Cardholder Data Privacy Violation
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Description
Cardholder data privacy violations involve the compromising of data such as Primary Account Numbers (PAN), cardholder names, expiration dates, security codes, and any other data related to the use of credit cards and their respective owners. Such violations can occur through hacking, physical theft, or even internal misuse.
Card brands enforce standards to reduce the risk of data breaches. The most widely adopted standard is the Payment Card Industry Data Security Standard (PCI DSS). PCI DSS is a set of information security standards applicable to all companies that accept, process, store, and/or transmit private cardholder data.
Violations occur when organizations fail to effectively implement and maintain the safeguards specified in PCI DSS. This non-compliance can lead to severe consequences, including fines, increased fees, and suspension of credit card processing privileges by payment brands. Furthermore, breaches can result in significant financial losses, legal liabilities, and damage to an organization’s reputation.
Impact
Failing to protect cardholder data can result in:
- Financial Loss from Criminal Activity: Inadequate security makes businesses more vulnerable to breaches and fraud, leading to financial losses from stolen data, legal liabilities, and breach-related costs.
- Punitive Measures by Payment Brands: Payment brands can penalize businesses that don’t meet PCI standards with fines, increased fees, or suspension of credit card processing.
- Reputational Damage: Both punitive measures and financial losses can result in lasting reputational harm, affecting customer trust and revenue.
It is important to note that PCI DSS in itself is not a collection of laws but a contractual set of standards. The payment brands can, however, enforce penalties for non-compliance:
- Fines ranging from $5,000 to $100,000 per month, card replacement costs, and obligated forensic audits are all at the disposal of the payment card brand.
- Lawsuits as a possible outcome if information has been exposed in a data breach: in this example from well over a decade ago, the company TJX settled with banks to the tune of USD$40.9M as a result of 45.7 million customer records being compromised. In the aftermath, TJX reaffirmed its commitment to achieving the PCI DSS goals.
- Following a massive 2013 breach of retail giant Target, its profits dropped an estimated USD $440M, a hefty price to pay after already having to fork out millions in fines and legal settlements.
Scenarios
Although standards such as the PCI DSS framework are very comprehensive, there are, as always, creative exploits that have been engineered by malicious actors to take advantage of the gaps in the framework.
RAM Scraping attacks were first flagged publicly by Visa in 2008 after the card provider discovered that malicious actors had infiltrated point-of-sale (POS) machines and gained access to volatile random access memory (RAM) systems within the terminals that contained unencrypted cardholder data. The attack method itself was largely in response to a 2007 upgrade within the PCI DSS that prohibited the practice of storing private card data on POS machines for extended periods of time. By targeting the RAM, malicious actors circumvented this standard evolution.
Prevention of Cardholder Data Privacy Violation
To prevent sensitive cardholder data from being compromised, organizations must implement robust security measures. Here is a list of critical prevention strategies focusing on sensitive data disclosure:
- Data Classification: Implement a data classification system to identify and categorize sensitive cardholder data according to its importance and sensitivity, and establish clear internal policies on how different types of data should be handled, stored, and protected.
- Access Management: Employ stringent access management protocols to control who can view or manipulate sensitive cardholder data. Use strong identity verification methods, regularly updating access permissions, and ensuring that only necessary accounts have access to critical data.
- Data Encryption at Rest: Encrypt all sensitive cardholder data stored on servers or databases to ensure that it remains secure even if unauthorized access occurs.
- Data Encryption in Transit: Implement strong encryption protocols like TLS (Transport Layer Security) for all data being transmitted across networks to protect against interception by malicious actors.
- Sensitive Data Redaction: Redact sensitive information on any outputs, such as logs, reports, or user interfaces, to prevent accidental disclosure of cardholder data.
- Tokenization: Replace sensitive cardholder data with unique identification symbols or tokens that retain all the essential information about the data without compromising its security.
- Protections Against RAM Scraping: Encourage using programming patterns that minimize the time that sensitive data is unencrypted in RAM, reducing the risk of RAM scraping attacks. Use volatile memory more efficiently and clear memory immediately after use.
- Monitoring Tools: Deploy advanced monitoring tools that continuously scan for unusual and suspicious activities, allowing for immediate remediation actions.
Testing
Ensure that cardholder data is protected from unauthorized observation or disclosure.
- OWASP ASVS: 1, 2, 3, 4, 6, 8, 9
- OWASP Testing Guide: Testing for Sensitive Information Sent via Unencrypted Channels, Testing for Weak Encryption, Authentication Testing, Authorization Testing