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Obligations for storing credit card numbers
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Stuartj
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PostPosted: Wed May 24, 2006 1:14 am    Post subject: Obligations for storing credit card numbers Reply with quote



Hi all,
im currenlty havng discussion with collegues in regard to our oligation
(legal and otherwise) to storing credit card numbers.
Ive tried to do some searches to find out exactly how this kind of sensative
data should be stored in a database, but havent been able to find anything
that specifically outlines minimum requirements etc. We all agree that the
information must be encrypted to some degree, but cant agree on the level of
encryption.
We need to be able to decrypt the information, so one-way encryption is no
good.
If anyone has experience in this area and could advice me of any
particulars, it would be appreciated.
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.

regards
Stuart
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Stuartj
Guest





PostPosted: Wed May 24, 2006 2:14 am    Post subject: Re: Obligations for storing credit card numbers Reply with quote



"Marc Rohloff [TeamB]" <"on request"> wrote in message
news:byj37roczgii$.dlg (AT) dlg (DOT) marcrohloff.com...
Quote:
On Wed, 24 May 2006 11:05:59 +1000, Stuartj wrote:

im currenlty havng discussion with collegues in regard to our oligation
(legal and otherwise) to storing credit card numbers.
Ive tried to do some searches to find out exactly how this kind of
sensative
data should be stored in a database, but havent been able to find
anything
that specifically outlines minimum requirements etc. We all agree that
the
information must be encrypted to some degree, but cant agree on the
level of
encryption.
We need to be able to decrypt the information, so one-way encryption is
no
good.
If anyone has experience in this area and could advice me of any
particulars, it would be appreciated.
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.

It is usually preferable not to store them at all. It should be
sufficient just to store the reference number provided by the card
agent.

--
Marc Rohloff [TeamB]
marc rohloff -at- myrealbox -dot- com

Hi Marc,
agreed Smile
but unfortunately this isnt/wasnt my call......So im just trying to make
sure what we do store, is stored correctly.

Stuart
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Marc Rohloff [TeamB]
Guest





PostPosted: Wed May 24, 2006 2:14 am    Post subject: Re: Obligations for storing credit card numbers Reply with quote



On Wed, 24 May 2006 11:05:59 +1000, Stuartj wrote:

Quote:
im currenlty havng discussion with collegues in regard to our oligation
(legal and otherwise) to storing credit card numbers.
Ive tried to do some searches to find out exactly how this kind of sensative
data should be stored in a database, but havent been able to find anything
that specifically outlines minimum requirements etc. We all agree that the
information must be encrypted to some degree, but cant agree on the level of
encryption.
We need to be able to decrypt the information, so one-way encryption is no
good.
If anyone has experience in this area and could advice me of any
particulars, it would be appreciated.
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.

It is usually preferable not to store them at all. It should be
sufficient just to store the reference number provided by the card
agent.

--
Marc Rohloff [TeamB]
marc rohloff -at- myrealbox -dot- com
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Marc Rohloff [TeamB]
Guest





PostPosted: Wed May 24, 2006 2:14 am    Post subject: Re: Obligations for storing credit card numbers Reply with quote

On Wed, 24 May 2006 11:36:50 +1000, Stuartj wrote:

Quote:
"Marc Rohloff [TeamB]" <"on request"> wrote in message
but unfortunately this isnt/wasnt my call......So im just trying to make
sure what we do store, is stored correctly.

Since you require a reversible encryption I would assume something
like triple-DES or blowfish would be fine.
The biggest issue you need to solve is how you are going to safeguard
the key.

However no matter what you use, since you are only encoding 16
characters and they are a limited set (0-9), a brute force attach
would be relatively easy. I would suggest that you prefix your number
with some sort of salt (random data) to make it more difficult.

I am sure that Google would turn up quite a few solutions to this.

--
Marc Rohloff [TeamB]
marc rohloff -at- myrealbox -dot- com
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Stuartj
Guest





PostPosted: Wed May 24, 2006 3:14 am    Post subject: Re: Obligations for storing credit card numbers Reply with quote

Quote:
However no matter what you use, since you are only encoding 16
characters and they are a limited set (0-9), a brute force attach
would be relatively easy. I would suggest that you prefix your number
with some sort of salt (random data) to make it more difficult.

I am sure that Google would turn up quite a few solutions to this.

--
Marc Rohloff [TeamB]
marc rohloff -at- myrealbox -dot- com

Thanks Marc,
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.

thanks agian
stuart
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Medbob
Guest





PostPosted: Wed May 24, 2006 3:14 am    Post subject: Re: Obligations for storing credit card numbers Reply with quote

ToDo:
1. Find some way to get the DBAs off of the project.....
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Bob Dawson
Guest





PostPosted: Wed May 24, 2006 4:14 am    Post subject: Re: Obligations for storing credit card numbers Reply with quote

"Stuartj" wrote
Quote:
tried to do some searches to find out exactly how this kind of sensative
data should be stored in a database, but havent been able to find anything
that specifically outlines minimum requirements etc. We all agree that the

This is a pretty significant question of liability.The only advice you
should accept on non-tech is to see a good lawyer that knows this issue.

bobD
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Roger Lascelles
Guest





PostPosted: Wed May 24, 2006 4:14 am    Post subject: Re: Obligations for storing credit card numbers Reply with quote

"Marc Rohloff [TeamB]" <"on request"> wrote in message
news:bxqo7qq91746.dlg (AT) dlg (DOT) marcrohloff.com...
Quote:
On Wed, 24 May 2006 11:36:50 +1000, Stuartj wrote:

Since you require a reversible encryption I would assume something
like triple-DES or blowfish would be fine.
The biggest issue you need to solve is how you are going to safeguard
the key.

I think the poster means he needs to decrypt the information, not just store
a hash to prove a number is valid. That means he can use asymmetric
encryption like RSA, if he likes - that way the decoding key could even be
totally off the server.

This whole thing leaves me cold - get a single key and you can decode the
whole lot. You will want a CGI or ISAPI or server EXE, not something with
potential loopholes like PHP.

Roger Lascelles
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Chris Burrows
Guest





PostPosted: Wed May 24, 2006 5:14 am    Post subject: Re: Obligations for storing credit card numbers Reply with quote

"Stuartj" <stuartjatcmshospdotcomdotau> wrote in message
news:4473b154 (AT) newsgroups (DOT) borland.com...
Quote:
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):

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

--
Chris Burrows
CFB Software
http://www.cfbsoftware.com
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Henrick Hellström [Stream
Guest





PostPosted: Wed May 24, 2006 7:14 am    Post subject: Re: Obligations for storing credit card numbers Reply with quote

Chris Burrows wrote:
Quote:
Refer to the Payment Card Industry Data Security Standard (PCIDSS):

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

That is good advice (legal and otherwise), but I think the paragraph 3.4
misses the best option for storing credit card information, namely
asymmetric encryption, such as RSA-OAEP using a RSA public key you store
on the server. This means you can decrypt the information later, but
only from somewhere where you got access to the corresponding private
key, such as a back end management computer.
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TObject
Guest





PostPosted: Wed May 24, 2006 7:14 am    Post subject: Re: Obligations for storing credit card numbers Reply with quote

As far as obligations go you can look at it this way: if somebody steals
your customers' credit card numbers from you, as a merchant you will
be responsible for 100% of fraudulent charges, plus investigation costs.

So, basically, it is in merchants' best interests to make sure credit card
information doesn't get into wrong hands.
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K. Sallee
Guest





PostPosted: Wed May 24, 2006 9:14 am    Post subject: Re: Obligations for storing credit card numbers Reply with quote

Quote:
storing credit card numbers.

<quote>
"Today, the requirement is to make all information unreadable wherever it
is stored," Maxwell said. But this encryption requirement is causing so
much trouble for merchants that credit card companies are having trouble
dealing with requests for alternative measures, he said.

In response, changes to PCI will let companies replace encryption with
other types of security technology, such as additional firewalls and
access controls.

....

Retailers that don't comply may face penalties, including fines.

</quote>

http://news.com.com/Credit+card+security+rules+to+get+update/2100-1029_3-6072594.html?tag=nefd.top


But, unless you have a very good reason to store CC numbers such as
selling a subscription or other method that requires automatic renewal, I
ask, why bother with the cost of management and its risks:

https://secure.booklocker.com/secure.html

Kevin
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Jim Cooper
Guest





PostPosted: Wed May 24, 2006 9:14 am    Post subject: Re: Obligations for storing credit card numbers Reply with quote

Quote:
Oh, we develop in AU, but our software is distributed internationally as
well as locally.

You may ned to take into account local laws, or at least allow for whoever buys
your software to comply with local laws. In the UK there is the Data Protection
Act, for example, which applies to any companies storing personal information.

Cheers,
Jim Cooper

_____________________________________________

Jim Cooper jcooper (AT) tabdee (DOT) ltd.uk
Skype : jim.cooper
Tabdee Ltd http://www.tabdee.ltd.uk

TurboSync - Connecting Delphi to your Palm
_____________________________________________
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Henrick Hellström [Stream
Guest





PostPosted: Wed May 24, 2006 10:14 am    Post subject: Re: Obligations for storing credit card numbers Reply with quote

K. Sallee wrote:
Quote:
quote
"Today, the requirement is to make all information unreadable wherever
it is stored," Maxwell said. But this encryption requirement is causing
so much trouble for merchants that credit card companies are having
trouble dealing with requests for alternative measures, he said.

In response, changes to PCI will let companies replace encryption with
other types of security technology, such as additional firewalls and
access controls.
/quote

I guess the credit card companies have discovered that 99% of the
vendors who *do* apply encryption don't apply "proper key management".
For instance, how many of you store the encryption key in an ASP or
ASP.NET script on a website that has FrontPage Server Extensions
installed? If the hacker is able to steal the encryption key together
with the encrypted credit card numbers, the encryption obviously doesn't
add any security anyway.
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Craig Stuntz [TeamB]
Guest





PostPosted: Wed May 24, 2006 1:14 pm    Post subject: Re: Obligations for storing credit card numbers Reply with quote

TObject wrote:

Quote:
As far as obligations go you can look at it this way: if somebody
steals your customers' credit card numbers from you, as a merchant
you will be responsible for 100% of fraudulent charges, plus
investigation costs.

That's not how I read the fair credit billing act. Got a citation?

--
Craig Stuntz [TeamB] · Vertex Systems Corp. · Columbus, OH
Delphi/InterBase Weblog : http://blogs.teamb.com/craigstuntz
Everything You Need to Know About InterBase Character Sets:
http://blogs.teamb.com/craigstuntz/articles/403.aspx
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