Payment Card Industry (PCI) Data Security Standard

Payment Card Industry (PCI) Data Security Standard Attestation of Compliance for Onsite Assessments Service Providers Version 3.0 February 2014

Section 1: Assessment Information Instructions for Submission This Attestation of Compliance must be completed as a declaration of the results of the service provider s assessment with the Payment Card Industry Data Security Standard Requirements and Security Assessment Procedures (PCI DSS). Complete all sections: The service provider is responsible for ensuring that each section is completed by the relevant parties, as applicable. Contact the requesting payment brand for reporting and submission procedures. Part 1. Service Provider and Qualified Security Assessor Information Part 1a. Service Provider Organization Information Company Name: Shift4 Corporation DBA (doing business as): Contact Name: JD Oder II Title: Founder, CTO, SVP Research & Development ISA Name(s) (if applicable): Title: Telephone: 702.597.2480 E-mail: jd@shift4.com Business Address: 1491 Center Crossing Rd. City: Las Vegas State/Province: Nevada Country: USA Zip: 89144 URL: www.shift4.com Part 1b. Qualified Security Assessor Company Information (if applicable) Company Name: Fishnet Security, Inc. Lead QSA Contact Name: Chad Barr Title: Sr. Security Consultant Telephone: 888.732.9406 E-mail: Chad.Barr@fishnetsecurity.co m Business Address: 6130 Sprint Parkway, Suite 400 City: Overland Park State/Province: KS Country: USA Zip: 66211 URL: www.fishnetsecurity.com 2006-2014 PCI Security Standards Council, LLC. All Rights Reserved. Page 1

Part 2. Executive Summary Part 2a. Scope Verification Services that were INCLUDED in the scope of the PCI DSS Assessment (check all that apply): Name of service(s) assessed: DOLLARS ON THE NET (DOTN ) Type of service(s) assessed: Hosting Provider: Applications / software Hardware Infrastructure / Network Physical space (co-location) Storage Web Security services 3-D Secure Hosting Provider Shared Hosting Provider Other Hosting (specify): Managed Services (specify): Systems security services IT support Physical security Terminal Management System Other services (specify): Payment Processing: POS / card present Internet / e-commerce MOTO / Call Center ATM Other processing (specify): Account Management Fraud and Chargeback Payment Gateway/Switch Back-Office Services Issuer Processing Prepaid Services Billing Management Loyalty Programs Records Management Clearing and Settlement Merchant Services Tax/Government Payments Network Provider Others (specify): Note: These categories are provided for assistance only, and are not intended to limit or predetermine an entity s service description. If you feel these categories don t apply to your service, complete Others. If you re unsure whether a category could apply to your service, consult with the applicable payment brand. 2006-2014 PCI Security Standards Council, LLC. All Rights Reserved. Page 2

Services that are provided by the service provider but were NOT INCLUDED in the scope of the PCI DSS Assessment (check all that apply): Name of service(s) not assessed: Type of service(s) not assessed: Hosting Provider: Applications / software Hardware Infrastructure / Network Physical space (co-location) Storage Web Security services 3-D Secure Hosting Provider Shared Hosting Provider Other Hosting (specify): N/A Managed Services (specify): Systems security services IT support Physical security Terminal Management System Other services (specify): Payment Processing: POS / card present Internet / e-commerce MOTO / Call Center ATM Other processing (specify): Account Management Fraud and Chargeback Payment Gateway/Switch Back-Office Services Issuer Processing Prepaid Services Billing Management Loyalty Programs Records Management Clearing and Settlement Merchant Services Tax/Government Payments Network Provider Others (specify): Provide a brief explanation why any checked services were not included in the assessment: Part 2b. Description of Payment Card Business Describe how and in what capacity your business stores, processes, and/or transmits cardholder data. Describe how and in what capacity your business is otherwise involved in or has the ability to impact the security of cardholder data. Shift4 supplies electronic payment card authorization, accounting, fraud detection and settlement services. Shift4 provides POS application tokenization and web application tokenization solutions for their merchant clients. N/A Part 2c. Locations List types of facilities and a summary of locations included in PCI DSS review (for example, retail outlets, corporate offices, data centers, call centers, etc.): Type of facility: Location(s) of facility (city, country): Shift4 Corporate Office Fire Mesa Data Center S7 (Switch) Data Center 1491 Center Crossing Rd, Las Vegas Nevada 2410 Fire Mesa Street, Las Vegas Nevada 7135 S. Decatur Blvd, Las Vegas Nevada 2006-2014 PCI Security Standards Council, LLC. All Rights Reserved. Page 3

Part 2d. Payment Applications Does the organization use one or more Payment Applications? Yes No Provide the following information regarding the Payment Applications your organization uses: Payment Application Name Version Number Application Vendor Is application PA-DSS Listed? PA-DSS Listing Expiry date (if applicable) Universal Transacation Gateway (UTG ) 4Go with Universal Transaction Gateway (UTG ) Secure Suite 4 MICROS 3700 and 9700 with Universal Transaction Gateway (UTG ) 4.6 Shift4 Yes No 28 Oct 2016 4.6 Shift4 Yes No 28 Oct 2016 1.8 Shift4 Yes No 28 Oct 2016 Part 2e. Description of Environment Provide a high-level description of the environment covered by this assessment. For example: Connections into and out of the cardholder data environment (CDE). Critical system components within the CDE, such as POS devices, databases, web servers, etc., and any other necessary payment components, as applicable. Shift4 accepts Cardholder Data (CHD) into their environment for both Card-Present and Card-Not-Present credit transactions and also accepts Card-Present debit transactions. Shift4 acts as a value-added transaction payment gateway and provides a secure connection between merchant clients and their acquirer of record. Shift4 also provides extremely innovative customer applications allowing their merchant clients to have an extremely enhanced level of control over their transaction records and information. Shift4 s client offering is also a comprehensive accounting application that supports pre- and post-settlement auditing, batch settlements, and a 24-month archive of all transactions to help merchants simplify the accounting process and prevent against costly chargebacks. On the merchant side, Shift4 provides four PA-DSS v.2.0 validated API payment components to facilitate transactions. Currently, Shift4 has the following PCI SSC listed generic APIs for use at merchant client locations: 4Go with Universal Transaction Gateway (UTG ) Universal Transaction Gateway (UTG ) The 4Go and UTG APIs are designed to work with any multitude of customer POS systems and can be customized by Shift4 s integration team to accommodate any POS system running on these operating systems: Windows Vista SP2 2006-2014 PCI Security Standards Council, LLC. All Rights Reserved. Page 4

Windows 7 SP1 Windows 8/8.1 Windows Server 2008 SP2 Windows Server 2008 R2 Windows Server 2012 Shift4 also has two PCI SSC listed APIs for use at merchant locations where MICROS 3700 or 9700 POS systems are present: Secure Suite 4 MICROS 3700 with UTG Secure Suite 4 MICROS 9700 with UTG Shift4 merchant clients not using Shift4 APIs with their POS systems can use Shift4 s i4go technology. i4go can be used to accommodate ecommerce transactions and also works in a non-ecommerce environment if the merchant client s POS system is web-based. i4go utilizes TLSv1.2 connectivity over the Internet to connect to the Shift4 environment and securely process these transactions. Shift4 s transmission technologies, client tokenization solutions, and secure transaction processing environment ensure that CHD is secured and protected throughout the entire transaction process. Shift4 s Secure Transmission Methods: Shift4 has two secure transmission methods for their client s transactions: 1. Universal Transaction Gateway (UTG ) a clientside API that utilizes Shift4 s proprietary transmission technology known as Derived Unique Key Per Transaction with Moving Target Encryption (DUKPT w/mte) using three different PCI DSS defined strong encryption algorythms for transport of clients real-time transactional data. 2. i4go - browser-embedded client-side API that utilizes secure TLS 1.2 connectivity for the transport of clients real-time data. Shift4 s True-Tokenization Technology: Shift4 is the original innovator in tokenization technologies. Tokenization is accomplished as follows: 1. 4Go - Shift4 s patented API that runs at the driver level of client s POS systems and intercepts CHD at the swipe. CHD is replaced with either False Cardholder Data (FCHD) or a TrueToken. 4Go then utilizes UTG to transmit the actual CHD to Shift4 s DOTN environment. At this point, only FCHD or a TrueToken is then used to process the transaction within POS system. 2. i4go - at the point-of-sale, the merchant client or merchant client s customers enter their CHD directly into the merchant client s web application using the direct-post method into the integrated i4go form. The CHD is redirected from the browser to Shift4 s DOTN environment, so CHD never enters the browser based application or the host provider s environment (if present). i4go doesn t utilize 2006-2014 PCI Security Standards Council, LLC. All Rights Reserved. Page 5

UTG for transmission; rather all actual CHD is transmitted back to the DOTN environment using TLS 1.2 connectivity. At this point, only a TrueToken is passed back to the merchant s web application and is then used to process the transaction within the web application or web-based POS system. Shift4 and Point-to-Point Encryption (P2PE): Shift4 s solution is completely compatible with any P2PE solutions available today. Shift4 solutions are all capable of having hardware-based P2PE bolted on top. Adding hardware-based P2PE without the use of 4Go will still provide Shift4 True Tokenization through the use of UTG, and for merchants using 4Go, P2PE adds an additional layer of security beyond what 4Go provides by encrypting the CHD as it is swiped so that it never even enters a merchant client s system in any exposed form. Shift4 also provides compatibility for mobile P2PE devices in an offering known as VT4. VT4 is accomplished through the use of approved P2PE-enabled swipe devices attached to a merchant client s mobile phone, tablet, etc. The swipe device will immediately encrypt the CHD, and pass it along to UTG for transmission to the DOTN environment. With all of these P2PE solutions, as long as the Shift4 merchant client has no ability to decrypt the data onsite, the entire merchant environment can be removed from scope. Only the P2PE device itself would be in-scope for PCI, and that scope is limited to physical protection. Shift4 s environment can support any form of P2PE; mobile, PIN transaction P2PE devices, and Magnetic Stripe Reader (MSR) devices Shift4 s Gateway Environment: The Shift4 DOTN environment is currently connected to several processors In North America including a direct connection to American Express. All storage of merchant CHD is housed securely in separate merchant databases residing in MS-SQL servers on internal network segments. All of the tokenized and/or transactional data in each merchant database is fully encrypted with PCI DSS defined strong encryption. Backups of all merchant data are via storage area network replication are also fully encrypted and remain under the control of Shift4 personnel at all times. It s important to note that debit transactions involving PIN/PVV/PIN-Block are facilitated by ensuring all PIN/PVV/PIN-Block data merely passes through the Shift4 environment from the merchant s originating POS/Debit system to the upstream service provider. All PIN/PVV/PINblock data remains encrypted and untouched end-to-end, from the merchant s POS system, through the Shift4 environment, and remains encrypted until it is received by the upstream processor. At no time does Shift4 manipulate, write, or decrypt the encrypted PIN/PVV/PIN-Block data. 2006-2014 PCI Security Standards Council, LLC. All Rights Reserved. Page 6

All transactions handled within the DOTN environment are processed via nineteen upstream processors including Shift4 s direct connection to American Express. The assessment activities included interviews and a review of the network focusing on the Shift4 Dollars-on-the-Net (DOTN) environment. As a part of this assessment, the following elements were investigated: The process and security controls surrounding the storage of cardholder data The security of system components transmitting cardholder data Overall information security policies and practices of Shift4 Does your business use network segmentation to affect the scope of your PCI DSS environment? (Refer to Network Segmentation section of PCI DSS for guidance on network segmentation) Yes No Part 2f. Third-Party Service Providers Does your company have a relationship with one or more third-party service providers (for example, gateways, payment processors, payment service providers (PSP), web-hosting companies, airline booking agents, loyalty program agents, etc.) for the purpose of the services being validated? Yes No If Yes: Type of service provider: Description of services provided: Note: Requirement 12.8 applies to all entities in this list. 2006-2014 PCI Security Standards Council, LLC. All Rights Reserved. Page 7

Part 2g. Summary of Requirements Tested For each PCI DSS Requirement, select one of the following: Full The requirement and all sub-requirements of that requirement were assessed, and no subrequirements were marked as Not Tested or Not Applicable in the ROC. Partial One or more sub-requirements of that requirement were marked as Not Tested or Not Applicable in the ROC. None All sub-requirements of that requirement were marked as Not Tested and/or Not Applicable in the ROC. For all requirements identified as either Partial or None, provide details in the Justification for Approach column, including: Details of specific sub-requirements that were marked as either Not Tested and/or Not Applicable in the ROC Reason why sub-requirement(s) were not tested or not applicable Note: One table to be completed for each service covered by this AOC. Additional copies of this section are available on the PCI SSC website. Name of Service Assessed: DOLLARS ON THE NET (DOTN ) PCI DSS Requirement Requirement 1: Requirement 2: Requirement 3: Requirement 4: Requirement 5: Full Partial None Details of Requirements Assessed Justification for Approach (Required for all Partial and None responses. Identify which sub-requirements were not tested and the reason.) 1.2.2 - No routers are in scope, all routing occurs within the firewalls. 1.2.3 - No Wireless networks are in-scope. 1.4 - No moble devices with direct connectivity to the Internet are allowed route access to the CDE. 2.1.x - No Wireless networks are in-scope. 2.2.3 - No insecure services, daemons or protocols are used in the CDE. 2.6 - Shift4 is not a shared hostng provider. 3.2 - Shift4 does not store sensitive authentication data after authorization and is no an issuer or support issuing services. 3.4.1 - Shift4 does not use Disk Level Encryption. 3.6.a - Shift4 does not share any encryption keys with 3 rd Parties. 3.6.6 - Manual clear-text cryptographic keymanagement operations are not used. 4.1.1 - No Wireless networks are in-scope 4.2 - No end-user messageing technologies are ever used to transmit cardholder data. 5.1.2 - Shift4 is an all Windows shop and all systems are running the latest Anti-virus software. Requirement 6: 2006-2014 PCI Security Standards Council, LLC. All Rights Reserved. Page 8

Requirement 7: Requirement 8: Requirement 9: 8.1.5 - No vendors or 3 rd parties are allowed remote access into the CDE. 8.3 - No remote access is allowed to the CDE originating from outside the network. 8.5.1 - Shift4 does not have access to customer premises. 9.1.3 - No Wireless devices are in the CDE. 9.5-9.7 - Shift4 performs no backup to external media. 9.8.1 - Shift4 does not have any hard-copy material that would contain CHD. 9.9 Shift4 has no physical interfaces receiving CHD. Requirement 10: Requirement 11: Requirement 12: Appendix A: 11.3.2 - No internal environment that would require any form of penetration testing. 11.3.4.b - Penitration testing didn't include segmentation testing because of the Shift4 environment. 12.3.9 Vendors do not have remote access into the CDE. 12.8 Shift4 does not share CHD with 3 rd parties or services providers. 12.9 - RoC was performed before June 30, 2015. Shift4 does have in their contracts Roles and Responsibilies for protecting CHD. Shift4 is not a shared hosting provider 2006-2014 PCI Security Standards Council, LLC. All Rights Reserved. Page 9

Section 2: Report on Compliance This Attestation of Compliance reflects the results of an onsite assessment, which is documented in an accompanying Report on Compliance (ROC). The assessment documented in this attestation and in the ROC was completed on: Have compensating controls been used to meet any requirement in the ROC? Were any requirements in the ROC identified as being not applicable (N/A)? May 31, 2015 Yes Yes No No Were any requirements not tested? Yes No Were any requirements in the ROC unable to be met due to a legal constraint? Yes No 2006-2014 PCI Security Standards Council, LLC. All Rights Reserved. Page 10

Section 3: Validation and Attestation Details Part 3. PCI DSS Validation Based on the results noted in the ROC dated May 31, 2015, the signatories identified in Parts 3b-3d, as applicable, assert(s) the following compliance status for the entity identified in Part 2 of this document as of May 31, 2015: (check one): Compliant: All sections of the PCI DSS ROC are complete, all questions answered affirmatively, resulting in an overall COMPLIANT rating; thereby Shift4 has demonstrated full compliance with the PCI DSS. Non-Compliant: Not all sections of the PCI DSS ROC are complete, or not all questions are answered affirmatively, resulting in an overall NON-COMPLIANT rating, thereby (Service Provider Company Name) has not demonstrated full compliance with the PCI DSS. Target Date for Compliance: An entity submitting this form with a status of Non-Compliant may be required to complete the Action Plan in Part 4 of this document. Check with the payment brand(s) before completing Part 4. Compliant but with Legal exception: One or more requirements are marked Not in Place due to a legal restriction that prevents the requirement from being met. This option requires additional review from acquirer or payment brand. If checked, complete the following: Affected Requirement Details of how legal constraint prevents requirement being met Part 3a. Acknowledgement of Status Signatory(s) confirms: (Check all that apply) The ROC was completed according to the PCI DSS Requirements and Security Assessment Procedures, Version 3.0, and was completed according to the instructions therein. All information within the above-referenced ROC and in this attestation fairly represents the results of my assessment in all material respects. I have confirmed with my payment application vendor that my payment system does not store sensitive authentication data after authorization. I have read the PCI DSS and I recognize that I must maintain PCI DSS compliance, as applicable to my environment, at all times. If my environment changes, I recognize I must reassess my environment and implement any additional PCI DSS requirements that apply. 2006-2014 PCI Security Standards Council, LLC. All Rights Reserved. Page 11

Part 3a. Acknowledgement of Status (continued) No evidence of full track data 1, CAV2, CVC2, CID, or CVV2 data 2, or PIN data 3 storage after transaction authorization was found on ANY system reviewed during this assessment. ASV scans are being completed by the PCI SSC Approved Scanning Vendor AppSec Consulting Part 3b. Service Provider Attestation J.D. Oder II (Jul 27, 2015) Signature of Service Provider Executive Officer Date: May 31, 2015 Service Provider Executive Officer Name: J.D. Oder II Title: CTO Part 3c. QSA Acknowledgement (if applicable) If a QSA was involved or assisted with this assessment, describe the role performed: Chad M Barr Chad M Barr (Jul 27, 2015) FishNet Security QSA (Chad Barr) reviewed ALL requirements to validate they are indeed "IN-PLACE". The QSA also reviewed all physical/logical evidence and visited all "in-scope" facilities. Signature of QSA Date: May 31, 2015 QSA Name: Chad Barr QSA Company: FishNet Security Part 3d. ISA Acknowledgement (if applicable) If an ISA was involved or assisted with this assessment, describe the role performed: Signature of ISA ISA Name: Date: Title: 1 2 3 Data encoded in the magnetic stripe or equivalent data on a chip used for authorization during a card-present transaction. Entities may not retain full track data after transaction authorization. The only elements of track data that may be retained are primary account number (PAN), expiration date, and cardholder name. The three- or four-digit value printed by the signature panel or on the face of a payment card used to verify card-not-present transactions. Personal identification number entered by cardholder during a card-present transaction, and/or encrypted PIN block present within the transaction message. 2006-2014 PCI Security Standards Council, LLC. All Rights Reserved. Page 12

Part 4. Action Plan for Non-Compliant Requirements Select the appropriate response for Compliant to PCI DSS Requirements for each requirement. If you answer No to any of the requirements, you may be required to provide the date your Company expects to be compliant with the requirement and a brief description of the actions being taken to meet the requirement. Check with the applicable payment brand(s) before completing Part 4. PCI DSS Requirement Description of Requirement Compliant to PCI DSS Requirements (Select One) YES NO Remediation Date and Actions (If NO selected for any Requirement) 1 Install and maintain a firewall configuration to protect cardholder data 2 Do not use vendor-supplied defaults for system passwords and other security parameters 3 Protect stored cardholder data 4 5 6 7 8 9 10 11 12 Encrypt transmission of cardholder data across open, public networks Protect all systems against malware and regularly update antivirus software or programs Develop and maintain secure systems and applications Restrict access to cardholder data by business need to know Identify and authenticate access to system components Restrict physical access to cardholder data Track and monitor all access to network resources and cardholder data Regularly test security systems and processes Maintain a policy that addresses information security for all personnel 2006-2014 PCI Security Standards Council, LLC. All Rights Reserved. Page 13

Shift4 2015 PCI DSS v3 AOC Adobe Document Cloud Document History July 27, 2015 Created: July 27, 2015 By: Status: Transaction ID: Chad Barr (chad.barr@fishnetsecurity.com) SIGNED XQH4FRKXT3G6I4B Shift4 2015 PCI DSS v3 AOC History Document created by Chad M Barr (chad.barr@fishnetsecurity.com) July 27, 2015-3:58 AM PDT - IP address: 71.75.125.130 Document emailed to J.D. Oder II (jd@shift4.com) for signature July 27, 2015-3:59 AM PDT Document viewed by J.D. Oder II (jd@shift4.com) July 27, 2015-9:29 AM PDT - IP address: 166.171.121.217 Document e-signed by J.D. Oder II (jd@shift4.com) Signature Date: July 27, 2015-9:30 AM PDT - Time Source: server - IP address: 166.171.121.217 Document emailed to Chad M Barr (chad.barr@fishnetsecurity.com) for signature July 27, 2015-9:30 AM PDT Document viewed by Chad M Barr (chad.barr@fishnetsecurity.com) July 27, 2015-11:33 AM PDT - IP address: 71.75.125.130 Document e-signed by Chad M Barr (chad.barr@fishnetsecurity.com) Signature Date: July 27, 2015-11:35 AM PDT - Time Source: server - IP address: 71.75.125.130 Signed document emailed to J.D. Oder II (jd@shift4.com) and Chad M Barr (chad.barr@fishnetsecurity.com) July 27, 2015-11:35 AM PDT