PCI Compliance with Sage Pay Form, Server & Direct

12 July 2009

I’ve done a large amount of research into PCI Compliancy, specifically in relation to Sage Pay and Magento. After running in many circles I can finally summarise my findings.

The comments below are based on a Level 4 Merchant (most SME’s come into this category) who only ever uses their Magento Website to take payments, i.e no on/offline terminals, etc).

For this article, I assume that “storing” cardholder data includes even for a short while in “memory”. Unfortunately the “in memory” issue seems to have a lot of people arguing, I’ve come to the conclusion that by taking the details of a card on your site and then using Apache to post these onto the Payment Provider, you are indeed storing the details in Memory and exposing them to any potential Viruses/Hackers on your server. It would be good if PCI Security Standards council could be more specific on these issues.

Merchant’s using Sage Pay Form and Server (also Google Checkout, PayPal Standard, etc):

  • Do not need quarterly vulnerability scans unless their merchant account providers specifically require it.
  • The website does not need to be hosted with a PCI compliant service provider.
  • Should complete the SAQ-A because they do not "store, process or transmit any cardholder data" on merchant premises but rely entirely on (Sage Pay) to handly these functions.

Merchant’s using Sage Pay Direct (also Authorize.net):

  • Should not store un-necessary cardholder data
  • Should be running a PA-DSS Compliant Payment Application by October 2009 (Coming soon to Magento Commercial Editions)
  • Should host the site on a Dedicated Server environment with a Level 1 or 2 PCI Compliant Service Provider (with the Database and Application Server seperated).
  • Should carry out quarterly vulnerability scans of their server network
  • Will need to complete SAQ-D because they are storing data (even thought it’s for a short time in system memory). The SAQ-D is complicated and can cost a lot of time and money to complete!

At the moment there are very few web hosts who are actually fully PCI-DSS certified service providers to Level 1 or 2 (due to the costs and restrictions). Be very wary of web hosts who claim that their hosting is PCI compliant without saying which levels, types and parts they are talking about. Remember that passing the security scan is only a small part of overall compliance. Visa provides a list of the Level 1 service providers here:

http://usa.visa.com/download/merchants/cisp_list_of_cisp_compliant_service_providers.pdf

I’ve also compiled a list of some providers I’ve been able to confirm their status with:

ZZ Servers
GSI Hosting

Approved Scanning Vendors who can provide the scanning and PCI certificates include McAfee Secure, Comodo and SecurityMetrics (https://www.pcisecuritystandards.org/pdfs/asv_report.html)

Once all this has been done, the SAQ along with the successful completion of the quarterly vulnerability scan (if any), should be submitted to your merchant account provider to show compliance with the requirements of PCI-DSS.

I hope this helps some people along the way, If you need help with a Magento and SagePay Integration, please get in touch.


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