# How Much Math Must You Take Before Taking Math 227 PCI DSS 101 – All The Background You Need For Understanding The PCI DSS – Part 2

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## PCI DSS 101 – All The Background You Need For Understanding The PCI DSS – Part 2

This is the second of a two-part article intended to provide a basic understanding of PCI DSS. See Part 1 for the following

• What is it and why is it important?

• The 12-point PCI DSS

• So who exactly is subject to PCI DSS?

It sounds like a lot of work and expense – what is the justification for the cost of PCI DSS?

Trying to understand the true cost of payment card fraud is not straightforward: by their very nature, fraudulent transactions are hidden.

Visa Europe reports a fraud level of around 6 cents for every 100 euros spent. It is important to realize that this is the cost of fraud to Visa Europe itself (as opposed to the total cost associated with card fraud which would include litigation costs between merchants, acquirers and issuers). Even so, in 2009, these cards were used to make purchases and cash withdrawals worth more than €1.3 trillion. Doing the math, that would put the cost of fraud at €780 million, just for Europe and just for Visa.

In order to extrapolate these figures, based on the income statement of Visa Inc. Q1 FY 2010 Visa’s global network processed payments totaling \$4.4 trillion. Assuming that Visa had a market share of 38.3% of the credit card market and 60.7% of the debit card market, the total value of payment card transactions for the world would be about 8 .5 trillion dollars.

If Visa’s theoretical formula of 6 cents on every dollar were applied, this would give an estimated value of fraud for the global payment card market of \$5.1 billion, although again, this is purely for same card companies.

Compare this figure with other sources which suggest that the overall cost of UK plastic card fraud was almost £610m in 2008, an increase of over 14% on 2007 (figures published by APACS, the industry of UK payments). Extrapolating this figure to the same 14% annual increase would give a 2010 figure of over £730 million (about \$1.2 billion) for the UK alone. The UK Cards Association claims card fraud figures have fallen by 20% in their most recent figures, based on January to June 2010, so these figures may be lower than estimated.

Global estimates of the cost of online fraud, including identity theft and all payment card abuse and organized crime, reached about \$78 billion last year (according to research house Global Uncertainties ). However, if you’re reading this as a card merchant, the numbers you’ll be most interested in are what the potential costs are to you. For Visa members, failure to report any suspected or confirmed loss of transaction data will subject the member to a penalty of \$100,000 per incident, rising to \$500,000 depending on the scale and severity of the breach As for repair costs, most estimates cost between \$90 and \$302 per record.

The cost of compliance can also increase if an engaged Tier 2, 3 or 4 merchant is subject to the PCI DSS requirements of the Tier 1 merchant, with the more stringent audit process.

The absolute penalty for a payment brand is to disqualify a merchant from being able to process card transactions.

It’s worth mentioning that in one of the few reported breaches, Heartland Payment Systems (corporate.visa.com/media-center/press-releases/press974.jsp) is agreeing to pay \$60 million in compensation to card issuers that have suffered losses as a result of the criminal breach of Heartland’s systems. The loss of customer trust and the corporate embarrassment of being exposed as an organization that has compromised its customers’ personal data could ultimately be much more expensive.

What happens if we are infringed?

Visa offers the following steps for “committed entities”

1. Contain and limit exposure immediately. Avoid further data loss by conducting a thorough investigation of suspected or confirmed information compromise.

2. Notify all necessary parties immediately. including

• Your internal information security group and incident response team.

• Visa Fraud Investigations and Incident Management Group

• Your local US Secret Service office

3. Provide all committed Visa, Interlink and Plus accounts to your merchant bank within 10 business days

4. Within 3 working days of reported transmission, provide incident report document to your commercial bank

Is PCI-DSS compliance required by law?

Minnesota’s plastic card security law does not make PCI a legal requirement, but it does require companies that store credit card information that are later breached to reimburse the card issuer for costs associated with the breach. In other words, it reinforces a key PCI requirement rather than legislating for it.

Similarly, Nevada has the Personal Information Security Act and Nevada Senate Bill 227 in which amendment SB 227 specifically establishes a requirement to comply with PCI-DSS.

Additionally, Washington House Bill 1149 (effective July 1, 2010) “recognizes that data breaches of credit and debit card information contribute to identity theft and fraud and can be costly to to consumers”.

Massachusetts is introducing 201 CMR 17.00 which apparently borrows heavily from PCI DSS.

Several other states are making attempts to enforce PCI DSS-aligned legislation, including Texas, California, Illinois, and Connecticut.

Beyond these specific examples of PCI DSS-aligned laws, the vast majority of states in the United States, Puerto Rico, and the Virgin Islands have legislation requiring disclosure of data breaches.

Summary

Understanding PCI DSS and how to implement it for your organization will take time, care and attention, but many of the necessary steps can be automated and simplified using modern software technology.

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