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CREDIT CARD POLICY (Effective July 15, 2025)
We have implemented a suite of Advanced Fraud Detection filters on our website to protect us from fraudulent charges that create chargebacks to our bank account. These filters help protect our account from abuse by fraudsters who are testing credit cards, and helps us identify high-volume fraud attacks. These types of credit card purchases will be held back for personal review prior to being authorized. Our transaction filters prevent unauthorized card use by checking transactions for unusual patterns or security mismatches. Additional filters in place help prevent common e-commerce fraud scenarios by verifying and comparing billing addresses, shipping addresses, and IP address locations. Shipping AND Billing addresses MUST match or your card will be declined! The card CCV MUST be entered or your purchase will be declined! Our site identifies & collects email addresses, IP addresses & the age of your email address to aid in deciding credit card purchase authorizations. Email addresses that are less than 6-months old will be personally reviewed BEFORE your purchase will be fulfilled and shipped. Certain regional filters have also been implemented that lets us block specific customers’ IP addresses to prevent known sources of fraud. If your card is declined by any of our fraud filters and you feel these actions are unwarranted, please send us a message to info@whisperingpinestacticalgunsmithing.com and we will investigate and get back to you.
PURCHASING FIREARMS ONLINE - GENERAL REQUIREMENTS
It is illegal to ship firearms to anyone not holding an active Federal Firearms License (FFL). For that reason, firearms purchased online may be picked up at our store or shipped to an FFL (gun store) near you. We may contact and verify the FFL you select during checkout before we ship your firearm(s). The buyer is encouraged to contact the receiving FFL licensee before purchase.
RETURNS
Please read all return policies prior to purchasing your items. If you have questions regarding the item, please contact info@whisperingpinestacticalgunsmithing.com prior to placing the order. Once an order has been placed, you are agreeing to the terms and conditions of this return policy.
Firearms
While rare, there are times when a firearm may have a manufacturing defect that requires attention. If you identify a defect, please refer to the manufacturer for warranty repair.
Suppressors & NFA Items
While rare, there are times when a suppressor/NFA item may have a manufacturing defect that requires attention. If you identify a defect, please refer to the manufacturer for warranty repair.
Accessories
The following items are non-refundable:
USED FIREARMS
Used firearms may not be returned. All sales are final. Description and photos (if available) are provided by the seller.
GENERAL FIREARM SALES
All firearms, magazines, receivers and restricted law enforcement items are sold and shipped in accordance with all existing federal, state and local laws and regulations. Many of the firearms, magazines and parts for sale on this website may be restricted or prohibited in your area. Please check your local and state regulations before ordering. More specific regulatory information regarding certain States is listed below.
All new firearms are shipped in the original manufacturer's box, with magazine(s), accessories and applicable warranty. Firearms requiring warranty work must be returned to the factory within 1 year of purchase for repair. Accessories and special-order items not normally sold by our store will not be covered under warranty even if these products are part of an integrated firearms package, unless we have guaranteed the entire package in writing. Please contact the original manufacturer for warranty information on all accessories and special-order items.
Purchasing Firearms Online & In-Store – Specific Requirements
All handguns and long guns purchased online must be shipped to an authorized FFL dealer in your locality. Please see below for firearms purchase requirements in certain States within the United States.
NOTE: All items are shipped via UPS, FedEx, or USPS at our discretion. Items that require customization or that are not immediately available may delay shipment. Oversized and/or overweight items may require additional shipping charges, so you will be notified before the order is processed to verify additional payments for shipping & handling oversized packages.
1. Firearm Purchases
NOTE: This policy is subject to state and local firearms laws and regulations. Please know your local and state laws and regulations pertaining to the purchase and ownership of firearms before you make the purchase.
NOTE: Firearm Shipping Fees are variable and based on order total and may be subject to an additional $30 handling fee.
NOTE: We do not ship firearms/weapons to California, Hawaii or Alaska.
NOTE: We will only ship ammunition to the lower 48 continental United States.
Whispering Pines Tactical & Gunsmithing is committed to providing the best service possible during your firearm and ammunition purchase. We will follow the laws that govern firearm transfer and ammunition purchases in your locality.
2. Firearm Sale and Magazine Capacity Restriction Notice by State:
Residents of the following states are subject to the following restrictions. If an order is placed for a magazine or weapon that is restricted, the order will be canceled.
NOTE: Due to the volatility of firearm laws, the following is subject to change without notice. You are responsible for knowing the laws in your locality.
Colorado
As of July 1, 2013, magazines holding more than 15 rounds may not be sold or transferred within the state. In the City and County of Denver, devices defined as assault weapons are not allowable. Law enforcement exception: Agency orders or personal LE orders are supported by LE ID
Connecticut
Sales may be made to "Members or employees of the Department of Emergency Services and Public Protection, police departments, the Department of Correction or the military or naval forces of this state or of the United States for use in the discharge of their official duties or when off duty". You must be currently "Active Duty" to be eligible.
· No sales of "Assault Rifles."
· No sales of centerfire rifle magazines exceeding a 5-round capacity.
· No sales of pistol magazines exceeding a 10-round capacity.
All sales to individuals (including personal, individual LEO purchases) must go through an FFL and must comply with local laws. Whispering Pines Tactical & Gunsmithing may contact your local FFL for verification. Proof of the ability to transfer a firearm to you in your location may be required. Whispering Pines Tactical & Gunsmithing reserves the right to cancel any order that does not comply with local laws.
Hawaii
High-capacity magazines holding over 10 rounds cannot be shipped to Hawaii.
Illinois
· Aurora - Maximum 15 round magazine capacity
· Chicago - Maximum 12 round magazine capacity
· Franklin Park - Maximum 16 round magazine capacity
· Oak Park - Maximum 10 round magazine capacity
· Riverdale - Maximum 35 round magazine capacity
Maryland
All sales to individuals (including personal, individual LEO purchases) must go through an FFL and must comply with local laws. Whispering Pines Tactical & Gunsmithing may contact your FFL for verification. Proof of the ability to transfer a firearm to you in your location may be required. Whispering Pines Tactical & Gunsmithing reserves the right to cancel any order that does not comply with local laws.
High-capacity magazines holding over 10 rounds cannot be shipped to Maryland.
Massachusetts
All sales to individuals (including personal, individual LEO purchases) must go through an FFL and must comply with local laws. Whispering Pines Tactical & Gunsmithing may contact your FFL for verification. Proof of the ability to transfer a firearm to you in your location may be required. Whispering Pines Tactical & Gunsmithing reserves the right to cancel any order that does not comply with local laws.
High-capacity magazines holding over 10 rounds cannot be shipped to Massachusetts.
New Jersey
All sales to individuals (including personal, individual LEO purchases) must go through an FFL that is a registered dealer in your area and must comply with local laws.
Whispering Pines Tactical & Gunsmithing may contact your receiving FFL for verification. Proof of the ability to transfer a firearm to you in your location will be required. Whispering Pines Tactical & Gunsmithing reserves the right to cancel any order that does not comply with local laws.
High-capacity magazines holding over 15 rounds cannot be shipped to NJ.
New York
No sales of "Assault Rifles". High-capacity magazines holding over 10 rounds cannot be shipped to NY.
Pennsylvania
All sales to individuals (including personal, individual LEO purchases) must go through an FFL and must comply with local laws. Whispering Pines Tactical & Gunsmithing may contact your FFL for verification. Proof of the ability to transfer a firearm to you in your location may be required. Whispering Pines Tactical & Gunsmithing reserves the right to cancel any order that does not comply with local laws.
Washington D.C.
High-capacity magazines holding over 10 rounds cannot be shipped to the District of Columbia.
This is not an all-inclusive list, please know the laws of your area. Whispering Pines Tactical & Gunsmithing reserves the right to render any sale null and void if the laws do not allow shipment into your area. Whispering Pines Tactical & Gunsmithing does not accept any responsibility for the actions of the buyer.
3. Standard FFL Fees for Services
Please note: ALL FFL transfers require us to enter the weapon into our gun logs and follow ALL ATF procedures before completing the transfer. Please make sure your ID is valid and displays your current address. Active-duty military with out-of-state drivers’ licenses must have a copy of your PCS orders showing assignment corresponding to Whispering Pines Tactical & Gunsmithing at our Princeton, West Virginia address.
Please allow two (2) business days for processing. Whispering Pines Tactical & Gunsmithing will call when your firearm is ready for pick-up.
4. In-Store Purchase NICS Background Check Fees & Requirements:
· For firearms purchased from our store or website, transfers are FREE.
· For all firearms shipped directly to our store from other merchants: $25.00
· VALID WV CCW holders will not be subject to a NICS Background Check UNLESS there is evidence or suspicion by the FFL Dealer that a NICS Background Check may be warranted. This decision is at the discretion of the Whispering Pines Tactical & Gunsmithing Staff.
NFA Class 3 FFL Transfers (Gun Trust or SOT)
Whispering Pines Tactical & Gunsmithing is an NFA Class 3 Dealer and offers a full array of FFL transfer services including NFA Class 3 weapons.
Whispering Pines Tactical & Gunsmithing can assist you with the Purchase and Transfer of:
· SBR/SBS (Short Barreled Rifle/Shotgun)
· Full Auto Firearms
· Suppressors/Silencers
NOTE: There will be a $50 fee for each item requiring a Class 3 transfer if purchased elsewhere.
· All transferred firearms must have an operational lock that fits the firearm. We have them available for purchase if one is not included.
· All firearms must be shipped via Fed Ex, UPS, or USPS with a copy of the transferring FFL's current FFL. If it is a private transfer, a copy of the transferring person's drivers’ license must be included.
· All firearms that are sent to us must be picked up by the person whose name is on the invoice.
· Whispering Pines Tactical & Gunsmithing reserves the right to refuse any firearm transfer for any reason. The purchaser is responsible for return-shipping to the original FFL.
· All firearm transfer requests must be sent to: info@whisperingpinestacticalgunsmithing.com
These requests must include the following information:
· 1. Buyer's name and contact info.
· 2. FFL's name, contact info and FFL number. (a copy of the valid FFL is preferred), or Seller's drivers’ license
· 3. Make, model and serial number of the firearm(s).
The purchaser will be contacted when we have received the firearm. Please do not call to check the status. We will call you when it is available.
ADDITIONAL WARRANTY INFORMATION (Applies ONLY to firearms fulfilled by Davidson’s)
Davidson’s GuaranteeD® Lifetime Replacement Program Terms and Conditions
If anything, ever goes wrong with any gun you buy that is covered by the Davidson's GuaranteeD® Lifetime Replacement Program (the “GuaranteeD® Program”), it will be replaced. If no replacement is available, it will be repaired at no charge to you. Simple, just return it to the GuaranteeD® Program retailer where it was purchased by you, pay for the return shipping, and upon receipt Davidson's will ship the returning retailer a *BRAND NEW GUN. (See the GuaranteeD® Program details below.)
Under the GuaranteeD® Program, Davidson’s, Inc. (“Davidson’s”) agrees that if any firearm sold by Davidson’s ever becomes defective, Davidson’s will replace the firearm at no charge, subject to the conditions set forth below. The GuaranteeD® Program applies only if Davidson’s sold the firearm to the licensed firearms dealer from which you purchased it online or in-store, and the program extends only to the original purchaser from that dealer. The GuaranteeD® Program applies only to firearms that are not regulated by The National Firearms Act of 1934, its amendments and rulings. The GuaranteeD® Program does not cover any other type of merchandise, such as firearm accessories, optics, suppressors, less lethal products, air guns or cutlery.
If Davidson’s determines that your firearm satisfies the conditions for coverage under the GuaranteeD® Program, Davidson’s will, at no charge, replace the firearm with the same model. If no replacement is available, Davidson’s will repair the firearm if the firearm can be repaired, as determined by Davidson’s in its sole discretion. If no replacement is available and Davidson’s determines that the firearm cannot be repaired, Davidson’s will replace your nonperforming or defective firearm with a firearm that, in Davidson's sole determination, is substantially similar to your firearm. Coverage under the GuaranteeD® Program extends to any and all parts of the firearm as originally sold by us but does not extend to any firearm that is altered or rebuilt after original purchase, damaged through abuse, misuse or lack of proper care and maintenance, or used other than for its legal intended purposes. To obtain performance under the GuaranteeD® Program, you must return the nonperforming or defective firearm to the licensed firearms dealer from which you purchased it and pay the cost of shipping the product to Davidson's. TO AVOID VIOLATION OF STATE AND FEDERAL LAWS, DO NOT SHIP THE FIREARM DIRECTLY TO DAVIDSON’S. If the dealer is no longer in business, you may contact us directly by email at comments@galleryofguns.com or by phone at (800) 537-2565, to arrange for you to deliver the firearm to another licensed firearms dealer.
*BRAND NEW GUN:
If no replacement is available and your firearm can be repaired, we will send your firearm to the factory or an authorized station for repair. Some manufacturers require up to 120 days to process repairs.
SECURE TRANSMISSION
All information collected during the checkout process is transmitted via industry standard Transport Layer Security (TLS). A Transport Layer Security (TLS) Certificate (or SSL Certificate) creates an encrypted connection between a Web site and a visitor's Web browser. This link ensures that all data passed between the Web site and the browser remains private and secure.
ORDER FULFILLMENT
All orders are shipped promptly from a distributor warehouse or in-store inventory within 3 - 10 business days using UPS, FedEx, or USPS. Tracking numbers are available for items shipped via UPS and FedEx.
ONLINE PRICE & DESCRIPTION ERRORS
Online inventory changes every day. Occasionally an item may appear on the site by mistake or the item's description may contain a typographical error. We do not guarantee that titles, descriptions, pictures or prices on our site are error-free. We reserve the right to refuse any order including but not limited to orders for items with errors in the description or price. In the event that we cancel an order we will not charge the customer's credit card or we will refund the money.
AMMUNITION PURCHASES
You must be 18 or older to purchase rifle or shotgun ammunition and 21 or older to purchase handgun ammunition. All ammunition will be shipped ground with adult signature required. Always make sure to use the correct ammunition for your specific firearms. Check your local laws for any other regulations.
Information Security Policy
K-Tron Enterprizes Inc., dba Whispering Pines Tactical & Gunsmithing
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Effective 07/01/2025
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Contents
2. Information Security Policy
6. Information Security Procedures and Standards Policy
9. Access to the sensitive cardholder data
13. Security Awareness and Procedures
15. System and Password Policy
19. System Administration Access policy
20. Vulnerability Management Policy
24. Secure Application development
25. Penetration testing methodology
27. Roles and Responsibilities
28. Third party and security of card holder data
This Policy Document encompasses all aspects of security surrounding confidential company information and must be distributed to all company employees. All company employees must read this document in its entirety and sign the form confirming they have read and understand this policy fully. This document will be reviewed and updated by Management on an annual basis or when relevant to include newly developed security standards into the policy and distribute it all employees and contracts as applicable.
K-Tron Enterprizes Inc., dba Whispering Pines Tactical & Gunsmithing (herein after referred to as “Whispering Pines Tactical & Gunsmithing”) handles sensitive cardholder information daily. Sensitive Information must have adequate safeguards in place to protect them, to protect cardholder privacy, to ensure compliance with various regulations and to guard the future of the organisation.
Whispering Pines Tactical & Gunsmithing commits to respecting the privacy of all its customers and to protecting any data about customers from outside parties. To this end management are committed to maintaining a secure environment in which to process cardholder information so that we can meet these promises.
Employees managing Sensitive cardholder data should ensure:
l Manage Company and account data including cardholder information in a manner that fits with their sensitivity.
l Limit personal use of Whispering Pines Tactical & Gunsmithing information and telecommunication systems and ensure it does not interfere with your job performance.
l Whispering Pines Tactical & Gunsmithing reserves the right to monitor, access, review, audit, copy, store, or delete any electronic communications, equipment, systems, and network traffic for any purpose.
l Do not use e-mail, internet, and other Company resources to engage in any action that is offensive, threatening, discriminatory, defamatory, slanderous, pornographic, obscene, harassing, or illegal.
l Do not disclose personnel information unless authorised.
l Protect sensitive cardholder information.
l Do not use e-mail or other end messaging technologies such as messenger WhatsApp, Signal to share sensitive data including account data in the form of cardholder information.
l Keep passwords and accounts secure.
l Request approval from management prior to establishing any new software or hardware, third party connections, etc.
l Do not install unauthorised software or hardware, including modems and wireless access unless you have explicit management approval.
l Always leave desks clear of sensitive cardholder data and lock computer screens when unattended.
l Information security incidents must be reported, without delay, to the individual responsible for incident response locally – Please find out who this is.
We each have a responsibility for ensuring our company’s systems and data are protected from unauthorised access and improper use. If you are unclear about any of the policies detailed herein you should seek advice and guidance from your line manager.
The Management’s intentions for publishing an Acceptable Use Policy are not to impose restrictions that are contrary to Whispering Pines Tactical & Gunsmithing established culture of openness, trust, and integrity. Management is committed to protecting the employees, partners, and the Company from illegal or damaging actions by individuals, either knowingly or unknowingly. Whispering Pines Tactical & Gunsmithing will maintain an approved list of technologies and devices and personnel with access to such devices as detailed in Appendix B.
· Employees are responsible for exercising good judgment regarding the reasonableness of personal use.
· Employees should ensure that they have appropriate credentials and are authenticated for the use of technologies.
· Employees should take all necessary steps to prevent unauthorized access to confidential data which includes card holder data.
· Employees should ensure that technologies should be used and setup in acceptable network locations.
· Keep passwords secure and do not share accounts.
· Authorized users are responsible for the security of their passwords and accounts.
· All PCs, laptops and workstations should be secured with a password-protected screensaver with the automatic activation feature.
· All POS and PIN entry devices should be appropriately protected and secured so they cannot be tampered or altered.
· Because information contained on portable computers is especially vulnerable, exceptional care should be exercised.
· Postings by employees from a Company email address to newsgroups should contain a disclaimer stating that the opinions expressed are strictly their own and not necessarily those of Whispering Pines Tactical & Gunsmithing, unless posting is in the course of business duties.
· Employees must use extreme caution when opening e-mail attachments received from unknown senders, which may contain viruses, e-mail bombs, or Trojan horse code.
Violation of the standards, policies and procedures presented in this document by an employee will result in disciplinary action, from warnings or reprimands up to and including termination of employment. Claims of ignorance, good intentions or using poor judgment will not be used as excuses for non-compliance.
This policy aims to ensure that Whispering Pines Tactical & Gunsmithing conducts its business in full compliance with all national and international laws and regulations that pertain to its industry, as well as professional standards, accepted business practices, and internal standards.
· The data processed by Whispering Pines Tactical & Gunsmithing need to be identified along with the relevant laws, regulations, and industry standards.
· The scope including assets, network diagrams, dataflow diagrams and data storage repositories need to be documented in accordance with identified laws and regulations.
In relation to this Information security policy and relevant laws regulation and industry standards Whispering Pines Tactical & Gunsmithing need to maintain up to date documentation and ensure they are relevant and updated when changes are made as well as reviewed for accuracy on an annual basis.
The documents include procedures, standards, asset lists, network diagrams, cardholder flow diagrams.
· All sensitive cardholder data stored and managed by Whispering Pines Tactical & Gunsmithing, and its employees must be secure & always protected against unauthorised use. Any sensitive card data that is no longer required by Whispering Pines Tactical & Gunsmithing for business reasons must be discarded in a secure and irrecoverable manner.
· If there is no specific need to see the full PAN (Primary Account Number), it must be masked when displayed.
· PAN'S which are not protected as stated above should not be sent to the outside network via end user messaging technologies like email, WhatsApp, messenger, signal, and other chat programs.
It is strictly prohibited to store:
1. The contents of the payment card magnetic stripe (track data) on any media whatsoever.
2. The sensitive authentication data in form of CVV2/CVC2/CAV2/CID (the 3- or 4-digit number on the signature panel on the reverse of the payment card) on any media whatsoever.
3. The PIN or the encrypted PIN Block under any circumstance.
Data and media containing data must always be labelled to indicate sensitivity level.
· Confidential data might include information assets for which there are legal requirements for preventing disclosure or financial penalties for disclosure, or data that would cause severe damage to Whispering Pines Tactical & Gunsmithing if disclosed or modified. Confidential data includes account data and cardholder data.
· Internal Use data might include information that the data owner feels should be protected to prevent unauthorized disclosure.
· Public data is information that may be freely disseminated.
All Access to sensitive cardholder should be controlled and authorised. Any Job functions that require access to cardholder data should be clearly defined.
· Any display of the card holder should be restricted at a minimum of the first six and the last four digits of the cardholder data.
· Access rights to privileged user IDs should be restricted to least privileges necessary to perform job responsibilities.
· Privileges should be assigned to individuals based on job classification and function (Role based access control)
· Access to sensitive cardholder information such as PAN’s, personal information and business data is restricted to employees that have a legitimate need to view such information.
· No other employees should have access to this confidential data unless they have a genuine business need.
· If cardholder data is shared with a Third-Party Service Provider (TPSP) or a TPSP can affect the security of cardholder data, then a list of such TPSP’s will be maintained as detailed in Appendix B.
· Whispering Pines Tactical & Gunsmithing will ensure a written agreement that includes an acknowledgement is in place that the TPSP will be responsible for the for the cardholder data that the TPSP possess or can affect the security off.
· Whispering Pines Tactical & Gunsmithing will ensure that a there is an established process including proper due diligence is in place before engaging with a TPSP.
· Whispering Pines Tactical & Gunsmithing will have a process in place to monitor the PCI DSS compliance status of the TPSP.
Access to sensitive information in both hard and soft media format must be physically restricted to prevent unauthorised individuals from obtaining sensitive data.
· Employees are responsible for exercising good judgment regarding the reasonableness of personal use.
· Employees should ensure that they have appropriate credentials and are authenticated for the use of technologies.
· Employees should take all necessary steps to prevent unauthorized access to confidential data which includes card holder data.
· Employees should ensure that technologies should be used and setup in acceptable network locations.
· A list of devices that accept payment card data should be maintained.
· The list should include make, model, and location of the device.
· The list should have the serial number or a unique identifier of the device.
· The list should be updated when devices are added, removed, or relocated.
· POS devices (POI/Terminals) surfaces should be periodically inspected to detect tampering or substitution.
· Personnel using the devices should be trained and aware of managing the POS devices.
· Personnel using the devices should verify the identity of any third-party personnel claiming to repair or run maintenance tasks on the devices, install new devices, or replace devices.
· Personnel using the devices should be trained to report suspicious behaviour and indications of tampering of the devices to the appropriate personnel.
· A “visitor” is defined as a vendor, guest of an employee, service personnel, or anyone who needs to enter the premises for a short duration, usually not more than one day.
· Keep passwords secure and do not share accounts. Authorized users are responsible for the security of their passwords and accounts.
· Media is defined as any printed or handwritten paper, received faxes, floppy disks, back-up tapes, computer hard drive, etc.
· Media containing sensitive cardholder information must be managed and distributed in a secure manner by trusted individuals.
· Visitors must always be escorted by a trusted employee when in areas that hold sensitive cardholder information.
· Procedures must be in place to help all personnel easily distinguish between employees and visitors, especially in areas where cardholder data is accessible. “Employee” refers to full-time and part-time employees, temporary employees and personnel, and consultants who are “resident” on Whispering Pines Tactical & Gunsmithing sites. A “visitor” is defined as a vendor, guest of an employee, service personnel, or anyone who needs to enter the premises for a short duration, usually not more than one day.
· Network Jacks located in public and areas accessible to visitors must be disabled and enabled when network access is explicitly authorised.
· All POS and PIN entry devices should be appropriately protected and secured so they cannot be tampered or altered.
· Strict control is maintained over the external or internal distribution of any media containing card holder data and must be approved by management.
· Strict control is maintained over the storage and accessibility of media.
· All computers that store sensitive cardholder data must have a password protected screensaver enabled to prevent unauthorised use.
All sensitive cardholder data must be protected securely if it is to be transported physically or electronically.
· Card holder data (PAN, track data etc) must never be sent over the internet via email, instant chat, or any other end user technologies.
· If there is a business justification to send cardholder data via email or via the internet or any other modes then it should be done after authorization and by using a strong encryption mechanism (i.e. – AES encryption, PGP encryption, IPSEC, GSM, GPRS, Wireless technologies etc.,).
· The transportation of media containing sensitive cardholder data to another location must be authorised by management, logged and inventoried before leaving the premises. Only secure courier services may be used for the transportation of such media. The status of the shipment should be monitored until it has been delivered to its new location.
The policies and procedures outlined below must be incorporated into company practice to maintain an elevated level of security awareness. The protection of sensitive data demands regular training of all employees and contractors.
· Review handling procedures for sensitive information and hold periodic security awareness meetings to incorporate these procedures into day-to-day company practice.
· Distribute this security policy document to all company employees to read. It is required that all employees confirm that they understand the content of this security policy document by signing an acknowledgement form (see Appendix A)
· All employees that manage sensitive information will undergo background checks (such as criminal and credit record checks, within the limits of the local law) before they commence their employment with the Company.
· All third parties with access to credit card account numbers are contractually obligated to comply with card association security standards (PCI/DSS).
· Company security policies must be reviewed annually and updated as needed.
· Security awareness training needs to include awareness on phishing.
· The security awareness training needs to be updated at least annually.
· Firewalls must be implemented at each internet connection and any perimeter network and the internal company network.
· A network diagram detailing all the inbound and outbound connections must be maintained and reviewed every 6 months.
· A firewall and router configuration document must be maintained which includes a documented list of services, protocols and ports including a business justification.
· Firewall and router configurations must restrict connections between untrusted networks and any systems in the card holder data environment.
· Stateful Firewall technology must be implemented where the Internet enters Whispering Pines Tactical & Gunsmithing Card network to mitigate known and on-going threats. Firewalls must also be implemented to protect local network segments and the IT resources that attach to those segments such as the business network, and open network.
· All inbound and outbound traffic must be restricted to that which is required for the card holder data environment.
· All inbound network traffic is blocked by default, unless explicitly allowed and the restrictions must be documented.
· All outbound traffic must be authorized by management (i.e. what are the whitelisted category of sites that can be visited by the employees), and the restrictions must be documented.
· Whispering Pines Tactical & Gunsmithing will have firewalls between any wireless networks and the cardholder data environment.
· Whispering Pines Tactical & Gunsmithing will quarantine wireless users into a DMZ, where they will be authenticated and firewalled as if they were coming in from the Internet.
· Disclosure of private IP addresses to external entities must be authorized.
· A topology of the firewall environment must be documented and must be updated in accordance with the changes in the network.
· The firewall rules will be reviewed on a six-month basis to ensure validity, and the firewall must have clean up rule at the bottom of the rule base.
· Whispering Pines Tactical & Gunsmithing must quarantine wireless users into a DMZ, where they were authenticated and firewalled as if they were coming in from the Internet.
· No direct connections from Internet to cardholder data environment will be permitted. All traffic must traverse through a firewall.
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All users, including contractors and vendors with access to Whispering Pines Tactical & Gunsmithing systems, are responsible for taking the appropriate steps, as outlined below, to select and secure their passwords.
· A system configuration standard must be developed along industry acceptable hardening standards (SANS, NIST, ISO)
· System configurations should be updated as contemporary issues are identified (as defined in PCI DSS requirement 6.3)
· System configurations must include common security parameter settings.
· The systems configuration standard should be applied to any news systems configured.
· All vendor default accounts and passwords for the systems must be changed at the time of provisioning the system/device into Whispering Pines Tactical & Gunsmithing network and all unnecessary services and user/system accounts must be disabled.
· All unnecessary default accounts must be removed or disabled before installing a system on the network.
· Security parameter settings must me set appropriately on System components.
· All unnecessary functionality (scripts, drivers, features, subsystems, file systems, web servers etc.,) must be removed.
· All unnecessary services, protocols, daemons etc., should be disabled if not in use by the system.
· Any insecure protocols, daemons, services in use must be documented and justified.
· All users with access to card holder data must have a unique ID.
· All users must use a password to access the company network or any other electronic resources.
· All user ID’s for terminated users must be deactivated or removed immediately.
· The User ID will be locked out if there are more than five unsuccessful attempts. This locked account can only be enabled by the system administrator. Locked out user accounts will be disabled for a minimum period of 30 minutes or until the administrator enables the account.
· All system and user level passwords must be changed on at least a quarterly basis.
· A minimum password history of four must be implemented.
· A unique password must be setup for inexperienced users and the users prompted to change the password on first login.
· Group shared or generic user account or password or other authentication methods must not be used to administer any system components.
· Where SNMP is used, the community strings must be defined as something other than the
Standard defaults of "public," "private" and "system" and must be different from the passwords used to log in interactively.
· All non-console administrative access will use appropriate technologies like SSH, VPN etc., or strong encryption is invoked before the administrator password is requested.
· System services and parameters will be configured to prevent the use of insecure technologies like telnet and other insecure remote login commands.
· Administrator access to web-based management interfaces is encrypted using strong cryptography.
· The responsibility of selecting a password that is hard to guess generally falls to users. A strong password must:
a) Be as long as possible (never shorter than twelve characters).
b) Include mixed-case letters, if possible.
c) Include digits and punctuation marks, if possible.
d) Not be based on any personal information.
e) Not be based on any dictionary word, in any language.
· If an operating system without security features is used (such as DOS, Windows, or MacOS), then an intruder only needs temporary physical access to the console to insert a keyboard monitor program. If the workstation is not physically secured, then an intruder can reboot even a secure operating system, restart the workstation from his own media, and insert the offending program.
· To protect against network analysis attacks, both the workstation and server should be cryptographically secured. Examples of strong protocols are the encrypted Netware login and Kerberos.
· All machines must be configured to run the latest anti-virus software as approved by Whispering Pines Tactical & Gunsmithing. The preferred application to use is Anti-Virus software, which must be configured to retrieve the latest updates to the antiviral program automatically on a daily basis. The antivirus should have periodic scanning enabled for all the systems.
· The antivirus software in use should be cable of detecting all known types of malicious software (Viruses, Trojans, adware, spyware, worms, and rootkits)
· All removable media (for example floppy and others) should be scanned for viruses before being used.
· All the logs generated from the antivirus solutions must be retained as per legal/regulatory/contractual requirements or at a minimum of PCI DSS requirement 10.7 of 3 months online and 1 year offline.
· Master Installations of the Antivirus software should be setup for automatic updates and periodic scans
· End users must not be able to modify and any settings or alter the antivirus software
· E-mail with attachments coming from suspicious or unknown sources should not be opened. All such e-mails and their attachments should be deleted from the mail system as well as from the trash bin. No one should forward any e-mail, which they suspect may contain virus.
· E-mails need to be checked for phishing attempts.
· All Workstations, servers, software, system components etc. owned by Whispering Pines Tactical & Gunsmithing must have up-to-date system security patches installed to protect the asset from known vulnerabilities.
· Wherever possible all systems, software must have automatic updates enabled for system patches released from their respective vendors. Security patches must be installed within one month of release from the respective vendors and must follow the process in accordance with the change control process.
· Any exceptions to this process must be documented.
· It is the responsibility of Whispering Pines Tactical & Gunsmithing employees, contractors, vendors, and agents with
remote access privileges to Whispering Pines Tactical & Gunsmithing’s corporate network to ensure that their remote
access connection is given the same consideration as the user's on-site connection to Whispering Pines Tactical & Gunsmithing.
· Secure remote access must be strictly controlled. Control will be enforced by multi-factor authentication via one-time password authentication or public/private keys with strong passphrases.
· Vendor accounts with access to Whispering Pines Tactical & Gunsmithing network will only be enabled during the time period the access is required and will be disabled or removed once access is no longer required.
· Remote access connection will be setup to be disconnected automatically after 30 minutes of inactivity.
· All hosts that are connected to Whispering Pines Tactical & Gunsmithing internal networks via remote access technologies will be monitored on a regular basis.
· All remote access accounts used by vendors or third parties will be reconciled at regular interviews and the accounts will be revoked if there is no further business justification.
· Vendor accounts with access to Whispering Pines Tactical & Gunsmithing network will only be enabled during the time period the access is required and will be disabled or removed once access is no longer required.
· It is the responsibility of Whispering Pines Tactical & Gunsmithing administrators with
administrative access privileges to Whispering Pines Tactical & Gunsmithing’s code network to ensure that their administrative access connection is given the same consideration as the administrative console connection.
· Secure administrative access must be strictly controlled. Control will be enforced by multi-factor authentication via one-time password authentication or public/private keys with strong passphrases.
· All the vulnerabilities would be assigned a risk ranking such as High, Medium, and Low based on industry best practices such as CVSS base score.
· As part of the PCI-DSS Compliance requirements, Whispering Pines Tactical & Gunsmithing will run internal and external network vulnerability scans at least quarterly and after any meaningful change in the network (such as new system component installations, changes in network topology, firewall rule modifications, product upgrades).
· Quarterly internal vulnerability scans must be performed by Whispering Pines Tactical & Gunsmithing by internal staff or a 3rd party vendor and the scan process has to include that rescans will be done until passing results are obtained, or all High vulnerabilities as defined in PCI DSS Requirement 6.3.3 are resolved.
· Quarterly external vulnerability scans must be performed by an Approved Scanning Vendor (ASV) qualified by PCI SSC. Scans conducted after network changes may be performed by the Company’s internal staff. The scan process should include re-scans until passing results are obtained.
· Information systems that process transmit, or store card holder data must be configured in accordance with the applicable standard for that class of device or system. Standards must be written and maintained by the team responsible for the management of the system in conjunction with the Information Security Office.
· All network device configurations must adhere to Whispering Pines Tactical & Gunsmithing required standards before being placed on the network as specified in Whispering Pines Tactical & Gunsmithing configuration guide. Using this guide, a boilerplate configuration has been created that will be applied to all network devices before being placed on the network.
· Before being deployed into production, a system must be certified to meet the applicable configuration standard.
· Updates to network device operating system and/or configuration settings that fall under the Company standards are announced by the Information security Office. Updates must be applied within the time frame identified by the Information security Office.
· Administrators of network devices that do not adhere to Whispering Pines Tactical & Gunsmithing standards (as identified via a previous exception) must document and follow a review process of announced vendor updates to operating system and/or configuration settings. This process must include a review schedule, risk analysis method and update method.
· All network device configurations must be checked annually against the configuration boilerplate to ensure the configuration continues to meet required standards.
· Where possible, network configuration management software will be used to automate the process of confirming adherence to the boilerplate configuration.
· For other devices, an audit will be performed quarterly to compare the boilerplate configuration to the configuration currently in place.
· All discrepancies will be evaluated and remediated by Network Administration.
· Changes to information resources shall be managed and executed according to a formal change control process. The control process will ensure that changes proposed are reviewed, authorised, evaluated, implemented, and released in a controlled manner; and that the status of each proposed change is monitored.
· The change control process shall be formally defined and documented. A change control process shall be in place to control changes to all critical company information resources (such as hardware, software, system documentation and operating procedures). This documented process shall include management responsibilities and procedures. Wherever practicable, operational and application change control procedures should be integrated.
· All change requests shall be logged whether approved or rejected on a standardised and central system. The approval of all change requests and the results thereof shall be documented. A documented audit trail, maintained at a Business Unit Level, containing relevant information shall be always maintained. This should include change request documentation, change authorisation and the outcome of the change. No single person should be able to effect changes to production information systems without the approval of other authorised personnel.
· A risk assessment shall be performed for all changes and dependant on the outcome; an impact assessment should be performed.
· The impact assessment shall include the potential effect on other information resources and potential cost implications. The impact assessment should, where applicable consider compliance with legislative requirements and standards.
· All change requests shall be prioritised in terms of benefits, urgency, effort required and potential impact on operations.
· Changes shall be evaluated in an isolated, controlled, and representative environment (where such an environment is feasible) prior to implementation to minimise the effect on the relevant business process, to assess its impact on operations and security and to verify that only intended and approved changes were made. (For more information see System Development Life Cycle [citation here]).
· Any software change and/or update shall be controlled with version control. Older versions shall be retained in accordance with corporate retention and storage management policies. (For more information see System Development Life Cycle [citation here])
· All changes shall be approved prior to implementation. Approval of changes shall be based on formal acceptance criteria i.e. the change request was done by an authorised user, the impact assessment was performed and proposed changes were evaluated.
· All users, significantly affected by a change, shall be notified of the change. The user representative shall sign-off on the change. Users shall be required to make submissions and comment prior to the acceptance of the change.
· Implementation will only be undertaken after appropriate testing and approval by stakeholders. All major changes shall be treated as new system implementation and shall be established as a project. Major changes will be classified according to effort required to develop and implement said changes. (For more information see System Development Life Cycle [citation here])
· Procedures for aborting and recovering from unsuccessful changes shall be documented. Should the outcome of a change be different to the expected result (as identified in the testing of the change), procedures and responsibilities shall be noted for the recovery and continuity of the affected areas. Fall back procedures will be in place to ensure systems can revert back to what they were prior to implementation of changes.
· Information resources documentation shall be updated on the completion of each change and old documentation shall be archived or disposed of as per the documentation and data retention policies.
· Specific procedures to ensure the proper control, authorisation, and documentation of emergency changes shall be in place. Specific parameters will be defined as a standard for classifying changes as Emergency changes.
· All changes will be monitored once they have been rolled out to the production environment. Deviations from design specifications and test results will be documented and escalated to the solution owner for ratification.
· This procedure covers all logs generated for systems within the cardholder data environment, based on the flow of cardholder data over Whispering Pines Tactical & Gunsmithing network, including the following components:
• Operating System Logs (Event Logs and SU logs).
• Database Audit Logs.
• Firewalls & Network Switch Logs.
• IDS Logs.
• Antivirus Logs.
• CCTV Video recordings.
• File integrity monitoring system logs.
· Audit Logs must be maintained for a minimum of 3 months online (available for immediate analysis) and 12 months offline.
· Review of logs is to be conducted by means of Whispering Pines Tactical & Gunsmithing’s network monitoring system (the Company to define hostname), which is controlled from Whispering Pines Tactical & Gunsmithing console (the Company to define hostname). The console is installed on the server (the Company to define hostname / IP address), located within Whispering Pines Tactical & Gunsmithing data centre environment.
· The following personnel are the only people permitted to access log files (the Company to define which individuals have a job-related need to view audit trails and access log files).
· The network monitoring system software (the Company to define) is configured to alert Whispering Pines Tactical & Gunsmithing [RESPONSIBLE TEAM] to any conditions deemed to be potentially suspicious, for further investigation. Alerts are configured to:
· A dashboard browser-based interface, monitored by Whispering Pines Tactical & Gunsmithing [RESPONSIBLE TEAM].
· Email / SMS alerts to Whispering Pines Tactical & Gunsmithing [RESPONSIBLE TEAM] mailbox with a summary of the incident. Whispering Pines Tactical & Gunsmithing [ROLE NAME] also receives details of email alerts for informational purposes.
· The following Operating System Events are configured for logging, and are monitored by the console (Whispering Pines Tactical & Gunsmithing to define hostname):
a) Any additions, modifications, or deletions of user accounts.
b) Any failed or unauthorised attempt at user logon.
c) Any modification to system files.
d) Any access to the server, or application running on the server, including files that hold cardholder data.
e) Actions taken by any individual with root or administrative privileges.
f) Any user access to audit trails.
g) Any creation / deletion of system-level objects installed by Windows. (Almost all system-level objects run with administrator privileges, and some can be abused to gain administrator access to a system.)
· The following Database System Events are configured for logging, and are monitored by the network monitoring system (Whispering Pines Tactical & Gunsmithing to define software and hostname):
a) Any failed user access attempts to log in to the Oracle database.
b) Any login that has been added or removed as a database user to a database.
c) Any login that has been added or removed from a role.
d) Any database role that has been added or removed from a database.
e) Any password that has been changed for an application role.
f) Any database that has been created, altered, or dropped.
g) Any database object, such as a schema, which has been connected to.
h) Actions taken by any individual with DBA privileges.
· The following Firewall Events are configured for logging, and are monitored by the network monitoring system (the Company to define software and hostname):
a) ACL violations.
b) Invalid user authentication attempts.
c) Logon and actions taken by any individual using privileged accounts.
d) Configuration changes made to the firewall (e.g. policies disabled, added, deleted, or modified).
· The following Switch Events are to be configured for logging and monitored by the network monitoring system (the Company to define software and hostname):
a) Invalid user authentication attempts.
b) Logon and actions taken by any individual using privileged accounts.
c) Configuration changes made to the switch (e.g. configuration disabled, added, deleted, or modified).
· The following Intrusion Detection Events are to be configured for logging, and are monitored by the network monitoring system (the Company to define software and hostname):
a) Any vulnerability listed in the Common Vulnerability Entry (CVE) database.
b) Any generic attack(s) not listed in CVE.
c) Any known denial of service attack(s).
d) Any traffic patterns that indicated pre-attack reconnaissance occurred.
e) Any attempts to exploit security-related configuration errors.
f) Any authentication failure(s) that might indicate an attack.
g) Any traffic to or from a back-door program.
h) Any traffic typical of known stealth attacks.
· The following File Integrity Events are to be configured for logging and monitored by (the Company to define software and hostname):
a) Any modification to system files.
b) Actions taken by any individual with administrative privileges.
c) Any user access to audit trails.
d) Any Creation / Deletion of system-level objects installed by Windows. (Almost all system-level objects run with administrator privileges, and some can be abused to gain administrator access to a system.)
· For any suspicious event confirmed, the following must be recorded on F17 - Log Review Form, and Whispering Pines Tactical & Gunsmithing [ROLE NAME] informed:
a) User Identification.
b) Event Type.
c) Date & Time.
d) Success or Failure indication.
e) Event Origination (e.g. IP address).
f) Reference to the data, system component or resource affected.
· The Secure Application development policy is a plan of action to guide developers’ decisions and actions during the software development lifecycle (SDLC) to ensure software security. This policy aims to be language and platform independent so that it is applicable across all software development projects.
· The adherence to and use of Secure Application Development Coding Policy is a requirement for all software development on Whispering Pines Tactical & Gunsmithing information technology systems and trusted contractor sites processing the Company data.
· Each phase of the SDLC is mapped with security activities, as explained below:
a) Design
§ Identify Design Requirements from security perspective.
§ Architecture & Design Reviews
§ Threat Modelling
b) Coding
§ Coding Best Practices
§ Perform Static Analysis
c) Testing
§ Vulnerability Assessment
§ Fuzzing
d) Deployment
§ Server Configuration Review
§ Network Configuration Review
· Development of code shall be checked and validated with the most current versions of Whispering Pines Tactical & Gunsmithing Coding Standards for Secure Application Development. All code developers shall verify that their code is in compliance with the most recent and approved coding standards and guidelines.
· Only validated code shall be implemented into Whispering Pines Tactical & Gunsmithing production environment. A review and validation ensure that code exhibits fundamental security properties to include correctness, predictability, and attack tolerance.
Application Code Developers shall:
· Ensure code meets the level of confidence that software is free from exploitable code vulnerabilities, regardless of whether they are already designed into the software or inserted later in its life cycle.
· Ensure code provides predictable execution or justifiable confidence and that the software, when executed, will provide security functionality as intended.
· Coding techniques must address injection flaws particularly SQL injection, buffer overflow vulnerabilities, cross site scripting vulnerabilities, improper access control (insecure direct object reference, failure to restrict URL access, directory traversal etc.,), cross site request forgery (CSRF), broken authentication and session management.
· Never trust incoming data to the system, apply checks to this data.
· Never rely on the client to store sensitive data no matter how trivial.
· Disable Error messages that return any information to the user.
· Use object inheritance, encapsulation, and polymorphism wherever possible.
· Use environment variables prudently and always check boundaries and buffers.
· Applications must validate input to ensure it is well-formed and meaningful.
· In this section should be listed the risks inherent in conducting penetration testing over the information systems of Whispering Pines Tactical & Gunsmithing. Additionally, it should be noted for each mitigation measures that will be taken. Examples might be:
Example 1#
Risk: Denial of Service in systems or network devices because of the network scans.
Mitigation measure 1: network scans must be performed in a controlled manner. The start and end of the scan must be notified to responsible personnel to allow monitoring during testing. For any sign of trouble will abort the scan in progress.
Mitigation measure 2: scanning tools must be configured to guarantee that the volume of sent packets or sessions established per minute does not cause a problem for network elements. In this sense, we must perform the first scans in a very controlled way and a use minimum configuration that may be expanded when is evident that the configuration is not dangerous for network devices or servers in the organization.
· Key staff involved in the project by the organization will be listed:
Technical Project Manager:
Chief Information Security Officer:
Chief Information Officer:
Head of Communications:
Responsible for web site https://www.whisperingpinestacticalgunsmithing.com:
· External intrusion tests will be performed remotely from the supplier's premises. Internal intrusion tests will be conducted in the office Whispering Pines Tactical & Gunsmithing of the Organization. Audit team must have access to the Organization's network. It must manage access permissions to the building early enough to ensure that the audit team can access without problems during planning period.
· If segmentation is used to limit the scope of PCI DSS the segmentation techniques need to be evaluated using a segmentation test.
· All the tests will be conducted from the equipment owned by the audit team so no equipment for the execution of the tests is required. The only requirement in this regard will be to have an active network connection for each member of the audit team. Those connections must provide access to the target network segment in every case.
· If an incident occurs during the execution of the tests that have an impact on the systems or services of the organization, the incident should be brought immediately to the attention of those responsible for incident management in the project.
· It should be noted that in order to comply with PCI DSS the scope of the test should include, at least the following:
§ All systems and applications that are part of the perimeter of the cardholder data environment card (CDE).
§ Critical systems within the CDE.
Example:
a) Systems included in the scope.
System 1: IP: System: System Description
System 2: IP: System: System Description
Wi-Fi network Whispering Pines Tactical & Gunsmithing
................
b) Applications included in the scope.
Application 1: URL: Description of the application
...................
c) Systems excluded from the scope.
System 5: IP: System: System Description
System 6: IP: System: System Description
....................
d) Applications excluded from the scope.
Application 3: URL: Description of the application
.....................
§ Technical tests must follow the OSSTMM methodology. Tests must be conducted at network, system and application level and must ensure that at least identifies any vulnerabilities documented by OWASP and SANS, as well as those identified in the PCI DSS standard v4:
1. Injections : Code, SQL, OS Command, LDAP, XPath, etc.
2. Buffer overflows.
3. Insecure storage of cryptographic keys
4. Insecure Communications
5. Improper error handling
6. Cross -site scripting (XSS)
7. Control of inappropriate access.
8. Cross - site request forgery (CSRF).
9. Broken authentication and incorrectly session management.
10. Any other vulnerability considered High Risk by the organization.
· For all findings or vulnerabilities identified during the tests conducted will be generated and documented sufficient evidence to prove the existence of the same. The format of the evidence can be variable in each case, screen capture, raw output of security tools, photographs, paper documents, etc.
· As a result of tests performed should generate a document containing at least the following sections:
Introduction
Executive Summary
Methodology
Identified vulnerabilities
Recommendations for correcting vulnerabilities
Conclusions
Evidence
'Security incident' means any incident (accidental, intentional, or deliberate) relating to your communications or information processing systems. The attacker could be a malicious stranger, a competitor, or a disgruntled employee, and their intention might be to steal information or money, or just to damage your company.
The Incident response plan must be evaluated once annually. Copies of this incident response plan is to be made available to all relevant staff members and take steps to ensure that they understand it and what is expected of them.
Employees of the company will be expected to report to the security officer for any security related issues.
Whispering Pines Tactical & Gunsmithing PCI security incident response plan is as follows:
4. The PCI Response Team will resolve the problem to the satisfaction of all parties involved, including reporting the incident and findings to the appropriate parties (credit card associations, credit card processors, etc.) as necessary.
5. The PCI Response Team will determine if policies and processes need to be updated to avoid a similar incident in the future, and whether additional safeguards are required in the environment where the incident occurred, or for the institution.
6. If an unauthorised wireless access point or devices is identified or detected as part of the quarterly test this should be immediately escalated to the Security officer or someone with similar privileges who has the authority to stop, cease, shut down, and remove the offending device immediately.
7. A department that reasonably believes it may have an account breach, or a breach of cardholder information or of systems related to the PCI environment in general, must inform Whispering Pines Tactical & Gunsmithing PCI Incident Response Team. After being notified of a compromise, the PCI Response Team, along with other designated staff, will implement the PCI Incident Response Plan to assist and augment departments’ response plans.
Whispering Pines Tactical & Gunsmithing PCI Security Incident Response Team: (Update as applicable)
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CIO |
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Communications Director |
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Compliance Officer |
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Counsel |
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Information Security Officer |
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Collections & Merchant Services |
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Risk Manager |
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Incident Response Notification
Escalation Members
Escalation – First Level
Information Security Officer Controller
Executive Project Director for Credit Collections and Merchant Services Legal Counsel
Risk Manager
Director of Whispering Pines Tactical & Gunsmithing Communications
Escalation – Second Level
Whispering Pines Tactical & Gunsmithing President
Executive Cabinet
Internal Audit
Auxiliary members as needed
External Contacts (as needed)
Merchant Provider Card Brands
Internet Service Provider (if applicable)
Internet Service Provider of Intruder (if applicable) Communication Carriers (local and long distance) Business Partners
Insurance Carrier
External Response Team as applicable (CERT Coordination Center 1, etc.) Law Enforcement Agencies as applicable in local jurisdiction
In response to a systems compromise, the PCI Response Team and designees will:
4. Contact internal and external departments and entities as appropriate.
5. Make forensic and log analysis available to appropriate law enforcement or card industry security personnel, as required.
6. Assist law enforcement and card industry security personnel in investigative processes, including in prosecutions.
The card companies have individually specific requirements the Response Team must address in reporting suspected or confirmed breaches of cardholder data.
Incident Response notifications to various card schemes
1. In the event of a suspected security breach, alert the information security officer or your line manager immediately.
2. The security officer will conduct an initial investigation of the suspected security breach.
3. Upon confirmation that a security breach has occurred, the security officer will alert management and begin informing all relevant parties that may be affected by the compromise.
VISA Steps
If the data security compromise involves credit card account numbers, implement the following procedure:
· Shut down any systems or processes involved in the breach to limit the extent and prevent further exposure.
· Alert all affected parties and authorities such as the Merchant Bank (your Bank), Visa Fraud Control, and the law enforcement.
· Provide details of all compromised or potentially compromised card numbers to Visa Fraud Control within 24 hrs.
· For more Information visit: http://usa.visa.com/business/accepting_visa/ops_risk_management/cisp_if_ compromised.html
Visa Incident Report Template
This report must be provided to VISA within 14 days after initial report of incident to VISA. The following report content and standards must be followed when completing the incident report. Incident report must be securely distributed to VISA and Merchant Bank. Visa will classify the report as “VISA Secret”*.
I. Executive Summary
a. Include overview of the incident.
b. Include RISK Level (High, Medium, Low)
c. Determine if compromise has been contained.
II. Background
III. Initial Analysis
IV. Investigative Procedures
a. Include forensic tools used during investigation.
V. Findings
a. Number of accounts at risk, identify those stores and compromised.
b. Type of account information at risk
c. Identify ALL systems analysed. Include the following:
• Domain Name System (DNS) names
• Internet Protocol (IP) addresses
• Operating System (OS) version
• Function of system(s)
d. Identify ALL compromised systems. Include the following:
• DNS names
• IP addresses
• OS version
• Function of System(s)
e. Timeframe of compromise
f. Any data exported by intruder.
g. Establish how and source of compromise.
h. Check all potential database locations to ensure that no CVV2, Track 1 or Track 2 data is stored anywhere, whether encrypted or unencrypted (e.g., duplicate or backup tables or databases, databases used in development, stage or testing environments, data on software engineers’ machines, etc.)
i. If applicable, review VisaNet endpoint security and determine risk.
VI. Compromised Entity Action
VII. Recommendations
VIII. Contact(s) at entity and security assessor performing investigation.
*This classification applies to the most sensitive business information, which is intended for use within VISA. Its unauthorized disclosure could seriously and adversely impact VISA, its employees, member banks, business partners, and/or the Brand.
MasterCard Steps:
5. Provide weekly written status reports to MasterCard, addressing open questions and issues until the audit is complete to the satisfaction of MasterCard.
6. Promptly furnish updated lists of potential or known compromised account numbers, additional documentation, and other information that MasterCard may request.
7. Provide finding of all audits and investigations to the MasterCard Merchant Fraud Control department within the required time frame and continue to address any outstanding exposure or recommendation until resolved to the satisfaction of MasterCard.
Once MasterCard obtains the details of the account data compromise and the list of compromised account numbers, MasterCard will:
1. Identify the issuers of the accounts that were suspected to have been compromised and group all known accounts under the respective parent member IDs.
2. Distribute the account number data to its respective issuers.
Employees of the company will be expected to report to the security officer for any security related issues. The role of the security officer is to effectively communicate all security policies and procedures to employees within the company and contractors. In addition to this, the security officer will oversee the scheduling of security training sessions, monitor and enforce the security policies outlined in both this document and at the training sessions and finally, oversee the implantation of the incident response plan in the event of a sensitive data compromise.
Discover Card Steps
1. Within 24 hours of an account compromise event, notify Discover Fraud Prevention
2. Prepare a detailed written statement of fact about the account compromise including the contributing circumstances.
3. Prepare a list of all known compromised account numbers.
4. Obtain additional specific requirements from Discover Card
American Express Steps
1. Within 24 hours of an account compromise event, notify American Express Merchant Services
2. Prepare a detailed written statement of fact about the account compromise including the contributing circumstances.
3. Prepare a list of all known compromised account numbers.
Obtain additional specific requirements from American Express
Roles and responsibilities need to be defined down to a requirement level.
Chief Security Officer (or equivalent) is responsible for overseeing all aspects of information security, including but not limited to:
· Creating and distributing security policies and procedures.
· Ensure that security controls are maintained.
· Perform risk analysis.
· Monitoring and analysing security alerts and distributing information to appropriate information security and business unit management personnel.
· creating and distributing security incident response and escalation procedures that
· Maintaining a formal security awareness program for all employees that provide multiple methods of communicating awareness and educating employees (for example, posters, letters, meetings).
· Manage the vulnerability management and penetration testing program.
· Maintain a list of service providers.
· Ensure there is a process for engaging service providers including proper due diligence prior to engagement.
· Maintain a program to verify service providers’ PCI-DSS compliant status, with supporting documentation.
The Information Technology Office (or equivalent) shall maintain daily administrative and technical operational security procedures that are consistent with the PCI-DSS (for example, user account maintenance procedures, and log review procedures).
Network Administrators shall:
· Maintain network devices including firewalls and routers.
· Perform firewall ruleset reviews every six months.
· Ensure that network devices are securely configured.
System and Application Administrators shall:
· monitor and analyse security alerts and information and distribute to appropriate personnel.
· administer user accounts and manage authentication.
· Monitor and control all access to data.
· Ensure that systems and devices are securely configured.
The Human Resources Office (or equivalent) is responsible for tracking employee participation in the security awareness program, including:
· Facilitating participation upon hire and at least annually.
· Ensuring that employees acknowledge in writing at least annually that they have read and understand the Company’s information security policy.
General Counsel (or equivalent) will ensure that for service providers with whom cardholder information is shared:
· Written contracts require adherence to PCI-DSS by the service provider.
· Written contracts include acknowledgement or responsibility for the security of cardholder data by the service provider.
· All third-party companies providing critical services to Whispering Pines Tactical & Gunsmithing must provide an agreed Service Level Agreement.
· All third-party companies providing hosting facilities must comply with the Company’s Physical Security and Access Control Policy.
· All third-party companies which can affect the security of Card Holder information must:
1. Adhere to the PCI DSS security requirements.
2. Acknowledge their responsibility for securing the Card Holder data.
3. Acknowledge that the Card Holder data must only be used for assisting the completion of a transaction, supporting a loyalty program, providing a fraud control service or for uses specifically required by law.
4. Have appropriate provisions for business continuity in the event of a major disruption, disaster, or failure.
· Access to Whispering Pines Tactical & Gunsmithing is controlled through a formal user registration process beginning with a formal notification from HR or from a line manager.
· Each user is identified by a unique user ID so that users can be linked to and made responsible for their actions. The use of group IDs is only permitted where they are suitable for the work conducted.
· There is a standard level of access; other services can be accessed when specifically authorized by HR/line management.
· The job function of the user decides the level of access the employee has to cardholder data.
· A request for service must be made in writing (email or hard copy) by the newcomer’s line manager or by HR. The request is free format, but must state:
Name of person making request:
Job title of the newcomers and workgroup:
Start date:
Services required (default services are MS Outlook, MS Office, and Internet access):
· Each user will be given a copy of their new user form to provide a written statement of their access rights, signed by an IT representative after their induction procedure. The user signs the form indicating that they understand the conditions of access.
· Access to all Whispering Pines Tactical & Gunsmithing systems is provided by IT and can only be started after proper procedures are completed.
· As soon as an individual leaves the Company employment, all his/her system logons must be immediately revoked.
· As part of the employee termination process HR (or line managers in the case of contractors) will inform IT operations of all leavers and their date of leaving.
· Access Control systems are in place to protect the interests of all users of Whispering Pines Tactical & Gunsmithing computer systems by providing a safe, secure, and readily accessible environment in which to work.
· Whispering Pines Tactical & Gunsmithing will provide all employees and other users with the information they need to carry out their responsibilities in as effective and efficient manner as possible.
· Generic or group IDs shall not normally be permitted but may be granted under exceptional circumstances if sufficient other controls on access are in place.
· The allocation of privilege rights (e.g. local administrator, domain administrator, super-user, root access) shall be restricted and controlled, and authorization provided jointly by the system owner and IT Services. Technical teams shall guard against issuing privilege rights to entire teams to prevent loss of confidentiality.
· Access rights will be accorded following the principles of least privilege and need to know.
· Every user should attempt to maintain the security of data at its classified level even if technical security mechanisms fail or are absent.
· Users electing to place information on digital media or storage devices or maintaining a separate database must only do so where such an action is in accord with the data’s classification.
· Users are obligated to report instances of non-compliance to the Whispering Pines Tactical & Gunsmithing CISO.
· Access to The Company IT resources and services will be given through the provision of a unique Active Directory account and complex password.
· No access to any The Company IT resources and services will be provided without prior authentication and authorization of a user’s Whispering Pines Tactical & Gunsmithing Windows Active Directory account.
· Password issuing, strength requirements, changing and control will be managed through formal processes. Password length, complexity and expiration times will be controlled through Windows Active Directory Group Policy Objects.
· Access to Confidential, Restricted and Protected information will be limited to authorised persons whose job responsibilities require it, as determined by the data owner or their designated representative. Requests for access permission to be granted, changed or revoked must be made in writing.
· Users are expected to become familiar with and abide by Whispering Pines Tactical & Gunsmithing policies, standards, and guidelines for appropriate and acceptable usage of the networks and systems.
· Access for remote users shall be subject to authorization by IT Services and be provided in accordance with the Remote Access Policy and the Information Security Policy. No uncontrolled external access shall be permitted to any network device or networked system.
· Access to data is variously and appropriately controlled according to the data classification levels described in the Information Security Management Policy.
· Access control methods include logon access rights, Windows share and NTFS permissions, user account privileges, server and workstation access rights, firewall permissions, IIS intranet/extranet authentication rights, SQL database rights, isolated networks, and other methods, as necessary.
· A formal process shall be conducted at regular intervals by system owners and data owners in conjunction with IT Services to review users’ access rights. The review shall be logged, and IT Services shall sign off the review to give authority for users’ continued access rights.
· Installation or use of any wireless device or wireless network intended to be used to connect to any of the Whispering Pines Tactical & Gunsmithing networks or environments is prohibited.
· A quarterly test should be run to discover any wireless access points connected to Whispering Pines Tactical & Gunsmithing network.
· Usage of appropriate testing using tools like net stumbler, kismet etc. must be performed on a quarterly basis to ensure that:
· Any devices which support wireless communication remain disabled or decommissioned.
· If any violation of the Wireless Policy is discovered because of the normal audit processes, the security officer or any one with similar job description has the authorisation to stop, cease, shut down, and remove the offending device immediately.
If the need arises to use wireless technology, it should be approved by Whispering Pines Tactical & Gunsmithing, and the following wireless standards must be adhered to:
1. Default SNMP community strings and passwords, passphrases, Encryption keys/security related vendor defaults (if applicable) should be changed immediately after the installation of the device and if anyone with knowledge of these leaves the company.
2. The firmware on the wireless devices must be updated accordingly as per vendors release schedule.
3. The firmware on the wireless devices must support strong encryption for authentication and transmission over wireless networks.
4. Any other security related wireless vendor defaults should be changed if applicable.
5. Wireless networks must implement industry best practices (IEEE 802.11i) and strong encryption for authentication and transmission of cardholder data.
6. An Inventory of authorized access points along with a business justification must be maintained. (Update Appendix B)
· Cardholder Data (CHD) must be rendered unreadable when stored and use strong encryption such as AES 256 or Triple DES 168-bit encryption and associated key management.
· Encryption keys must be managed according to the following:
o Rotated annually.
o Data encryption keys (DEK) must be protected when stored either within a Secure Cryptographic Device (SCD) or encrypted using a Key Encryption Key.
o DEK and KEK are not to be stored together.
o Keys and key components must be managed so that separation of duties and split knowledge are maintained.
Appendix A – Agreement to Comply Form – Agreement to Comply with Information Security Policies
________________________
Employee Name (printed)
________________
Department
I agree to take all reasonable precautions to assure that company internal information, or information that has been entrusted to the Company by third parties such as customers, will not be disclosed to unauthorised persons. At the end of my employment or contract with the Company, I agree to return all information to which I have had access because of my position. I understand that I am not authorised to use sensitive information for my own purposes, nor am I at liberty to provide this information to third parties without the express written consent of the internal manager who is the designated information owner.
I have access to a copy of the Information Security Policies, I have read and understand these policies, and I understand how it impacts my job. As a condition of continued employment, I agree to abide by the policies and other requirements found in the Company security policy. I understand that non-compliance will be cause for disciplinary action up to and including dismissal, and perhaps criminal and/or civil penalties.
I also agree to promptly report all violations or suspected violations of information security policies to the designated security officer.
________________________
Employee Signature
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Appendix C – POI Management Policy
Where the Company are utilizing POI’s, the following policies are applicable:
POI Device Inventory and Management:
· Maintain an up-to-date inventory of all POI devices, including make, model, location, and serial number.
· Establish procedures for securely adding, relocating, and decommissioning POI devices.
Physical Security Measures:
· Secure POI devices to prevent tampering or substitution. This includes using tamper-evident seals or enclosures.
· Regularly inspect devices for signs of tampering or substitution.
· Implement secure storage for devices not in use.
Device Inspection and Maintenance:
· Conduct regular inspections and maintenance of POI devices to ensure they are functioning correctly and have not been compromised.
· Document and maintain a record of all inspections and maintenance activities.
Secure Configuration and Software Management:
· Ensure that POI devices are configured securely and in compliance with PCI DSS requirements.
· Implement measures to prevent unauthorized changes to software and configuration settings.
· Regularly update POI device software, including patches for known vulnerabilities.
Access Controls:
· Restrict access to POI devices to authorized personnel only.
· Use strong authentication methods for administrative access to POI devices.
· Implement role-based access controls and segregate duties to minimize the risk of unauthorized access or changes.
Appendix D – eCommerce Configuration and Hardening Policy
Where the Company are utilizing re-direct and iFrame solutions to take payments for the eCommerce environment the Company need to apply system configuration and hardening of these systems as follows:
Establish a Standard eCommerce Server Configuration:
· Define a standard configuration for servers that includes necessary services, protocols, and settings.
· Ensure that vendor default accounts are changed, removed, or disabled.
· Disable unnecessary services and protocols to minimize vulnerabilities.
· Ensure that all security settings are aligned with industry best practices.
Implement Hardening Procedures:
· Implement strong authentication and authorization mechanisms.
· Use file integrity monitoring tools to detect unauthorized changes.
· Enforce the use of antivirus and anti-malware solutions.
Control Administrative Access:
· Limit access to server configurations to authorized personnel only.
· Use multi-factor authentication for administrative access.
· Maintain an audit trail of all access and changes made to server configurations.
Regularly Review and Update Configurations:
· Periodically review server configurations against the established standard.
· Update the configurations in response to new threats, vulnerabilities, or changes in organizational needs.
Maintain a Vulnerability Management Program:
· Regularly scan for vulnerabilities and address identified weaknesses.
· Include both software and physical components in your vulnerability assessments.
· Establish a process to check for new security vulnerabilities and include the following:
o Industry recognized sources
o Risk ranking process based on industry best practices and identification of vulnerabilities that are elevated risk.
· Regularly update and patch operating systems and software to fix vulnerabilities.
· Ensure to apply applicable security patches within one month from release.
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