Board index » delphi » Re: Obligations for storing credit card numbers

Re: Obligations for storing credit card numbers


2006-05-25 06:36:44 AM
delphi230
On Wed, 24 May 2006 15:19:48 -0400, Wayne Niddery [TeamB] writes:
Quote
What good is storing only the last 4 digits? You can not do anything with it,
and the customer has to enter the whole thing anyway.
To display on the bill when the customer requests a copy 3 months
later.
--
Marc Rohloff [TeamB]
marc rohloff -at- myrealbox -dot- com
 
 

Re: Obligations for storing credit card numbers

On Wed, 24 May 2006 14:12:53 -0400, Jim Rowell writes:
Quote
Lance R. writes:
>I've looked into this a little bit. One of the issues I had was
>exporting CVV2 along with the other information from an app to a
>credit card processing/submittal software. The credit card software
>allowed for importing everything except CVV2. When I contacted the
>major bank processor who deals with the software, their comment was
>that the CVV2 number is NEVER to be stored at any time. It should be
>accepted at the time it is being processed, then forgotten.

Obviously good policy but I really can not see there being any serious
liability as long as good practices are followed should one decide to store
them. After all, credit card numbers are not secret. In fact they're only
half a step down from being published in the local library. Hundreds or even
thousands of people get to see most people's card numbers. it is just a
reference number.
I would say the same about my social security number, except that
people keep telling me to keep it a secret and not give it to anyone
except the SSA!
--
Marc Rohloff [TeamB]
marc rohloff -at- myrealbox -dot- com
 

Re: Obligations for storing credit card numbers

Jim Rowell writes:
Quote
Obviously good policy but I really can not see there being any serious
liability as long as good practices are followed should one decide to store
them. After all, credit card numbers are not secret. In fact they're only
half a step down from being published in the local library. Hundreds or even
thousands of people get to see most people's card numbers. it is just a
reference number. If after taking reasonable steps, a thief manages to get
numbers off a system, he's the one committing the crime. Same as someone
grabbing a box of receipts from a gas station. I would say don't store numbers
for your own reputation as a vendor but I would be surprised if any liability
held up in court (IANAL).
It is not that simple. The idea is that most vendors make it
sufficiently hard to steal credit card numbers, so that when one vendor
is seriously compromised (such as a database is stolen from a {*word*40}
site), it is possible for the credit card company to cross reference
customer complaints with transaction history, to track down the point of
compromise. That vendor might then be held liable.
Some year ago I encountered a hacker that had taken this one step
further. Apparently he had stolen credit card numbers from a {*word*40} site
and used them for purchasing lots of products on the Internet, including
ours. The interesting thing about the credit cards he used was however
that practically all of the credit card owners were members of different
political or otherwise vocal Christian organizations in the U.S. I guess
the hacker had found it amusing they had paid for {*word*40}. ;)
 

Re: Obligations for storing credit card numbers

"Craig Stuntz [TeamB]" wrote
Quote

ISTM he needs legal *and* technical advice. The need for legal advice
is a good point (if I were in his shoes I would probably be asking about
/personal/ liability, too...) but lawyers don't always give good advice
on computer security....
Actually this isn't a very good place to seek technical advice on security,
either ...<g>
Though normally I do tend to trust Henrick (StreamSec) on that topic.
bobD
 

Re: Obligations for storing credit card numbers

"Chris Burrows" <XXXX@XXXXX.COM>writes
Quote
"Stuartj" <stuartjatcmshospdotcomdotau>writes
news:XXXX@XXXXX.COM...
>Hi all,
>im currenlty havng discussion with collegues in regard to our oligation
>(legal and otherwise) to storing credit card numbers.

>Oh, we develop in AU, but our software is distributed internationally as
>well as locally. So any input is welcome as it will all be relevent.
>

Refer to the Payment Card Industry Data Security Standard (PCIDSS):


usa.visa.com/download/business/accepting_visa/ops_risk_management/cisp_PCI_Data_Security_Standard.pdf

--
Chris Burrows
CFB Software
www.cfbsoftware.com
This is great!
Thanks for the link. At least know i have something to throw on the table to
add strength to my argument.
 

Re: Obligations for storing credit card numbers

Thanks everyone for the discussion and your input.
To be honest, i cant believe that im having to form an argument on the
merits of encrypting this sort of sensative data.
Glad to see that im not the only one who sees it as a no-brainer.
Thans once again for the discussion.
Stuart
 

Re: Obligations for storing credit card numbers

Stuartj writes:
Quote

This is great!
Thanks for the link. At least know i have something to throw on the
table to add strength to my argument.
Will they read it? You know the old story about a horse and water...
--
Wayne Niddery - Logic Fundamentals, Inc. (www.logicfundamentals.com)
RADBooks: www.logicfundamentals.com/RADBooks.html
"If there is any principle of the Constitution that more imperatively
calls for attachment than any other, it is the principle of free
thought ?not free thought for those who agree with us, but freedom for
the thought that we hate." - Oliver Wendell Holmes
 

Re: Obligations for storing credit card numbers

"Wayne Niddery [TeamB]" <XXXX@XXXXX.COM>writes
Quote
Stuartj writes:
>
>This is great!
>Thanks for the link. At least know i have something to throw on the
>table to add strength to my argument.

Will they read it? You know the old story about a horse and water...

Touche (spelling)
Itll make me feel good anyway :)
 

Re: Obligations for storing credit card numbers

Quote
this is the kinda of method ive proposed but have been shouted down as it
increases the length of the original string representation, which would
require a change to the field length in the database...a ridiculous
argument
for my money. But this is why i was trying to work out what if any legal
requirements we must observe.
In today's world of corporate apathy, concerning personal
information, I doubt there's anything specific that you need
to do. But, that being said, every one of those stored numbers
represents a potential participant in a class action suit
against your company if your scheme is ever compromised..
IOW, you probably should "lawyer up" before you put this
little scheme in place..
 

Re: Obligations for storing credit card numbers

Wayne Niddery [TeamB] writes:
Quote
That's pretty much standard practice now - no reputable merchant
allows anything more than the last 4 digits to be displayed on any
public place - receipt or web page, etc.
Yes, and it should have always been, but here in Washington State they
are making it law because there are still a good number of full credit
card numbers being printed on receipts.
Quote
What good is storing only the last 4 digits? You can not do anything
with it, and the customer has to enter the whole thing anyway.
Depends on the app. It does exactly what our clients need. They can
tell the customer which card they used by giving them the last 4 digits
and removes any possiblity of having the credit card numbers fall into
the wrong hands. Our application is retail POS, not internet, so the
cards are almost always swiped so the customer does not really have to
enter anythihg. Example: Customer brings back an item for a refund
but does not have receipt. Clerk pulls up original sale and asks the
customer for his Visa card ending in 1234. That card is used to credit
the customer. This is all that our application requires. It may be
different for other types of applcations that require recurring billing
to a credit card.
 

Re: Obligations for storing credit card numbers

Jim Rowell writes:
Quote
Obviously good policy but I really can not see there being any serious
liability as long as good practices are followed should one decide to
store them. After all, credit card numbers are not secret.
Actually, this kind of data theft has been making headlines recently.
A transaction that contained the customer name, address, postal code,
phone number and credit card number/expiration date is often all that
is needed for a criminal to use your customers card. Credit card
numbers are not secret, as you say, but those numbers along with other
identifiying information makes it easy for thieves. Social Security
numbers are not secret either but I certainly would be careful who I
gave mine to.
 

Re: Obligations for storing credit card numbers

David Farrell-Garcia writes:
Quote
Jim Rowell writes:

>Obviously good policy but I really can not see there being any serious
>liability as long as good practices are followed should one decide to
>store them. After all, credit card numbers are not secret.

Actually, this kind of data theft has been making headlines recently.
A transaction that contained the customer name, address, postal code,
phone number and credit card number/expiration date is often all that
is needed for a criminal to use your customers card. Credit card
numbers are not secret, as you say, but those numbers along with other
identifiying information makes it easy for thieves. Social Security
numbers are not secret either but I certainly would be careful who I
gave mine to.
That's what makes it good policy but what I was referring to was the
liability. I'd imagine that as long as a database owner takes reasonable
precautions, I doubt there is any liability since a whole bunch of personal
info and a credit card number are not enough to legally complete a
transaction. Of course it *is* enough to *illegally* complete it but then
the liability rests with the thief and the credit card company that allowed
it rather than the company the records were stolen from. I am just giving a
layman's opinion here, of course. I am sure a judge would say the database
was only one of many possible sources, most of which would be far less
protected and absolve the DB owner of liability providing the system was
locked down reasonably well. Actually I would bet money it would never get as
far as a judge.
At the same time, I am not sure I would do business with a company that held on
to the numbers with no good reason. Credit cards have almost no inherent
security other than vigilance and effort on the part of the credit companies
and vendors. it is a very poor system that needs fixing soon!
--
Jim Rowell
 

Re: Obligations for storing credit card numbers

"Jim Rowell" <XXXX@XXXXX.COM>writes news:XXXX@XXXXX.COM...
Quote
precautions, I doubt there is any liability since a whole bunch of personal
info and a credit card number are not enough to legally complete a
transaction. Of course it *is* enough to *illegally* complete it but then
Just the credit card number and expiration date
are enough to legally complete a transaction.
But it is a good idea to verify other attributes, for your own protection.