
2010
2.0 To align content with new PCI DSS v2.0 requirements and testing procedures.
February
2014
3.0 To align content with PCI DSS v3.0 requirements and testing procedures and incorporate
additional response options.
April
2015
3.1 Updated to align with PCI DSS v3.1. For details of PCI DSS changes, see PCI DSS - Summary
of Changes from PCI DSS Version 3.0 to 3.1.
April
2016
3.2 1.0 Updated to align with PCI DSS v3.2. For details of PCI DSS changes, see PCI DSS - Summary
of Changes from PCI DSS Version 3.1 to 3.2.
January
2017
3.2 1.1 Updated version numbering to align with other SAQs
June
2018
3.2.1 1.0 Updated to align with PCI DSS v3.2.1. For details of PCI DSS changes, see PCI DSS -
Summary of Changes from PCI DSS Version 3.2 to 3.2.1.
June 2018
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PCI DSS v3.2.1 SAQ D, Rev. 1.0
© 2006-2018 PCI Security Standards Council, LLC. All Rights Reserved.
Section 3: Validation and Attestation Details 52
Annotation 51
Appendix C: Explanation of Non-Applicability 49
Appendix B: Compensating Controls Worksheet 48
Appendix B: Additional PCI DSS Requirements for Shared Hosting Providers 47
Requirement 12: Maintain a policy that addresses information security for all personnel. 43
Maintain an Information Security Policy 43
Requirement 11: Regularly test security systems and processes. 38
Requirement 10: Track and monitor all access to network resources and cardholder data 36
Regularly Monitor and Test Networks 36
Requirement 9: Restrict physical access to cardholder data 31
Requirement 8: Identify and authenticate access to system components 29
Requirement 7: Restrict access to cardholder data by business need to know 28
Implement Strong Access Control Measures 28
Requirement 6: Develop and maintain secure systems and applications 23
Requirement 5: Protect all systems against malware and regularly update anti-virus software or programs 23
Maintain a Vulnerability Management Program 23
Requirement 4: Encrypt transmission of cardholder data across open, public networks 21
Requirement 3: Protect stored cardholder data 18
Protect Cardholder Data 18
Requirement 2: Do not use vendor-supplied defaults for system passwords and other security parameters 14
Requirement 1: Install and maintain a firewall configuration to protect cardholder data 12
Build and Maintain a Secure Network and Systems 12
Section 2: Self-Assessment Questionnaire D 12
Section 1: Assessment Information 8
Legal Exception 7
Understanding the difference between Not Applicable and Not Tested 7
Guidance for Non-Applicability of Certain, Specific Requirements 6
Completing the Self-Assessment Questionnaire 5
Understanding the Self-Assessment Questionnaire 4
PCI DSS Compliance-Completion Steps 4
Before you Begin 4
Document changes 2
Table of contents
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PCI DSS v3.2.1 SAQ D, Rev. 1.0
© 2006-2018 PCI Security Standards Council, LLC. All Rights Reserved.
1.
2.
3.
4.
5.
Before you Begin
SAQ D for Merchants applies to SAQ-eligible merchants not meeting the criteria for any other SAQ type. Examples of merchant
environments that would use SAQ D may include but are not limited to:
E-commerce merchants who accept cardholder data on their website.
Merchants with electronic storage of cardholder data
Merchants that don't store cardholder data electronically but that do not meet the criteria of another SAQ type
Merchants with environments that might meet the criteria of another SAQ type, but that have additional PCI DSS
requirements applicable to their environment
While many organizations completing SAQ D will need to validate compliance with every PCI DSS requirement, some
organizations with very specific business models may find that some requirements do not apply. See the guidance below for
information about the exclusion of certain, specific requirements.
PCI DSS Self-Assessment Completion Steps
Identify the applicable SAQ for your environment - refer to the Self-Assessment Questionnaire Instructions and Guidelines
document on PCI SSC website for information.
Confirm that your environment is properly scoped and meets the eligibility criteria for the SAQ you are using.
Assess your environment for compliance with applicable PCI DSS requirements.
Complete all sections of this document:
Section 1 (Part 1 & 2 of the AOC) - Assessment Information and Executive Summary.
Section 2 - PCI DSS Self-Assessment Questionnaire (SAQ D).
Section 3 (Parts 3 & 4 of the AOC) - Validation and Attestation Details and Action Plan for Non-Compliant Requirements
(if applicable)
Submit the SAQ and Attestation of Compliance (AOC), along with any other requested documentation -such as ASV scan
reports- to your acquirer, payment brand or other requester.
Understanding the Self-Assessment Questionnaire
The questions contained in the "PCI DSS Question" column in this self-assessment questionnaire are based on the requirements
in the PCI DSS.
Additional resources that provide guidance on PCI DSS requirements and how to complete the self-assessment questionnaire
have been provided to assist with the assessment process. An overview of some of these resources is provided below:
Document Includes:
PCI DSS
(PCI Data Security Standard Requirements and Security
Assessment Procedures)
Guidance on Scoping
Guidance on the intent of all PCI DSS Requirements
Details of testing procedures
Guidance on Compensating Controls
SAQ Instructions and Guidelines documents Information about all SAQs and their eligibility criteria
How to determine which SAQ is right for your organization
PCI DSS and PA-DSS Glossary of Terms, Abbreviations,
and Acronyms
Descriptions and definitions of terms used in the PCI DSS and
self-assessment questionnaires
These and other resources can be found on the PCI SSC website (www.pcisecuritystandards.org). Organizations are encouraged to
review the PCI DSS and other supporting documents before beginning an assessment.
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PCI DSS v3.2.1 SAQ D, Rev. 1.0
© 2006-2018 PCI Security Standards Council, LLC. All Rights Reserved.
Completing the Self-Assessment Questionnaire
For each question, there is a choice of responses to indicate your company's status regarding that requirement. Only one
response should be selected for each question.
A description of the meaning for each response is provided in the table below:
Response When to use this response:
Yes The expected testing has been performed, and all elements of the requirement have been met as stated.
Yes with CCW
(Compensating
Control
Worksheet)
The expected testing has been performed, and the requirement has been met with the assistance of a
compensating control.
All responses in this column require completion of a Compensating Control Worksheet (CCW) in Appendix B of
the SAQ.
Information on the use of compensating controls and guidance on how to complete the worksheet is provided
in the PCI DSS.
No Some or all elements of the requirement have not been met, or are in the process of being implemented, or
require further testing before it will be known if they are in place.
N/A
(Not
Applicable)
The requirement does not apply to the organization's environment. (See Guidance for Non-Applicability of
Certain, Specific Requirements below for examples.)
All responses in this column require a supporting explanation in Appendix C of the SAQ.
Not Tested The requirement was not included for consideration in the assessment, and was not tested in any way. (See
Understanding the difference between Not Applicable and Not Tested below for examples of when this option
should be used.)
All responses in this column require a supporting explanation in Appendix D of the SAQ.
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PCI DSS v3.2.1 SAQ D, Rev. 1.0
© 2006-2018 PCI Security Standards Council, LLC. All Rights Reserved.
Guidance for Non-Applicability of Certain, Specific Requirements
While many organizations completing SAQ D will need to validate compliance with every PCI DSS requirement, some
organizations with very specific business models may find that some requirements do not apply. For example, a company that
does not use wireless technology in any capacity would not be expected to validate compliance with the sections of the PCI DSS
that are specific to managing wireless technology. Similarly, an organization that does not store any cardholder data electronically
at any time would not need to validate requirements related to secure storage of cardholder data (for example, Requirement 3.4).
Examples of requirements with specific applicability include:
The questions specific to securing wireless technologies (for example, Requirements 1.2.3, 2.1.1, and 4.1.1) only need to be
answered if wireless is present anywhere in your network. Note that Requirement 11.1 (use of processes to identify
unauthorized wireless access points) must still be answered even if you don't use wireless technologies in your network,
since the process detects any rogue or unauthorized devices that may have been added without your knowledge.
The questions specific to application development and secure coding (Requirements 6.3 and 6.5) only need to be answered
if your organization develops its own custom applications.
The questions for Requirements 9.1.1 and 9.3 only need to be answered for facilities with "sensitive areas" as defined here:
"Sensitive areas" refers to any data center, server room or any area that houses systems that store, process, or transmit
cardholder data. This excludes the areas where only point-of-sale terminals are present, such as the cashier areas in a retail
store, but does include retail store back-office server rooms that store cardholder data, and storage areas for large
quantities of cardholder data.
If any requirements are deemed not applicable to your environment, select the "N/A" option for that specific requirement, and
complete the "Explanation of Non-Applicability" worksheet in Appendix C for each "N/A" entry.
Understanding the difference between Not Applicable and Not Tested
Requirements that are deemed to be not applicable to an environment must be verified as such. Using the wireless example
above, for an organization to select "N/A" for Requirements 1.2.3, 2.1.1, and 4.1.1, the organization would first need to confirm
that there are no wireless technologies used in their CDE or that connect to their CDE. Once this has been confirmed, the
organization may select "N/A" for those specific requirements.
If a requirement is completely excluded from review without any consideration as to whether it could apply, the "Not Tested"
option should be selected. Examples of situations where this could occur may include:
An organization may be asked by their acquirer to validate a subset of requirements -for example: using the prioritized
approach to validate certain milestones.
An organization may wish to validate a new security control that impacts only a subset of requirements -for example,
implementation of a new encryption methodology that requires assessment of PCI DSS Requirements 2, 3 and 4.
A service provider organization might offer a service which covers only a limited number of PCI DSS requirements -for
example, a physical storage provider may only wish to validate the physical security controls per PCI DSS Requirement 9 for
their storage facility.
In these scenarios, the organization only wishes to validate certain PCI DSS requirements even though other requirements might
also apply to their environment.
Legal Exception
If your organization is subject to a legal restriction that prevents the organization from meeting a PCI DSS requirement, check the
"No" column for that requirement and complete the relevant attestation in Part 3.
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PCI DSS v3.2.1 SAQ D, Rev. 1.0
© 2006-2018 PCI Security Standards Council, LLC. All Rights Reserved.
Section 1: Assessment Information
Instructions for Submission
This document must be completed as a declaration of the results of the merchant's self-assessment with the Payment Card
Industry Data Security Standard Requirements and Security Assessment Procedures (PCI DSS). Complete all sections: The
merchant is responsible for ensuring that each section is completed by the relevant parties, as applicable. Contact acquirer
(merchant bank) or the payment brands to determine reporting and submission procedures.
Part 1. Merchant and Qualified Security Assessor Information
Part 1a. Merchant Organisation Information
Company Name: OPENPATH INC DBA (doing
business as):
OPENPATH INC
Contact Name: Jason Martin Title: Chief Technology Officer
ISA Name(s) (if applicable): Title:
Telephone: 9496125210 E-mail: J@OPENPATH.IO
Business Address: JOE WATKINS
200 SPECTRUM CENTER DR
IRVINE
CA
92614
Country: USA
URL:
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PCI DSS v3.2.1 SAQ D, Rev. 1.0
© 2006-2018 PCI Security Standards Council, LLC. All Rights Reserved.
Part 1b. Qualified Security Assessor Company Information (if applicable)
Company Name:
Lead QSA Contact Name: Title:
Telephone: Email:
Business Address:
Country:
URL:
Part 2. Executive Summary
Part 2a. Type of Merchant Business (check all that apply)
Retailer Telecommunications Grocery and Supermarkets
Petroleum E-Commerce Mail order/telephone order (MOTO)
Others (please specify):
What types of payment channels does your business serve?
Mail order/telephone order (MOTO)
x E-Commerce
Card-present (face-to-face)
Which payment channels are covered by this SAQ?
Mail order/telephone order (MOTO)
x E-Commerce
Card-present (face-to-face)
Note: If your organization has a payment channel or process that is not covered by this SAQ, consult your acquirer or payment
brand about validation for the other channels.
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© 2006-2018 PCI Security Standards Council, LLC. All Rights Reserved.
Part 2b. Description of Payment Card Business
How and in what capacity does your business store, process
and/or transmit cardholder data?
Part 2c. Locations
List types of facilities (for example, retail outlets, corporate offices, data centers, call centers, etc.)and a summary of locations
included in the PCI DSS review.
Type of facility Number of facilities of this type Location(s) of facility (city, country)
Part 2d. Payment Application
Does the organization use one or more Payment Applications?
Yes
x
No
Provide the following information regarding the Payment Applications your organization uses:
Payment Application Name Version
Number
Application Vendor Is application PA-DSS
Listed
PA-DSS Listing Expiry
date (if applicable)
Yes No
Part 2e. Description of Environment
Provide a high-level description of the environment covered by this assessment.
For example:
Connections into and out of the cardholder data environment (CDE).
Critical system components within the CDE, such as POS devices, databases,
web servers, etc., and any other necessary payment components, as
applicable.
Does your business use network segmentation to affect the scope of your PCI DSS environment?
(Refer to "Network Segmentation" section of PCI DSS for guidance on network segmentation)
x
Yes
No
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PCI DSS v3.2.1 SAQ D, Rev. 1.0
© 2006-2018 PCI Security Standards Council, LLC. All Rights Reserved.
Part 2f. Third-Party Service Providers
Does your company use a Qualified Integrator & Reseller (QIR)?
If Yes:
Name of QIR Company:
QIR Individual Name:
Description of services provided by QIR:
Yes
x
No
Does your company share cardholder data with any third-party service providers (for example, Qualified
Integrator & Resellers (QIR), gateways, payment processors, payment service providers (PSP), web-hosting
companies, airline booking agents, loyalty program agents, etc.)?
x
Yes
No
If Yes:
Name of service provider: Description of services provided:
Microsoft Corp Hosting
First Data Integrated Payment Systems Payment Processing
Custom / bespoke Shopping Cart
Note: Requirement 12.8 applies to all entities in this list.
June 2018
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PCI DSS v3.2.1 SAQ D, Rev. 1.0
© 2006-2018 PCI Security Standards Council, LLC. All Rights Reserved.
Section 2: Self-Assessment Questionnaire D
Note: The following questions are numbered according to PCI DSS requirements and testing procedures, as defined in the PCI
DSS Requirements and Security Assessment Procedures document.
Self-assessment completion date: 04/03/2023
Build and Maintain a Secure Network and Systems
Requirement 1: Install and maintain a firewall configuration to protect cardholder data
PCI DSS Question Response:
(Check one response for each question)
Yes Yes with
CCW
No N/A
1.1 Are firewall and router configuration standards established and implemented to
include the following:
1.1.1 Is there a formal process for approving and testing all network connections and
changes to the firewall and router configurations?
1.1.2
(a)
Is there a current network diagram that documents all connections between the
cardholder data environment and other networks, including any wireless
networks?
1.1.2
(b)
Is there a process to ensure the diagram is kept current?
1.1.3
(a)
Is there a current diagram that shows all cardholder data flows across systems
and networks?
1.1.3
(b)
Is there a process to ensure the diagram is kept current?
1.1.4
(a)
Is a firewall required and implemented at each Internet connection and between
any demilitarized zone (DMZ) and the internal network zone?
1.1.4
(b)
Is the current network diagram consistent with the firewall configuration
standards?
1.1.5 Are groups, roles, and responsibilities for logical management of network
components assigned and documented in the firewall and router configuration
standards?
1.1.6
(a)
Do firewall and router configuration standards include a documented list of
services, protocols, and ports, including business justification and approval for
each?
1.1.6
(b)
Are all insecure services, protocols, and ports identified, and are security features
documented and implemented for each identified service?
1.1.7
(a)
Do firewall and router configuration standards require review of firewall and
router rule sets at least every six months?
1.1.7
(b)
Are firewall and router rule sets reviewed at least every six months?
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1.2 Do firewall and router configurations restrict connections between untrusted
networks and any system in the cardholder data environment as follows:
Note: An "untrusted network" is any network that is external to the networks
belonging to the entity under review, and/or which is out of the entity's ability to
control or manage.
1.2.1
(a)
Is inbound and outbound traffic restricted to that which is necessary for the
cardholder data environment?
1.2.1
(b)
Is all other inbound and outbound traffic specifically denied (for example by using
an explicit "deny all" or an implicit deny after allow statement)?
1.2.2 Are router configuration files secured from unauthorized access and synchronized
- for example, the running (or active) configuration matches the start-up
configuration (used when machines are booted)?
1.2.3 Are perimeter firewalls installed between all wireless networks and the cardholder
data environment, and are these firewalls configured to deny or, if traffic is
necessary for business purposes, permit only authorized traffic between the
wireless environment and the cardholder data environment?
1.3 Is direct public access prohibited between the Internet and any system
component in the cardholder data environment, as follows:
1.3.1 Is a DMZ implemented to limit inbound traffic to only system components that
provide authorized publicly accessible services, protocols, and ports?
1.3.2 Is inbound Internet traffic limited to IP addresses within the DMZ?
1.3.3 Are anti-spoofing measures implemented to detect and block forged sourced IP
addresses from entering the network?
(For example, block traffic originating from the internet with an internal address.)
1.3.4 Is outbound traffic from the cardholder data environment to the Internet explicitly
authorized?
1.3.5 Are only established connections permitted into the network?
1.3.6 Are system components that store cardholder data (such as a database) placed in
an internal network zone, segregated from the DMZ and other untrusted
networks?
1.3.7
(a)
Are methods in place to prevent the disclosure of private IP addresses and routing
information to the Internet?
Note: Methods to obscure IP addressing may include, but are not limited to:
Network Address Translation (NAT)
Placing servers containing cardholder data behind proxy servers/firewalls,
Removal or filtering of route advertisements for private networks that employ
registered addressing,
Internal use of RFC1918 address space instead of registered addresses.
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1.3.7
(b)
Is any disclosure of private IP addresses and routing information to external
entities authorized?
1.4(a) Is personal firewall software (or equivalent functionality) installed and active on
any portable computing devices (including company and/or employee-owned) that
connect to the Internet when outside the network (for example, laptops used by
employees), and which are also used to access the CDE?
1.4(b) Is the personal firewall software (or equivalent functionality) configured to specific
configuration settings, actively running, and not alterable by users of mobile and
/or employee-owned devices?
1.5 Are security policies and operational procedures for managing firewalls:
Documented
In use
Known to all affected parties?
Requirement 2: Do not use vendor-supplied defaults for system passwords and other security
parameters
PCI DSS Question Response:
(Check one response for each question)
Yes Yes with
CCW
No N/A
2.1(a) Are vendor-supplied defaults always changed before installing a system on the
network?
This applies to ALL default passwords, including but not limited to those used by
operating systems, software that provides security services, application and
system accounts, point-of-sale (POS) terminals, payment applications, Simple
Network Management Protocol (SNMP) community strings, etc.
2.1(b) Are unnecessary default accounts removed or disabled before installing a system
on the network?
2.1.1 For wireless environments connected to the cardholder data environment or
transmitting cardholder data, are ALL wireless vendor defaults changed at
installations, as follows:
2.1.1
(a)
Are encryption keys changed from default at installation, and changed anytime
anyone with knowledge of the keys leaves the company or changes positions?
2.1.1
(b)
Are default SNMP community strings on wireless devices changed at installation?
2.1.1
(c)
Are default passwords/passphrases on access points changed at installation?
2.1.1
(d)
Is firmware on wireless devices updated to support strong encryption for
authentication and transmission over wireless networks?
2.1.1
(e)
Are other security-related wireless vendor defaults changed, if applicable?
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2.2(a) Are configuration standards developed for all system components and are they
consistent with industry-accepted system hardening standards?
Sources of industry-accepted system hardening standards may include, but are
not limited to, SysAdmin Audit Network Security (SANS) Institute, National
Institute of Standards Technology (NIST), International Organization for
Standardization (ISO), and Center for Internet Security (CIS).
2.2(b) Are system configuration standards updated as new vulnerability issues are
identified, as defined in Requirement 6.1?
2.2(c) Are system configuration standards applied when new systems are configured?
2.2(d) Do system configuration standards include all of the following:
Changing of all vendor-supplied defaults and elimination of unnecessary
default accounts?
Implementing only one primary function per server to prevent functions that
require different security levels from co-existing on the same server?
Enabling only necessary services, protocols, daemons, etc., as required for the
function of the system?
Implementing additional security features for any required services, protocols
or daemons that are considered to be insecure?
Configuring system security parameters to prevent misuse?
Removing all unnecessary functionality, such as scripts, drivers, features,
subsystems, file systems, and unnecessary web servers?
2.2.1
(a)
Is only one primary function implemented per server, to prevent functions that
require different security levels from co-existing on the same server?
For example, web servers, database servers, and DNS should be implemented on
separate servers.
2.2.1
(b)
If virtualization technologies are used, is only one primary function implemented
per virtual system component or device?
2.2.2
(a)
Are only necessary services, protocols, daemons, etc. enabled as required for the
function of the system (services and protocols not directly needed to perform the
device's specified function are disabled)?
2.2.2
(b)
Are all enabled insecure services, daemons, or protocols justified per documented
configuration standards?
2.2.3 Are additional security features documented and implemented for any required
services, protocols or daemons that are considered to be insecure?
Note: Where SSL/early TLS is used, the requirements in Appendix A2 must be
completed.
2.2.4
(a)
Are system administrators and/or personnel that configure system components
knowledgeable about common security parameter settings for those system
components?
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2.2.4
(b)
Are common system security parameters settings included in the system
configuration standards?
2.2.4
(c)
Are security parameter settings set appropriately on system components?
2.2.5
(a)
Has all unnecessary functionality such as scripts, drivers, features, subsystems, file
systems, and unnecessary web servers been removed?
2.2.5
(b)
Are enabled functions documented and do they support secure configuration?
2.2.5
(c)
Is only documented functionality present on system components?
2.3 Is non-console administrative access encrypted as follows:
Note: Where SSL/early TLS is used, the requirements in Appendix A2 must be
completed
2.3(a) Is all non-console administrative access encrypted with strong cryptography, and
is a strong encryption method invoked before the administrator's password is
requested?
2.3(b) Are system services and parameter files configured to prevent the use of Telnet
and other insecure remote login commands?
2.3(c) Is administrator access to web-based management interfaces encrypted with
strong cryptography?
2.3(d) For the technology in use, is strong cryptography implemented according to
industry best practice and/or vendor recommendations?
2.4(a) Is an inventory maintained for systems components that are in scope for PCI DSS,
including a list of hardware and software components and a description of
function/use for each?
2.4(b) Is the documented inventory kept current?
2.5 Are security policies and operational procedures for managing vendor defaults
and other security parameters:
Documented
In use
Known to all affected parties?
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Protect Cardholder Data
Requirement 3: Protect stored cardholder data
PCI DSS Question Response:
(Check one response for each question)
Yes Yes with
CCW
No N/A
3.1 Are data-retention and disposal policies, procedures, and processes implemented
as follows:
3.1(a) Is data storage amount and retention time limited to that required for legal,
regulatory, and/or business requirements?
3.1(b) Are there defined processes in place for securely deleting cardholder data when
no longer needed for legal, regulatory, and/or business reasons?
3.1(c) Are there specific retention requirements for cardholder data?
For example, cardholder data needs to be held for X period for Y business reasons.
3.1(d) Is there a quarterly process for identifying and securely deleting stored cardholder
data that exceeds defined retention requirements?
3.1(e) Does all stored cardholder data meet the requirements defined in the dataretention policy?
3.2(c) Is sensitive authentication data deleted or rendered unrecoverable upon
completion of the authorization process?
3.2(d) Do all systems adhere to the following requirements regarding non-storage of
sensitive authentication data after authorization (even if encrypted):
3.2.1 The full contents of any track (from the magnetic stripe located on the back of a
card, equivalent data contained on a chip, or elsewhere) are not stored after
authorization?This data is alternatively called full track, track, track 1, track 2, and
magnetic-stripe data.
Note: In the normal course of business, the following data elements from the
magnetic stripe may need to be retained:
The cardholder's name,
Primary account number (PAN),
Expiration date, and
Service code
To minimize risk, store only these data elements as needed for business.
3.2.2 The card verification code or value (three-digit or four-digit number printed on the
front or back of a payment card) is not stored after authorization?
3.2.3 The personal identification number (PIN) or the encrypted PIN block is not stored
after authorization?
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3.3 Is the PAN masked when displayed (the first six and last four digits are the
maximum number of digits to be displayed) such that only personnel with a
legitimate business need can see more than the first six/last four digits of the
PAN?
Note: This requirement does not supersede stricter requirements in place for
displays of cardholder data for example, legal or payment card brand
requirements for point-of-sale (POS) receipts.
3.4 Is PAN rendered unreadable anywhere it is stored (including data repositories,
portable digital media, backup media, and in audit logs), by using any of the
following approaches?
One-way hashes based on strong cryptography (hash must be of the entire
PAN)
Truncation (hashing cannot be used to replace the truncated segment of PAN)
Index tokens and pads (pads must be securely stored)
Strong cryptography with associated key management processes and
procedures.
Note: It is a relatively trivial effort for a malicious individual to reconstruct original
PAN data if they have access to both the truncated and hashed version of a PAN.
Where hashed and truncated versions of the same PAN are present in an entity's
environment, additional controls should be in place to ensure that the hashed and
truncated versions cannot be correlated to reconstruct the original PAN.
3.4.1 If disk encryption (rather than file- or column-level database encryption) is used, is
access managed as follows:
Note: This requirement applies in addition to all other PCI DSS encryption and key
management requirements.
3.4.1
(a)
Is logical access to encrypted file systems managed separately and independently
of native operating system authentication and access control mechanisms (for
example, by not using local user account databases or general network login
credentials)?
3.4.1
(b)
Are cryptographic keys stored securely (for example, stored on removable media
that is adequately protected with strong access controls)?
3.4.1
(c)
Is cardholder data on removable media encrypted wherever stored?
Note: If disk encryption is not used to encrypt removable media, the data stored
on this media will need to be rendered unreadable through some other method.
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3.5 Are keys used to secure stored cardholder data protected against disclosure and
misuse as follows:
Note: This requirement applies to keys used to encrypt stored cardholder data,
and also applies to key-encrypting keys used to protect data-encrypting keys. Such
key-encrypting keys must be at least as strong as the data-encrypting key.
3.5.2 Is access to cryptographic keys restricted to the fewest number of custodians
necessary?
3.5.3 Are secret and private cryptographic keys used to encrypt/decrypt cardholder data
stored in one (or more) of the following forms at all times?
Encrypted with a key-encrypting key that is at least as strong as the dataencrypting key, and that is stored separately from the data-encrypting key
Within a secure cryptographic device (such as a hardware (host) security
module (HSM) or PTS-approved point-of-interaction device)
As at least two full-length key components or key shares, in accordance with
an industry-accepted method.
Note:It is not required that public keys be stored in one of these forms.
3.5.4 Are cryptographic keys stored in the fewest possible locations?
3.6(a) Are all key-management processes and procedures fully documented and
implemented for cryptographic keys used for encryption of cardholder data?
3.6(c) Are key-management processes and procedures implemented to require the
following:
3.6.1 Do cryptographic key procedures include the generation of strong cryptographic
keys?
3.6.2 Do cryptographic key procedures include secure cryptographic key distribution?
3.6.3 Do cryptographic key procedures include secure cryptographic key storage?
3.6.4 Do cryptographic key procedures include cryptographic key changes for keys that
have reached the end of their defined cryptoperiod (for example, after a defined
period of time has passed and/or after a certain amount of cipher-text has been
produced by a given key), as defined by the associated application vendor or key
owner, and based on industry best practices and guidelines (for example, NIST
Special Publication 800-57)?
3.6.5
(a)
Do cryptographic key procedures include retirement or replacement (for example,
archiving, destruction, and/or revocation) of cryptographic keys when the integrity
of the key has been weakened (for example, departure of an employee with
knowledge of a clear-text key)?
3.6.5
(b)
Do cryptographic key procedures include replacement of known or suspected
compromised keys?
3.6.5
(c)
If retired or replaced cryptographic keys are retained, are these keys only used for
decryption/verification purposes, and not used for encryption operations?
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3.6.6 If manual clear-text key-management operations are used, do cryptographic key
procedures include split knowledge and dual control of cryptographic keys as
follows:
Do split knowledge procedures require that key components are under the control
of at least two people who only have knowledge of their own key components?
AND
Do dual control procedures require that at least two people are required to
perform any key management operations and no one person has access to the
authentication materials (for example, passwords or keys) of another?
Note: Examples of manual key management operations include, but are not
limited to: key generation, transmission, loading, storage and destruction.
3.6.7 Do cryptographic key procedures include the prevention of unauthorized
substitution of cryptographic keys?
3.6.8 Are cryptographic key custodians required to formally acknowledge (in writing or
electronically) that they understand and accept their key-custodian
responsibilities?
3.7 Are security policies and operational procedures for protecting stored cardholder
data:
Documented
In use
Known to all affected parties?
Requirement 4: Encrypt transmission of cardholder data across open, public networks
PCI DSS Question Response:
(Check one response for each question)
Yes Yes with
CCW
No N/A
4.1(a) Are strong cryptography and security protocols used to safeguard sensitive
cardholder data during transmission over open, public networks?
Note: Where SSL/early TLS is used, the requirements in Appendix A2 must be
completed.
Examples of open, public networks include but are not limited to the Internet;
wireless technologies, including 802.11 and Bluetooth; cellular technologies, for
example, Global System for Mobile communications (GSM), Code division multiple
access (CDMA); and General Packet Radio Service (GPRS).
4.1(b) Are only trusted keys and/or certificates accepted?
4.1(c) Are security protocols implemented to use only secure configurations, and to not
support insecure versions or configurations?
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4.1(d) Is the proper encryption strength implemented for the encryption methodology in
use (check vendor recommendations/best practices)?
4.1(e) For TLS implementations, is TLS enabled whenever cardholder data is transmitted
or received?
For example, for browser-based implementations:
"HTTPS" appears as the browser Universal Record Locator (URL) protocol, and
Cardholder data is only requested if "HTTPS" appears as part of the URL.
4.1.1 Are industry best practices used to implement strong encryption for
authentication and transmission for wireless networks transmitting cardholder
data or connected to the cardholder data environment?
4.2(a) Are PANs rendered unreadable or secured with strong cryptography whenever
they are sent via end-user messaging technologies (for example, e-mail, instant
messaging, SMS, chat, etc.)?
4.2(b) Are policies in place that state that unprotected PANs are not to be sent via enduser messaging technologies?
4.3 Are security policies and operational procedures for encrypting transmissions of
cardholder data:
Documented
In use
Known to all affected parties?
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Maintain a Vulnerability Management Program
Requirement 5: Protect all systems against malware and regularly update anti-virus software or
programs
PCI DSS Question Response:
(Check one response for each question)
Yes Yes with
CCW
No N/A
5.1 Is anti-virus software deployed on all systems commonly affected by malicious
software?
5.1.1 Are anti-virus programs capable of detecting, removing, and protecting against all
known types of malicious software (for example, viruses, Trojans, worms,
spyware, adware, and rootkits)?
5.1.2 Are periodic evaluations performed to identify and evaluate evolving malware
threats in order to confirm whether those systems considered to not be
commonly affected by malicious software continue as such?
5.2 Are all anti-virus mechanisms maintained as follows:
5.2(a) Are all anti-virus software and definitions kept current?
5.2(b) Are automatic updates and periodic scans enabled and being performed?
5.2(c) Are all anti-virus mechanisms generating audit logs, and are logs retained in
accordance with PCI DSS Requirement 10.7?
5.3 Are all anti-virus mechanisms:
Actively running?
Unable to be disabled or altered by users?
Note: Anti-virus solutions may be temporarily disabled only if there is legitimate
technical need, as authorized by management on a case-by-case basis. If anti-virus
protection needs to be disabled for a specific purpose, it must be formally
authorized. Additional security measures may also need to be implemented for the
period of time during which anti-virus protection is not active.
5.4 Are security policies and operational procedures for protecting systems against
malware:
Documented
In use
Known to all affected parties?
Requirement 6: Develop and maintain secure systems and applications
PCI DSS Question Response:
(Check one response for each question)
Yes Yes with
CCW
No N/A
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6.1 Is there a process to identify security vulnerabilities, including the following:
Using reputable outside sources for vulnerability information?
Assigning a risk ranking to vulnerabilities that includes identification of all
"high" risk and "critical" vulnerabilities?
Note: Risk rankings should be based on industry best practices as well as
consideration of potential impact. For example, criteria for ranking vulnerabilities
may include consideration of the CVSS base score and/or the classification by the
vendor, and/or type of systems affected.
Methods for evaluating vulnerabilities and assigning risk ratings will vary based on
an organization's environment and risk assessment strategy. Risk rankings should,
at a minimum, identify all vulnerabilities considered to be a "high risk" to the
environment. In addition to the risk ranking, vulnerabilities may be considered
"critical" if they pose an imminent threat to the environment, impact critical
systems, and/or would result in a potential compromise if not addressed. Examples
of critical systems may include security systems, public-facing devices and systems,
databases, and other systems that store, process or transmit cardholder data.
6.2(a) Are all system components and software protected from known vulnerabilities by
installing applicable vendor-supplied security patches?
6.2(b) Are critical security patches installed within one month of release?
Note: Critical security patches should be identified according to the risk ranking
process defined in Requirement 6.1.
6.3(a) Are software- development processes based on industry standards and/or best
practices?
6.3(b) Is information security included throughout the software-development life cycle?
6.3(c) Are software applications developed in accordance with PCI DSS (for example,
secure authentication and logging)?
6.3(d) Do software development processes ensure the following at 6.3.1 - 6.3.2:
6.3.1 Are development, test, and/or custom application accounts, user IDs, and
passwords removed before applications become active or are released to
customers?
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6.3.2 Is all custom code reviewed prior to release to production or customers to identify
any potential coding vulnerability (using either manual or automated processes)
as follows:
Are code changes reviewed by individuals other than the originating code
author, and by individuals who are knowledgeable about code review
techniques and secure coding practices?
Do code reviews ensure code is developed according to secure coding
guidelines?
Are appropriate corrections implemented prior to release?
Are code review results reviewed and approved by management prior to
release?
Note: This requirement for code reviews applies to all custom code (both internal
and public-facing), as part of the system development life cycle. Code reviews can
be conducted by knowledgeable internal personnel or third parties. Public-facing
web applications are also subject to additional controls, to address ongoing threats
and vulnerabilities after implementation, as defined at PCI DSS Requirement 6.6.
6.4 Are change control processes and procedures followed for all changes to system
components to include the following:
6.4.1
(a)
Are development/test environments separate from the production environment?
6.4.1
(b)
Is access control in place to enforce the separation between the development/test
environments and the production environment?
6.4.2 Is there separation of duties between personnel assigned to the development/test
environments and those assigned to the production environment?
6.4.3 Are production data (live PANs) not used for testing or development?
6.4.4 Are test data and accounts removed from system components before the system
becomes active / goes into production?
6.4.5
(a)
Are change-control procedures documented and require the following?
Documentation of impact
Documented change control approval by authorized parties
Functionality testing to verify that the change does not adversely impact the
security of the system
Back-out procedures
6.4.5
(b)
Are the following performed and documented for all changes:
6.4.5.1 Documentation of impact?
6.4.5.2 Documented approval by authorized parties?
6.4.5.3
(a)
Functionality testing to verify that the change does not adversely impact the
security of the system?
6.4.5.3
(b)
For custom code changes, testing of updates for compliance with PCI DSS
Requirement 6.5 before being deployed into production?
6.4.5.4 Back-out procedures?
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6.4.6 Upon completion of a significant change, are all relevant PCI DSS requirements
implemented on all new or changed systems and networks, and documentation
updated as applicable?
6.5(a) Do software-development processes address common coding vulnerabilities?
6.5(b) Are developers trained at least annually in up-to-date secure coding techniques,
including how to avoid common coding vulnerabilities?
6.5(c) Are applications developed based on secure coding guidelines to protect
applications from, at a minimum, the following vulnerabilities:
Note: The vulnerabilities listed at 6.5.1 through 6.5.10 were current with industry
best practices when this version of PCI DSS was published. However, as industry
best practices for vulnerability management are updated (for example, the Open
Web Application Security Project (OWASP) Guide, SANS CWE Top 25, CERT Secure
Coding, etc.), the current best practices must be used for these requirements.
6.5.1 Do coding techniques address injection flaws, particularly SQL injection?
Note: Also consider OS Command Injection, LDAP and XPath injection flaws as
well as other injection flaws.
6.5.2 Do coding techniques address buffer overflow vulnerabilities?
6.5.3 Do coding techniques address insecure cryptographic storage?
6.5.4 Do coding techniques address insecure communications?
6.5.5 Do coding techniques address improper error handling?
6.5.6 Do coding techniques address all "high risk" vulnerabilities identified in the
vulnerability identification process (as defined in PCI DSS Requirement 6.1)?
For web applications and application interfaces (internal or external), are
applications developed based on secure coding guidelines to protect applications
from the following additional vulnerabilities:
6.5.7 Do coding techniques address cross-site scripting (XSS) vulnerabilities?
6.5.8 Do coding techniques address improper access control such as insecure direct
object references, failure to restrict URL access, directory traversal, and failure to
restrict user access to functions?
6.5.9 Do coding techniques address cross-site request forgery (CSRF)?
6.5.10 Do coding techniques address broken authentication and session management?
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6.6 For public-facing web applications, are new threats and vulnerabilities addressed
on an ongoing basis, and are these applications protected against known attacks
by applying either of the following methods?
Reviewing public-facing web applications via manual or automated application
vulnerability security assessment tools or methods, as follows:
At least annually
After any changes
By an organization that specializes in application security
That, at a minimum, all vulnerabilities in Requirement 6.5 are included in the
assessment
That all vulnerabilities are corrected
That the application is re-evaluated after the corrections
Note: This assessment is not the same as the vulnerability scans performed for
Requirement 11.2.
- OR -
Installing an automated technical solution that detects and prevents web-based
attacks (for example, a web-application firewall) as follows:
Is situated in front of public-facing web applications to detect and prevent
web-based attacks.
Is actively running and up to date as applicable.
Is generating audit logs.
Is configured to either block web-based attacks, or generate an alert that is
immediately investigated.
6.7 Are security policies and operational procedures for developing and maintaining
secure systems and applications:
Documented
In use
Known to all affected parties?
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Implement Strong Access Control Measures
Requirement 7: Restrict access to cardholder data by business need to know
PCI DSS Question Response:
(Check one response for each question)
Yes Yes with
CCW
No N/A
7.1 Is access to system components and cardholder data limited to only those
individuals whose jobs require such access, as follows:
7.1 Is there a written policy for access control that incorporates the following?
Defining access needs and privilege assignments for each role
Restriction of access to privileged user IDs to least privileges necessary to
perform job responsibilities,
Assignment of access based on individual personnel's job classification and
function
Documented approval (electronically or in writing) by authorized parties for all
access, including listing of specific privileges approved
7.1.1 Are access needs for each role defined, including:
System components and data resources that each role needs to access for
their job function?
Level of privilege required (for example, user, administrator, etc.) for
accessing resources?
7.1.2 Is access to privileged user IDs restricted as follows:
To least privileges necessary to perform job responsibilities?
Assigned only to roles that specifically require that privileged access?
7.1.3 Is access assigned based on individual personnel's job classification and function?
7.1.4 Is documented approval by authorized parties required, specifying required
privileges?
7.2 Is an access control system(s) in place for system components to restrict access
based on a user's need to know, and is it set to "deny all" unless specifically
allowed, as follows:
7.2.1 Is the access control system(s) in place on all system components?
7.2.2 Is the access control system(s) configured to enforce privileges assigned to
individuals based on job classification and function?
7.2.3 Does the access control system(s) have a default "deny-all" setting?
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7.3 Are security policies and operational procedures for restricting access to
cardholder data:
Documented
In use
Known to all affected parties?
Requirement 8: Identify and authenticate access to system components
PCI DSS Question Response:
(Check one response for each question)
Yes Yes with
CCW
No N/A
8.1 Are policies and procedures for user identification management controls defined
and in place for non-consumer users and administrators on all system
components, as follows:
8.1.1 Are all users assigned a unique ID before allowing them to access system
components or cardholder data?
8.1.2 Are additions, deletions, and modifications of user IDs, credentials, and other
identifier objects controlled such that user IDs are implemented only as
authorized (including with specified privileges)?
8.1.3 Is access for any terminated users immediately deactivated or removed?
8.1.4 Are inactive user accounts either removed or disabled within 90 days?
8.1.5
(a)
Are accounts used by third parties to access, support, or maintain system
components via remote access enabled only during the time period needed and
disabled when not in use?
8.1.5
(b)
Are third party remote access accounts monitored when in use?
8.1.6
(a)
Are repeated access attempts limited by locking out the user ID after no more
than six attempts?
8.1.7 Once a user account is locked out, is the lockout duration set to a minimum of 30
minutes or until an administrator enables the user ID?
8.1.8 If a session has been idle for more than 15 minutes, are users required to reauthenticate (for example, re-enter the password) to re-activate the terminal or
session?
8.2 In addition to assigning a unique ID, is one or more of the following methods
employed to authenticate all users?
Something you know, such as a password or passphrase
Something you have, such as a token device or smart card
Something you are, such as a biometric
8.2.1
(a)
Is strong cryptography used to render all authentication credentials (such as
passwords/passphrases) unreadable during transmission and storage on all
system components?
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8.2.2 Is user identity verified before modifying any authentication credential (for
example, performing password resets, provisioning new tokens, or generating
new keys)?
8.2.3
(a)
Are user password parameters configured to require passwords/passphrases
meet the following?
A minimum password length of at least seven characters
Contain both numeric and alphabetic characters
Alternatively, the passwords/passphrases must have complexity and strength at
least equivalent to the parameters specified above.
8.2.4
(a)
Are user passwords/passphrases changed at least once every 90 days?
8.2.5
(a)
Must an individual submit a new password/passphrase that is different from any
of the last four passwords/passphrases he or she has used?
8.2.6 Are passwords/passphrases set to a unique value for each user for first-time use
and upon reset, and must each user change their password immediately after the
first use?
8.3 Is all individual non-console administrative access and all remote access to the
CDE secured using multi-factor authentication as follows:
Note: Multi-factor authentication requires that a minimum of two of the three
authentication methods (see PCI DSS Requirement 8.2 for descriptions of
authentication methods) be used for authentication. Using one factor twice (for
example, using two separate passwords) is not considered multi-factor
authentication.
8.3.1 Is multi-factor authentication incorporated for all non-console access into the CDE
for personnel with administrative access?
8.3.2 Is multi-factor authentication incorporated for all remote network access (both
user and administrator, and including third party access for support or
maintenance) originating from outside the entity's network?
8.4(a) Are authentication policies and procedures documented and communicated to all
users?
8.4(b) Do authentication policies and procedures include the following?
Guidance on selecting strong authentication credentials
Guidance for how users should protect their authentication credentials
Instructions not to reuse previously used passwords
Instructions that users should change passwords if there is any suspicion the
password could be compromised
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8.5 Are group, shared, or generic accounts, passwords, or other authentication
methods prohibited as follows:
Generic user IDs and accounts are disabled or removed;
Shared user IDs for system administration activities and other critical
functions do not exist; and
Shared and generic user IDs are not used to administer any system
components?
8.6 Where other authentication mechanisms are used (for example, physical or logical
security tokens, smart cards, and certificates, etc.), is the use of these mechanisms
assigned as follows?
Authentication mechanisms must be assigned to an individual account and
not shared among multiple accounts
Physical and/or logical controls must be in place to ensure only the intended
account can use that mechanism to gain access
8.7 Is all access to any database containing cardholder data (including access by
applications, administrators, and all other users) restricted as follows:
8.7(a) Is all user access to, user queries of, and user actions on (for example, move,
copy, delete), the database through programmatic methods only (for example,
through stored procedures)?
8.7(b) Is user direct access to or queries to of databases restricted to database
administrators?
8.7(c) Are application IDs only able to be used by the applications (and not by individual
users or other processes)?
8.8 Are security policies and operational procedures for identification and
authentication:
Documented
In use
Known to all affected parties?
Requirement 9: Restrict physical access to cardholder data
PCI DSS Question Response:
(Check one response for each question)
Yes Yes with
CCW
No N/A
9.1 Are appropriate facility entry controls in place to limit and monitor physical access
to systems in the cardholder data environment?
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9.1.1
(a)
Are either video cameras or access-control mechanisms (or both) in place to
monitor individual physical access to sensitive areas?
Note: "Sensitive areas" refers to any data center, server room, or any area that
houses systems that store, process, or transmit cardholder data. This excludes
public-facing areas where only point-of-sale terminals are present such as the
cashier areas in a retail store.
9.1.1
(b)
Are either video cameras or access-control mechanisms (or both) protected from
tampering or disabling?
9.1.1
(c)
Is data collected from video cameras and/or access control mechanisms reviewed
and correlated with other entries?
9.1.1
(d)
Is data collected from video cameras and/or access control mechanisms stored
for at least three months unless otherwise restricted by law?
9.1.2 Are physical and/or logical controls in place to restrict access to publicly accessible
network jacks?
For example, network jacks located in public areas and areas accessible to visitors
could be disabled and only enabled when network access is explicitly authorized.
Alternatively, processes could be implemented to ensure that visitors are escorted
at all times in areas with active network jacks.
9.1.3 Is physical access to wireless access points, gateways, handheld devices,
networking/communications hardware, and telecommunication lines restricted?
9.2(a) Are procedures developed to easily distinguish between onsite personnel and
visitors, which include:
Identifying onsite personnel and visitors (for example, assigning badges),
Changing access requirements, and
Revoking terminated onsite personnel and expired visitor identification (such
as ID badges)
For the purposes of Requirement 9, "onsite personnel" refers to full-time and parttime employees, temporary employees, contractors and consultants who are
physically present on the entity's premises. A "visitor" refers to a vendor, guest of
any onsite personnel, service workers, or anyone who needs to enter the facility for
a short duration, usually not more than one day.
9.2(b) Do identification methods (such as ID badges) clearly identify visitors and easily
distinguish between onsite personnel and visitors?
9.2(c) Is access to the badge system limited to authorized personnel?
9.3 Is physical access to sensitive areas controlled for onsite personnel, as follows:
Is access authorized and based on individual job function?
Is access revoked immediately upon termination
Upon termination, are all physical access mechanisms, such as keys, access
cards, etc., returned or disabled?
9.4 Is visitor identification and access handled as follows:
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9.4.1 Are visitors authorized before entering, and escorted at all times within, areas
where cardholder data is processed or maintained?
9.4.2
(a)
Are visitors identified and given a badge or other identification that visibly
distinguishes the visitors from onsite personnel?
9.4.2
(b)
Do visitor badges or other identification expire?
9.4.3 Are visitors asked to surrender the badge or other identification before leaving the
facility or at the date of expiration?
9.4.4
(a)
Is a visitor log in use to record physical access to the facility as well as for
computer rooms and data centers where cardholder data is stored or
transmitted?
9.4.4
(b)
Does the visitor log contain the visitor's name, the firm represented, and the
onsite personnel authorizing physical access?
9.4.4
(c)
Is the visitor log retained for at least three months?
9.5 Are all media physically secured (including but not limited to computers,
removable electronic media, paper receipts, paper reports, and faxes)?
For purposes of Requirement 9, "media" refers to all paper and electronic media
containing cardholder data.
9.5.1 Is the location where media back-ups are stored reviewed at least annually to
confirm storage is secure?
9.6(a) Is strict control maintained over the internal or external distribution of any kind of
media?
9.6(b) Do controls include the following:
9.6.1 Is media classified so the sensitivity of the data can be determined?
9.6.2 Is media sent by secured courier or other delivery method that can be accurately
tracked?
9.6.3 Is management approval obtained prior to moving the media (especially when
media is distributed to individuals)?
9.7 Is strict control maintained over the storage and accessibility of media?
9.7.1
(a)
Are inventory logs of all media properly maintained?
9.7.1
(b)
Are periodic media inventories conducted at least annually?
9.8(a) Is all media destroyed when it is no longer needed for business or legal reasons?
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9.8(b) Is there a periodic media destruction policy that defines requirements for the
following?
Hard-copy materials must be crosscut shredded, incinerated, or pulped such
that there is reasonable assurance the hard-copy materials cannot be
reconstructed.
Storage containers used for materials that are to be destroyed must be
secured.
Cardholder data on electronic media must be rendered unrecoverable (e.g. via
a secure wipe program in accordance with industry-accepted standards for
secure deletion, or by physically destroying the media).
9.8(c) Is media destruction performed as follows:
9.8.1
(a)
Are hardcopy materials cross-cut shredded, incinerated, or pulped so that
cardholder data cannot be reconstructed?
9.8.1
(b)
Are storage containers used for materials that contain information to be
destroyed secured to prevent access to the contents?
9.8.2 Is cardholder data on electronic media rendered unrecoverable (e.g. via a secure
wipe program in accordance with industry-accepted standards for secure deletion,
or otherwise by physically destroying the media), so that cardholder data cannot
be reconstructed?
9.9 Are devices that capture payment card data via direct physical interaction with the
card protected against tampering and substitution as follows?
Note: This requirement applies to card-reading devices used in card-present
transactions (that is, card swipe or dip) at the point of sale. This requirement is not
intended to apply to manual key-entry components such as computer keyboards
and POS keypads.
9.9(a) Do policies and procedures require that a list of such devices be maintained?
9.9(b) Do policies and procedures require that devices are periodically inspected to look
for tampering or substitution?
9.9(c) Do policies and procedures require that personnel are trained to be aware of
suspicious behavior and to report tampering or substitution of devices?
9.9.1
(a)
Does the list of devices include the following?
Make, model of device
Location of device (for example, the address of the site or facility where the
device is located)
Device serial number or other method of unique identification
9.9.1
(b)
Is the list accurate and up to date?
9.9.1
(c)
Is the list of devices updated when devices are added, relocated, decommissioned,
etc.?
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9.9.2
(a)
Are device surfaces periodically inspected to detect tampering (for example,
addition of card skimmers to devices), or substitution (for example, by checking
the serial number or other device characteristics to verify it has not been swapped
with a fraudulent device) as follows?
Note: Examples of signs that a device might have been tampered with or
substituted include unexpected attachments or cables plugged into the device,
missing or changed security labels, broken or differently colored casing, or
changes to the serial number or other external markings.
9.9.2
(b)
Are personnel aware of procedures for inspecting devices?
9.9.3 Are personnel trained to be aware of attempted tampering or replacement of
devices, to include the following?
9.9.3
(a)
Do training materials for personnel at point-of-sale locations include the
following?
Verify the identity of any third-party persons claiming to be repair or
maintenance personnel, prior to granting them access to modify or
troubleshoot devices.
Do not install, replace, or return devices without verification.
Be aware of suspicious behavior around devices (for example, attempts by
unknown persons to unplug or open devices).
Report suspicious behavior and indications of device tampering or
substitution to appropriate personnel (for example, to a manager or security
officer).
9.9.3
(b)
Have personnel at point-of-sale locations received training, and are they aware of
procedures to detect and report attempted tampering or replacement of devices?
9.10 Are security policies and operational procedures for restricting physical access to
cardholder data:
Documented
In use
Known to all affected parties?
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Regularly Monitor and Test Networks
Requirement 10: Track and monitor all access to network resources and cardholder data
PCI DSS Question Response:
(Check one response for each question)
Yes Yes with
CCW
No N/A
10.1(a) Are audit trails enabled and active for system components?
10.1
(b)
Is access to system components linked to individual users?
10.2 Are automated audit trails implemented for all system components to reconstruct
the following events:
10.2.1 All individual user accesses to cardholder data?
10.2.2 All actions taken by any individual with root or administrative privileges?
10.2.3 Access to all audit trails?
10.2.4 Invalid logical access attempts?
10.2.5 Use of and changes to identification and authentication mechanisms-including but
not limited to creation of new accounts and elevation of privileges - and all
changes, additions, or deletions to accounts with root or administrative privileges?
10.2.6 Initialization, stopping, or pausing of the audit logs?
10.2.7 Creation and deletion of system-level objects?
10.3 Are the following audit trail entries recorded for all system components for each
event:
10.3.1 User identification?
10.3.2 Type of event?
10.3.3 Date and time?
10.3.4 Success or failure indication?
10.3.5 Origination of event?
10.3.6 Identity or name of affected data, system component, or resource?
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10.4 Are all critical system clocks and times synchronized through use of time
synchronization technology, and is the technology kept current?
Note: One example of time synchronization technology is Network Time Protocol
(NTP).
10.4.1 Are the following processes implemented for critical systems to have the correct
and consistent time:
10.4.1
(a)
Do only designated central time server(s) receive time signals from external
sources, and are time signals from external sources based on International Atomic
Time or UTC?
10.4.1
(b)
Where there is more than one designated time server, do the time servers peer
with each other to keep accurate time?
10.4.1
(c)
Do systems receive time only from designated central time server(s)?
10.4.2 Is time data protected as follows:
10.4.2
(a)
Is access to time data restricted to only personnel with a business need to access
time data?
10.4.2
(b)
Are changes to time settings on critical systems logged, monitored, and reviewed?
10.4.3 Are time settings received from specific, industry-accepted time sources? (This is
to prevent a malicious individual from changing the clock).
Optionally, those updates can be encrypted with a symmetric key, and access
control lists can be created that specify the IP addresses of client machines that
will be provided with the time updates (to prevent unauthorized use of internal
time servers).
10.5 Are audit trails secured so they cannot be altered, as follows:
10.5.1 Is viewing of audit trails limited to those with a job-related need?
10.5.2 Are audit trail files protected from unauthorized modifications via access control
mechanisms, physical segregation, and/or network segregation?
10.5.3 Are audit trail files promptly backed up to a centralized log server or media that is
difficult to alter?
10.5.4 Are logs for external-facing technologies (for example, wireless, firewalls, DNS,
mail) written onto a secure, centralized, internal log server or media?
10.5.5 Is file-integrity monitoring or change-detection software used on logs to ensure
that existing log data cannot be changed without generating alerts (although new
data being added should not cause an alert)?
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10.6 Are logs and security events for all system components reviewed to identify
anomalies or suspicious activity as follows?
Note: Log harvesting, parsing, and alerting tools may be used to achieve
compliance with Requirement 10.6.
10.6.1
(a)
Are written policies and procedures defined for reviewing the following at least
daily, either manually or via log tools?
All security events
Logs of all system components that store, process, or transmit CHD and/or
SAD, or that could impact the security of CHD and/or SAD
Logs of all critical system components
Logs of all servers and system components that perform security functions
(for example, firewalls, intrusion-detection systems/intrusion-prevention
systems (IDS/IPS), authentication servers, e-commerce redirection servers,
etc.)
10.6.1
(b)
Are the above logs and security events reviewed at least daily?
10.6.2
(a)
Are written policies and procedures defined for reviewing logs of all other system
components periodically either manually or via log tools based on the
organization's policies and risk management strategy?
10.6.2
(b)
Are reviews of all other system components performed in accordance with
organization's policies and risk management strategy?
10.6.3
(a)
Are written policies and procedures defined for following up on exceptions and
anomalies identified during the review process?
10.6.3
(b)
Is follow up to exceptions and anomalies performed?
10.7(a) Are audit log retention policies and procedures in place and do they require that
logs are retained for at least one year, with a minimum of three months
immediately available for analysis (for example, online, archived, or restorable
from backup)?
10.7
(b)
Are audit logs retained for at least one year?
10.7(c) Are at least the last three months' logs immediately available for analysis?
10.9 Are security policies and operational procedures for monitoring all access to
network resources and cardholder data:
Documented
In use
Known to all affected parties?
Requirement 11: Regularly test security systems and processes.
PCI DSS Question Response:
(Check one response for each question)
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Yes Yes with
CCW
No N/A
11.1(a) Are processes implemented for detection and identification of both authorized
and unauthorized wireless access points on a quarterly basis?
Note: Methods that may be used in the process include, but are not limited to,
wireless network scans, physical/logical inspections of system components and
infrastructure, network access control (NAC), or wireless IDS/IPS.
Whichever methods are used, they must be sufficient to detect and identify any
unauthorized devices.
11.1
(b)
Does the methodology detect and identify any unauthorized wireless access
points, including at least the following?
WLAN cards inserted into system components;
Portable or mobile devices attached to system components to create a
wireless access point (for example, by USB, etc.); and
Wireless devices attached to a network port or network device.
11.1(c) If wireless scanning is utilized to identify authorized and unauthorized wireless
access points, is the scan performed at least quarterly for all system components
and facilities?
11.1
(d)
If automated monitoring is utilized (for example, wireless IDS/IPS, NAC, etc.), is
monitoring configured to generate alerts to notify personnel?
11.1.1 Is an inventory of authorized wireless access points maintained and a business
justification documented for all authorized wireless access points?
11.1.2
(a)
Does the incident response plan define and require a response in the event that
an unauthorized wireless access point is detected?
11.1.2
(b)
Is action taken when unauthorized wireless access points are found?
11.2 Are internal and external network vulnerability scans run at least quarterly and
after any significant change in the network (such as new system component
installations, changes in network topology, firewall rule modifications, product
upgrades), as follows?
Note: Multiple scan reports can be combined for the quarterly scan process to
show that all systems were scanned and all applicable vulnerabilities have been
addressed. Additional documentation may be required to verify non-remediated
vulnerabilities are in the process of being addressed.
For initial PCI DSS compliance, it is not required that four quarters of passing
scans be completed if the assessor verifies 1) the most recent scan result was a
passing scan, 2) the entity has documented policies and procedures requiring
quarterly scanning, and 3) vulnerabilities noted in the scan results have been
corrected as shown in a re-scan(s). For subsequent years after the initial PCI DSS
review, four quarters of passing scans must have occurred.
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11.2.1
(a)
Are quarterly internal vulnerability scans performed?
11.2.1
(b)
Does the quarterly internal scan process address all "high risk" vulnerabilities and
include rescans to verify all "high-risk" vulnerabilities (as defined in PCI DSS
Requirement 6.1) are resolved?
11.2.1
(c)
Are quarterly internal scans performed by a qualified internal resource(s) or
qualified external third party, and if applicable, does organizational independence
of the tester exist (not required to be a QSA or ASV)?
11.2.2
(a)
Are quarterly external vulnerability scans performed?
Note: Quarterly external vulnerability scans must be performed by an Approved
Scanning Vendor (ASV), approved by the Payment Card Industry Security
Standards Council (PCI SSC).
Refer to the ASV Program Guide published on the PCI SSC website for scan
customer responsibilities, scan preparation, etc.
11.2.2
(b)
Do external quarterly scan and rescan results satisfy the ASV Program Guide
requirements for a passing scan (for example, no vulnerabilities rated 4.0 or
higher by the CVSS, and no automatic failures)?
11.2.2
(c)
Are quarterly external vulnerability scans performed by a PCI SSC Approved
Scanning Vendor (ASV)?
11.2.3
(a)
Are internal and external scans, and rescans as needed, performed after any
significant change?
Note: Scans must be performed by qualified personnel.
11.2.3
(b)
Does the scan process include rescans until:
For external scans, no vulnerabilities exist that are scored 4.0 or higher by the
CVSS,
For internal scans, a passing result is obtained or all "high-risk" vulnerabilities
as defined in PCI DSS Requirement 6.1 are resolved?
11.2.3
(c)
Are scans performed by a qualified internal resource(s) or qualified external third
party, and if applicable, does organizational independence of the tester exist (not
required to be a QSA or ASV)?
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11.3 Does the penetration-testing methodology include the following?
Is based on industry-accepted penetration testing approaches (for example,
NIST SP800-115)
Includes coverage for the entire CDE perimeter and critical systems
Includes testing from both inside and outside the network
Includes testing to validate any segmentation and scope-reduction controls
Defines application-layer penetration tests to include, at a minimum, the
vulnerabilities listed in Requirement 6.5
Defines network-layer penetration tests to include components that support
network functions as well as operating systems
Includes review and consideration of threats and vulnerabilities experienced
in the last 12 months
Specifies retention of penetration testing results and remediation activities
results
11.3.1
(a)
Is external penetration testing performed per the defined methodology, at least
annually, and after any significant infrastructure or application changes to the
environment (such as an operating system upgrade, a sub-network added to the
environment, or an added web server)?
11.3.1
(b)
Are tests performed by a qualified internal resource or qualified external third
party, and if applicable, does organizational independence of the tester exist (not
required to be a QSA or ASV)?
11.3.2
(a)
Is internal penetration testing performed per the defined methodology, at least
annually, and after any significant infrastructure or application changes to the
environment (such as an operating system upgrade, a sub-network added to the
environment, or an added web server)?
11.3.2
(b)
Are tests performed by a qualified internal resource or qualified external third
party, and if applicable, does organizational independence of the tester exist (not
required to be a QSA or ASV)?
11.3.3 Are exploitable vulnerabilities found during penetration testing corrected,
followed by repeated testing to verify the corrections?
11.3.4 If segmentation is used to isolate the CDE from other networks:
11.3.4
(a)
Are penetration-testing procedures defined to test all segmentation methods, to
confirm they are operational and effective, and isolate all out-of-scope systems
from systems in the CDE?
11.3.4
(b)
Does penetration testing to verify segmentation controls meet the following?
Performed at least annually and after any changes to segmentation controls
/methods
Covers all segmentation controls/methods in use
Verifies that segmentation methods are operational and effective, and isolate
all out-of-scope systems from systems in the CDE.
11.3.4
(c)
Are tests performed by a qualified internal resource or qualified external third
party, and if applicable, does organizational independence of the tester exist (not
required to be a QSA or ASV)?
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11.4(a) Are intrusion-detection and/or intrusion-prevention techniques that detect and/or
prevent intrusions into the network in place to monitor all traffic:
At the perimeter of the cardholder data environment, and
At critical points in the cardholder data environment.
11.4
(b)
Are intrusion-detection and/or intrusion-prevention techniques configured to alert
personnel of suspected compromises?
11.4(c) Are all intrusion-detection and prevention engines, baselines, and signatures kept
up-to-date?
11.5(a) Is a change-detection mechanism (for example, file-integrity monitoring tools)
deployed to detect unauthorized modification (including changes, additions, and
deletions) of critical system files, configuration files, or content files?
Examples of files that should be monitored include:
System executables
Application executables
Configuration and parameter files
Centrally stored, historical or archived, log, and audit files
Additional critical files determined by entity (for example, through risk
assessment or other means)
11.5
(b)
Is the change-detection mechanism configured to alert personnel to unauthorized
modification (including changes, additions, and deletions) of critical system files,
configuration files or content files, and do the tools perform critical file
comparisons at least weekly?
Note: For change detection purposes, critical files are usually those that do not
regularly change, but the modification of which could indicate a system
compromise or risk of compromise. Change detection mechanisms such as fileintegrity monitoring products usually come pre-configured with critical files for
the related operating system. Other critical files, such as those for custom
applications, must be evaluated and defined by the entity (that is the merchant or
service provider).
11.5.1 Is a process in place to respond to any alerts generated by the change-detection
solution?
11.6 Are security policies and operational procedures for security monitoring and
testing:
Documented
In use
Known to all affected parties?
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Maintain an Information Security Policy
Requirement 12: Maintain a policy that addresses information security for all personnel.
Note: For the purposes of Requirement 12, "personnel" refers to full-time part-time employees, temporary employees and
personnel, and contractors and consultants who are "resident" on the entity's site or otherwise have access to the company's site
cardholder data environment.
PCI DSS Question Response:
(Check one response for each question)
Yes Yes with
CCW
No N/A
12.1 Is a security policy established, published, maintained, and disseminated to all
relevant personnel?
12.1.1 Is the security policy reviewed at least annually and updated when the
environment changes?
12.2(a) Is an annual risk assessment process implemented that
Identifies critical assets, threats, and vulnerabilities, and
Results in a formal, documented analysis of risk?
Examples of risk assessment methodologies include but are not limited to
OCTAVE, ISO 27005 and NIST SP 800-30.
12.2(b) Is the risk assessment process performed at least annually and upon significant
changes to the environment (for example, acquisition, merger, relocation, etc.)?
12.3 Are usage policies for critical technologies developed to define proper use of
these technologies and require the following:
Note: Examples of critical technologies include, but are not limited to, remote
access and wireless technologies, laptops, tablets, removable electronic media, email usage and Internet usage.
12.3.1 Explicit approval by authorized parties to use the technologies?
12.3.2 Authentication for use of the technology?
12.3.3 A list of all such devices and personnel with access?
12.3.4 A method to accurately and readily determine owner, contact information, and
purpose (for example, labeling, coding, and/or inventorying of devices)?
12.3.5 Acceptable uses of the technologies?
12.3.6 Acceptable network locations for the technologies?
12.3.7 List of company-approved products?
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12.3.8 Automatic disconnect of sessions for remote-access technologies after a specific
period of inactivity?
12.3.9 Activation of remote-access technologies for vendors and business partners only
when needed by vendors and business partners, with immediate deactivation
after use?
12.3.10
(a)
For personnel accessing cardholder data via remote-access technologies, does the
policy specify the prohibition of copying, moving, and storage of cardholder data
onto local hard drives and removable electronic media, unless explicitly
authorized for a defined business need?
Where there is an authorized business need, the usage policies must require the
data be protected in accordance with all applicable PCI DSS Requirements.
12.3.10
(b)
For personnel with proper authorization, does the policy require the protection of
cardholder data in accordance with PCI DSS Requirements?
12.4 Do security policy and procedures clearly define information security
responsibilities for all personnel?
12.5(a) Is responsibility for information security formally assigned to a Chief Security
Officer or other security-knowledgeable member of management?
12.5(b) Are the following information security management responsibilities formally
assigned to an individual or team:
12.5.1 Establishing, documenting, and distributing security policies and procedures?
12.5.2 Monitoring and analyzing security alerts and information, and distributing to
appropriate personnel?
12.5.3 Establishing, documenting, and distributing security incident response and
escalation procedures to ensure timely and effective handling of all situations?
12.5.4 Administering user accounts, including additions, deletions, and modifications?
12.5.5 Monitoring and controlling all access to data?
12.6(a) Is a formal security awareness program in place to make all personnel aware of
the cardholder data security policy and procedures?
12.6(b) Do security awareness program procedures include the following:
12.6.1
(a)
Does the security awareness program provide multiple methods of
communicating awareness and educating personnel (for example, posters, letters,
memos, web based training, meetings, and promotions)?
Note: Methods can vary depending on the role of the personnel and their level of
access to the cardholder data.
12.6.1
(b)
Are personnel educated upon hire and at least annually?
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12.6.1
(c)
Have employees completed awareness training and are they aware of the
importance of cardholder data security?
12.6.2 Are personnel required to acknowledge at least annually that they have read and
understood the security policy and procedures?
12.7 Are potential personnel (see definition of "personnel" above) screened prior to
hire to minimize the risk of attacks from internal sources?
Examples of background checks include previous employment history, criminal
record, credit history and reference checks.
Note: For those potential personnel to be hired for certain positions, such as store
cashiers who only have access to one card number at a time when facilitating a
transaction, this requirement is a recommendation only.
12.8 Are policies and procedures maintained and implemented to manage service
providers with whom cardholder data is shared, or that could affect the security
of cardholder data, as follows:
12.8.1 Is a list of service providers maintained, including a description of the service(s)
provided?
12.8.2 Is a written agreement maintained that includes an acknowledgement that the
service providers are responsible for the security of cardholder data the service
providers possess or otherwise store, process, or transmit on behalf of the
customer, or to the extent that they could impact the security of the customer's
cardholder data environment?
Note: The exact wording of an acknowledgement will depend on the agreement
between the two parties, the details of the service being provided, and the
responsibilities assigned to each party. The acknowledgement does not have to
include the exact wording provided in this requirement.
12.8.3 Is there an established process for engaging service providers, including proper
due diligence prior to engagement?
12.8.4 Is a program maintained to monitor service providers' PCI DSS compliance status
at least annually?
12.8.5 Is information maintained about which PCI DSS requirements are managed by
each service provider, and which are managed by the entity?
12.10 Has an incident response plan been implemented in preparation to respond
immediately to a system breach, as follows:
12.10.1
(a)
Has an incident response plan been created to be implemented in the event of
system breach?
12.10.1
(b)
Does the plan address the following, at a minimum:
12.10.1
(b)(i)
Roles, responsibilities, and communication and contact strategies in the event of a
compromise including notification of the payment brands, at a minimum?
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12.10.1
(b)(ii)
Specific incident response procedures?
12.10.1
(b)(iii)
Business recovery and continuity procedures?
12.10.1
(b)(iv)
Data backup processes?
12.10.1
(b)(v)
Analysis of legal requirements for reporting compromises?
12.10.1
(b)(vi)
Coverage and responses of all critical system components?
12.10.1
(b)(vii)
Reference or inclusion of incident response procedures from the payment
brands?
12.10.2 Is the plan reviewed and tested at least annually, including all elements listed in
Requirement 12.10.1?
12.10.3 Are specific personnel designated to be available on a 24/7 basis to respond to
alerts?
12.10.4 Is appropriate training provided to staff with security breach response
responsibilities?
12.10.5 Are alerts from security monitoring systems included in the incident response
plan?
12.10.6 Is a process developed and in place to modify and evolve the incident response
plan according to lessons learned and to incorporate industry developments?
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Appendix A: Additional PCI DSS Requirements for Shared
Hosting Providers
This appendix is not used for merchant assessments.
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Appendix B: Compensating Controls Worksheet
Use this worksheet to define compensating controls for any requirement where "YES with CCW" was checked.
Note: Only companies that have undertaken a risk analysis and have legitimate technological or documented business constraints
can consider the use of compensating controls to achieve compliance.
Refer to Appendices B, C, and D of PCI DSS for information about compensating controls and guidance on how to complete this
worksheet.
Requirement Number and Definition:
Information required Explanation
1. Constraints List constraints precluding compliance with
the original requirement.
2. Objective Define the objective of the original control;
identify the objective met by the
compensating control.
3. Identified Risk Identify any additional risk posed by the
lack of the original control.
4. Definition of Compensating
Controls
Define the compensating controls and
explain how they address the objectives of
the original control and the increased risk,
if any
5. Validation of Compensating
Controls
Define how the compensating controls
were validated and tested.
6. Maintenance Define process and controls in place to
maintain compensating controls.
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Appendix C: Explanation of Non-Applicability
If the "N/A" (Not Applicable) column was checked in the questionnaire, use this worksheet to explain why the related requirement
is not applicable to your organization.
Requirement Reason Requirement is Not Applicable
1.2.3 This question is specific to the use of wireless technology and only needs to be answered if such
technology is present anywhere in your network. You have indicated in your profile that you do not
use wireless technology in your network.
2.1.1(a) This question is specific to the use of wireless technology and only needs to be answered if such
technology is present anywhere in your network. You have indicated in your profile that you do not
use wireless technology in your network.
2.1.1(b) This question is specific to the use of wireless technology and only needs to be answered if such
technology is present anywhere in your network. You have indicated in your profile that you do not
use wireless technology in your network.
2.1.1(c) This question is specific to the use of wireless technology and only needs to be answered if such
technology is present anywhere in your network. You have indicated in your profile that you do not
use wireless technology in your network.
2.1.1(d) This question is specific to the use of wireless technology and only needs to be answered if such
technology is present anywhere in your network. You have indicated in your profile that you do not
use wireless technology in your network.
2.1.1(e) This question is specific to the use of wireless technology and only needs to be answered if such
technology is present anywhere in your network. You have indicated in your profile that you do not
use wireless technology in your network.
4.1.1 This question is specific to the use of wireless technology and only needs to be answered if such
technology is present anywhere in your network. You have indicated in your profile that you do not
use wireless technology in your network.
8.1.5(a) This question is specific to users that connect remotely (i.e. from outside your network) to systems
that contain cardholder data and only needs to be answered if you allow users to access systems that
contain cardholder data remotely. You have indicated in your profile that you do not permit users to
access systems that contain cardholder data remotely.
8.1.5(b) This question is specific to users that connect remotely (i.e. from outside your network) to systems
that contain cardholder data and only needs to be answered if you allow users to access systems that
contain cardholder data remotely. You have indicated in your profile that you do not permit users to
access systems that contain cardholder data remotely.
8.3.2 This question is specific to users that connect remotely (i.e. from outside your network) to systems
that contain cardholder data and only needs to be answered if you allow users to access systems that
contain cardholder data remotely. You have indicated in your profile that you do not permit users to
access systems that contain cardholder data remotely.
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Annotation
MIDs/ Accounts covered by this Attestation-of-Compliance
Mid / Account Company name Address Line 1
208200210887 OPENPATH INC JOE WATKINS, 200 SPECTRUM CENTER DR,
IRVINE, CA, 92614
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Section 3: Validation and Attestation Details
Part 3. PCI DSS Validation:
Based on the results noted in the SAQ D dated 04/03/2023, the signatories identified in Parts 3b-3d, as applicable, assert(s) the
following compliance status for the entity identified in Part 2 of this document as of 04/03/2023 (check one):
x
Compliant: All sections of the PCI DSS SAQ are complete, all questions answered affirmatively, resulting in an overall
COMPLIANT rating; thereby OPENPATH INC has demonstrated full compliance with the PCI DSS.
Non-Compliant: Not all sections of the PCI DSS SAQ are complete, or not all questions are answered affirmatively,
resulting in an overall NON-COMPLIANT rating, thereby OPENPATH INC has not demonstrated full compliance with the
PCI DSS.
Target Date for Compliance:
An entity submitting this form with a status of Non-Compliant may be required to complete the Action Plan in Part 4 of
this document. Check with your acquirer or the payment brand(s) before completing Part 4.
Compliant but with Legal exception: One or more requirements are marked "No" due to a legal restriction that
prevents the requirement from being met. This option requires additional review from acquirer or payment brand.
June 2018
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PCI DSS v3.2.1 SAQ D, Rev. 1.0
© 2006-2018 PCI Security Standards Council, LLC. All Rights Reserved.
Part 3a. Acknowledgement of Status
Signatory(s) confirms:
(Check all that apply)
x
PCI DSS Self-Assessment Questionnaire D , Version 3.2.1, was completed according to the instructions therein.
x
All information within the above-referenced SAQ and in this attestation fairly represents the results of my assessment
in all material respects.
x
I have read the PCI DSS and I recognize that I must maintain PCI DSS compliance, as applicable to my environment, at
all times.
x
If my environment changes, I recognize I must reassess my environment and implement any additional PCI DSS
requirements that apply.
x No evidence of full track data , CAV2, CVC2, CID or CVV2 data , or PIN data storage after transaction authorization 2 3 4
was found on ANY system reviewed during this assessment.
x
ASV scans are being completed by the PCI SSC Approved Scanning Vendor (ASV Name)
Part 3b. Merchant Attestation
Signature of Merchant Executive Officer
This was electronically signed by openpathinc on behalf of OPENPATH INC
Date:
04/03/2023
Merchant Executive Officer Name:
Jason Martin
Title:
Chief Technology Officer
Part 3c. QSA Acknowledgement (if applicable)
If a QSA was involved or assisted with this assessment, describe the role
performed:
Signature of Duly Authorized Officer of QSA Company Date:
Duly Authorized Officer Name: QSA Company:
June 2018
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PCI DSS v3.2.1 SAQ D, Rev. 1.0
© 2006-2018 PCI Security Standards Council, LLC. All Rights Reserved.
Part 3d. ISA Acknowledgement (if applicable)
If a ISA was involved or assisted with this assessment, describe the role
performed:
Signature of ISA Date:
ISA Name: Title:
Data encoded in the magnetic stripe or equivalent data on a chip used for authorization during a card-present transaction. 2
Entities may not retain full track data after transaction authorization. The only elements of track data that may be retained are
primary account number (PAN), expiration date, and cardholder name.
The three- or four-digit value printed by the signature panel or on the face of a payment card used to verify card-not-present 3
transactions.
Personal identification number entered by cardholder during a card-present transaction, and/or encrypted PIN block present 4
within the transaction message.