Cardholder Information Security Program (CISP) – Visa
USA Mandate
Since June 2001, the Visa U.S.A. Inc. has required that a
Member comply and ensure its merchants and agents comply with
the requirements of the Cardholder Information Security Program
(CISP). To broaden adoption and hasten implementation of cardholder
information security, Visa has redefined the processes for
validating CISP compliance of merchants and third party agents.
Level 1 Service Providers
The Level 1 Service Provider group includes all VisaNet Processors
(Member and Nonmember) and all payment gateways. Level 1 Service
Providers must validate CISP compliance with an annual onsite
review, resulting in a Report on Compliance. A Visa-approved,
independent security assessor according to the Security Audit
Procedures and Reporting document must conduct this review.
Additionally, a quarterly system perimeter scan must be performed
by a Visa-approved security assessor. Level 1 Service Providers
should have already begun CISP compliance validation and must
submit current compliance documentation to Visa, demonstrating
full compliance, by September 30, 2004. Required documentation
includes the annual Report on Compliance and quarterly
System Perimeter Scan Report. After a Level 1 Service
Provider has provided compliance documentation demonstrating
full compliance, they will be included on the list of CISP-Compliant
Service Providers.
Level 2 and Level 3 Service Providers
The Level 2 and Level 3 Service Provider group includes any
service provider (example, Third-Party Servicer (TPS), Independent
Sales Organizations (ISO), merchant vendor, Web hosting company
or shopping cart, media back-up company, Loyalty program vendor,
Risk management vendor, chargeback vendor, and credit bureau)
that is not in Level 1 and stores, processes, or transmits
Visa transactions. The number of transactions will be determined
based on the gross number of Visa transactions stored, processed,
or transmitted—not just for the merchant or Member supported
but for all entities supported by a service provider.
Level 2 Service Providers (more than one million
Visa transactions annually)
Level 2 Service Providers must validate CISP compliance in
the same manner as Level 1 Service Providers, demonstrating
full compliance, by September 30, 2004. After a Level 2 Service
Provider has provided compliance documentation demonstrating
full compliance, they will be included on the list of CISP-Compliant
Service Providers.
Level 3 Service Providers (less than one million
Visa transactions annually)
Level 3 Service Providers must submit compliance documentation
to Visa demonstrating full compliance, by September 30, 2004.
Required documentation includes the annual Compliance Questionnaire
and quarterly System Perimeter Scan Report. After
a Level 3 Service Provider has provided compliance documentation
demonstrating full compliance, they will be included on the
list of CISP-Compliant Service Providers.
CISP Compliance Validation Summary
The following is a summary of the compliance validation steps
required for third parties (including ISOs, loyalty, etc.)
that store cardholder data.
| CISP Merchant Compliance
Validation Level |
Annual Report on Compliance |
Quarterly System Perimeter
Scan Report |
Annual Compliance Questionnaire |
Compliance Validation
Due Date |
| Level 1 Service Provider
|
Required |
Required |
|
September 30, 2004 |
| Level 2 Service Provider
|
Required |
Required |
|
September 30, 2004 |
| Level 3 Service Provider
|
|
Required |
Required |
September 30, 2004 |
Level Selection Criteria
- All VisaNet Processors (Member and Nonmember)
- All payment gateways
- Any service provider that is not in Level 1 and stores,
processes, or transmits more than one million Visa accounts
annually.
- Any service provider that is not in Level 1 and stores,
processes, or transmits less than one million Visa accounts
annually.
CISP Compliance Validation Summary
The following is a summary of the compliance validation steps
required for merchants that store data.
| CISP Merchant Compliance
Validation Level |
Annual Report on Compliance |
Quarterly System Perimeter
Scan Report |
Annual Compliance Questionnaire |
Compliance Validation
Due Date |
| Level 1 Merchant |
Required |
Required |
|
September 30, 2004 |
| Level 2 Merchants |
|
Required |
Required |
March 31, 2005 |
| Level 3 Merchants |
|
Recommended |
Recommended |
To Be Announced by Member |
Merchant Level Selection Criteria
- More than 6 million Visa transactions processed annually
- 500 thousand to 6 million Visa transactions processed
annually
- Less than 500 thousand Visa transactions processed annually
Terms and Definitions
Annual Compliance Questionnaire: Required
for Level 3 Third Parties and Level 2 (and Level 3) merchant
to determine adherence to the Digital Dozen on the basis of
a self-assessment questionnaire. Merchants must also undergo
at least quarterly a System Perimeter Scan performed by a
Visa approved security assessor.
Annual Report on Compliance (ROC): Independent
security assessors review adherence to the Digital Dozen.
Visa approved assessors can be found at the CISP Web site
(www.visa.com/cisp). Required for Level 1, and 2 Third Parties
and Level 1 merchants. Visa will accept the Report on Compliance
from a merchant’s internal auditor, provided that a
letter signed by an executive-level officer of the merchant
accompanies the report.
System Perimeter Scan: Independent security
assessors perform a system perimeter scan is performed at
least quarterly. A system perimeter scan involves an automated
tool that checks third party or merchant’s systems for
vulnerabilities. This applies to all third parties and merchants
with external-facing Internet protocol (IP) addresses. Even
if a third party or merchant does not offer Web-based transactions,
there are other services such as e-mail and employee Internet
access that will result in the Internet-accessibility of a
company’s network. The tool will conduct a non-intrusive
scan to remotely review networks and Web applications based
on the external facing IP addresses provided by the merchant.
To view information on this topic from VISA,
click
here.
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