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	<title>Comments on: Self-Assessment Questionnaires</title>
	<atom:link href="http://pciguru.wordpress.com/2011/05/06/self-assessment-questionnaires/feed/" rel="self" type="application/rss+xml" />
	<link>http://pciguru.wordpress.com/2011/05/06/self-assessment-questionnaires/</link>
	<description>A common sense approach to achieving PCI compliance and retaining your sanity</description>
	<lastBuildDate>Fri, 24 May 2013 11:23:05 +0000</lastBuildDate>
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	<item>
		<title>By: PCIGuru</title>
		<link>http://pciguru.wordpress.com/2011/05/06/self-assessment-questionnaires/#comment-8126</link>
		<dc:creator><![CDATA[PCIGuru]]></dc:creator>
		<pubDate>Wed, 15 May 2013 19:31:46 +0000</pubDate>
		<guid isPermaLink="false">http://pciguru.wordpress.com/?p=770#comment-8126</guid>
		<description><![CDATA[Based on your description, I am assuming that your Web site has the code that invokes the card processing frame/window.  That puts your Web site in scope for at least transmission and possibly processing depending on your Web application.  As a result, I would say you need to be doing an SAQ D.]]></description>
		<content:encoded><![CDATA[<p>Based on your description, I am assuming that your Web site has the code that invokes the card processing frame/window.  That puts your Web site in scope for at least transmission and possibly processing depending on your Web application.  As a result, I would say you need to be doing an SAQ D.</p>
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	<item>
		<title>By: Dano</title>
		<link>http://pciguru.wordpress.com/2011/05/06/self-assessment-questionnaires/#comment-8118</link>
		<dc:creator><![CDATA[Dano]]></dc:creator>
		<pubDate>Wed, 15 May 2013 05:41:40 +0000</pubDate>
		<guid isPermaLink="false">http://pciguru.wordpress.com/?p=770#comment-8118</guid>
		<description><![CDATA[Great article but even after reading all the responses I&#039;m questioning our particular case&#039;s SAQ requirement.
We only have a website, no phone orders.  Our web application talks to a 3rd party provider, however this information is entered (not stored) on our website (SSL) which talks to their API (Zuora).
So we don&#039;t store, but we do pass that info on (securely).
I understand your disclaimer about the bank having the final say so just after your general advice on this matter.
Keep up the great work!]]></description>
		<content:encoded><![CDATA[<p>Great article but even after reading all the responses I&#8217;m questioning our particular case&#8217;s SAQ requirement.<br />
We only have a website, no phone orders.  Our web application talks to a 3rd party provider, however this information is entered (not stored) on our website (SSL) which talks to their API (Zuora).<br />
So we don&#8217;t store, but we do pass that info on (securely).<br />
I understand your disclaimer about the bank having the final say so just after your general advice on this matter.<br />
Keep up the great work!</p>
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	<item>
		<title>By: PCIGuru</title>
		<link>http://pciguru.wordpress.com/2011/05/06/self-assessment-questionnaires/#comment-7623</link>
		<dc:creator><![CDATA[PCIGuru]]></dc:creator>
		<pubDate>Fri, 26 Apr 2013 09:41:43 +0000</pubDate>
		<guid isPermaLink="false">http://pciguru.wordpress.com/?p=770#comment-7623</guid>
		<description><![CDATA[As a reminder since I neglected to add it in my original reply, any non-relevant requirements in SAQ D should be marked as &#039;Not Applicable&#039; and the reason you believe the requirement is not applicable.

Good luck.]]></description>
		<content:encoded><![CDATA[<p>As a reminder since I neglected to add it in my original reply, any non-relevant requirements in SAQ D should be marked as &#8216;Not Applicable&#8217; and the reason you believe the requirement is not applicable.</p>
<p>Good luck.</p>
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		<title>By: Barb</title>
		<link>http://pciguru.wordpress.com/2011/05/06/self-assessment-questionnaires/#comment-7561</link>
		<dc:creator><![CDATA[Barb]]></dc:creator>
		<pubDate>Wed, 24 Apr 2013 11:51:02 +0000</pubDate>
		<guid isPermaLink="false">http://pciguru.wordpress.com/?p=770#comment-7561</guid>
		<description><![CDATA[Thanks for your quick reply again - I&#039;m off to attempt SAQ D :)]]></description>
		<content:encoded><![CDATA[<p>Thanks for your quick reply again &#8211; I&#8217;m off to attempt SAQ D <img src='http://s0.wp.com/wp-includes/images/smilies/icon_smile.gif' alt=':)' class='wp-smiley' /> </p>
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	<item>
		<title>By: PCIGuru</title>
		<link>http://pciguru.wordpress.com/2011/05/06/self-assessment-questionnaires/#comment-7560</link>
		<dc:creator><![CDATA[PCIGuru]]></dc:creator>
		<pubDate>Wed, 24 Apr 2013 10:21:49 +0000</pubDate>
		<guid isPermaLink="false">http://pciguru.wordpress.com/?p=770#comment-7560</guid>
		<description><![CDATA[You do an SAQ D and only fill out those requirements that fit your operations. 

In your case, use the SAQ C-VT to address your virtual terminal process.  Use SAQ B for covering your terminals.  Combine those into the SAQ D and fill in any other requirements in SAQ D that are relevant such as those in requirement 12 and 9, but please look at all the requirements to ensure you are not missing something.  The remainder of SAQ D for your organization will be marked &#039;Not Applicable&#039;.]]></description>
		<content:encoded><![CDATA[<p>You do an SAQ D and only fill out those requirements that fit your operations. </p>
<p>In your case, use the SAQ C-VT to address your virtual terminal process.  Use SAQ B for covering your terminals.  Combine those into the SAQ D and fill in any other requirements in SAQ D that are relevant such as those in requirement 12 and 9, but please look at all the requirements to ensure you are not missing something.  The remainder of SAQ D for your organization will be marked &#8216;Not Applicable&#8217;.</p>
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		<title>By: Barb</title>
		<link>http://pciguru.wordpress.com/2011/05/06/self-assessment-questionnaires/#comment-7547</link>
		<dc:creator><![CDATA[Barb]]></dc:creator>
		<pubDate>Wed, 24 Apr 2013 03:40:16 +0000</pubDate>
		<guid isPermaLink="false">http://pciguru.wordpress.com/?p=770#comment-7547</guid>
		<description><![CDATA[Thanks for your quick reply!  wrt the terminal printing the full PAN, I spent years trying to get them to correct it, before finally giving up on it.  I will mention it next time we need to get something done with the terminals though, I&#039;d prefer them not to print the full number out!

My contact at the bank is on holidays, and the replacement person has sent through the SAQ C-VT after I questioned it.  I&#039;ve only had a chance to have a glance through it, but two things that stand are the statements &quot;Merchant&#039;s only payment processing is via a virtual terminal accessed by an Internet-Connected web browser&quot; and &quot;This option would never apply to e-commerce merchants&quot;.

As I said earlier, we also have a bricks and mortar store, and a website, so are also processing payments via terminals and via the internet.  The internet payments are handled by a 3rd party (it&#039;s not via a redirect, but newer technology that I don&#039;t understand, our contact at the bank recommended it and said that using it would eliminate our need to be so PCI compliant).

Anyway, what I&#039;m wondering is, what happens for people running stores that handle payment processing in more than 1 way.  Each of the SAQs seems to focus on one payment type only (eg A for web payments, B for terminal payments etc) - what happens when there is a cross over, such as in our situation?]]></description>
		<content:encoded><![CDATA[<p>Thanks for your quick reply!  wrt the terminal printing the full PAN, I spent years trying to get them to correct it, before finally giving up on it.  I will mention it next time we need to get something done with the terminals though, I&#8217;d prefer them not to print the full number out!</p>
<p>My contact at the bank is on holidays, and the replacement person has sent through the SAQ C-VT after I questioned it.  I&#8217;ve only had a chance to have a glance through it, but two things that stand are the statements &#8220;Merchant&#8217;s only payment processing is via a virtual terminal accessed by an Internet-Connected web browser&#8221; and &#8220;This option would never apply to e-commerce merchants&#8221;.</p>
<p>As I said earlier, we also have a bricks and mortar store, and a website, so are also processing payments via terminals and via the internet.  The internet payments are handled by a 3rd party (it&#8217;s not via a redirect, but newer technology that I don&#8217;t understand, our contact at the bank recommended it and said that using it would eliminate our need to be so PCI compliant).</p>
<p>Anyway, what I&#8217;m wondering is, what happens for people running stores that handle payment processing in more than 1 way.  Each of the SAQs seems to focus on one payment type only (eg A for web payments, B for terminal payments etc) &#8211; what happens when there is a cross over, such as in our situation?</p>
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	<item>
		<title>By: PCIGuru</title>
		<link>http://pciguru.wordpress.com/2011/05/06/self-assessment-questionnaires/#comment-7519</link>
		<dc:creator><![CDATA[PCIGuru]]></dc:creator>
		<pubDate>Tue, 23 Apr 2013 10:43:51 +0000</pubDate>
		<guid isPermaLink="false">http://pciguru.wordpress.com/?p=770#comment-7519</guid>
		<description><![CDATA[I congratulate you on your diligence to do the right thing.

The issue with the terminal printing the full primary account number (PAN) is most likely a configuration issue. We encounter this all of the time. Why the vendors do not properly configure these terminals for their customers, I do not know.

If you were still doing your telephone orders over your card terminal and not the virtual terminal, I would agree with using SAQ B. However, as you have found out, SAQ B really doesn&#039;t cover the virtual terminal environment. 

In my opinion, SAQ C-VT is probably the better choice for your virtual terminal situation.

However, remember, your bank has the official word in this matter and if your bank insists on SAQ B, then fill it out and send it to them as they are the official word in this matter.]]></description>
		<content:encoded><![CDATA[<p>I congratulate you on your diligence to do the right thing.</p>
<p>The issue with the terminal printing the full primary account number (PAN) is most likely a configuration issue. We encounter this all of the time. Why the vendors do not properly configure these terminals for their customers, I do not know.</p>
<p>If you were still doing your telephone orders over your card terminal and not the virtual terminal, I would agree with using SAQ B. However, as you have found out, SAQ B really doesn&#8217;t cover the virtual terminal environment. </p>
<p>In my opinion, SAQ C-VT is probably the better choice for your virtual terminal situation.</p>
<p>However, remember, your bank has the official word in this matter and if your bank insists on SAQ B, then fill it out and send it to them as they are the official word in this matter.</p>
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		<title>By: Barb</title>
		<link>http://pciguru.wordpress.com/2011/05/06/self-assessment-questionnaires/#comment-7511</link>
		<dc:creator><![CDATA[Barb]]></dc:creator>
		<pubDate>Tue, 23 Apr 2013 08:15:26 +0000</pubDate>
		<guid isPermaLink="false">http://pciguru.wordpress.com/?p=770#comment-7511</guid>
		<description><![CDATA[Hi,
Thanks for your informative website, it&#039;s great to finally find one that is clear!

I am struggling through filling out a SAQ, and I&#039;m not convinced that I have the correct one.  We are a small business, with two physical locations, and a website.  We handle credit card details in the follow ways:
- in store, using stand alone eftpos terminals not connected to the internet, or to any pos systems etc.
- on our website, which doesn&#039;t store the details, a 3rd party processes the payments for us
- over the phone, we enter the card details into a virtual terminal using a stand alone computer connected to the internet.

I&#039;ve informed our bank of the above, and they have told me that SAQ B is the correct form to fill out.  However I&#039;m not convinced that it allows for the phone orders.  I&#039;m stuck on the first question of Part 2c, the eligibility to complete SAQ B.  It mentions in part: 

OR Merchant uses only standalone, dial-out terminals... (it goes on). &lt;-- Whilst it is true that our dial out terminals are stand alone, this doesn&#039;t allow for our use of the virtual terminal for phone orders??

What&#039;s your take on this - I am going to email the bank yet again to ask...

For those that have given up on phone orders (I&#039;m about to!) - has anyone considered MOTO transactions?  Before we had the virtual terminal, we used to use our stand alone terminal to process phone payments.  The reason we moved to a virtual terminal is because the receipt printed by the terminal used to list the full card number and expiry date - we felt this wasn&#039;t particularly secure (I don&#039;t know if this is still the case).  I wonder if moving back to using this function may make the process of PCI compliance easier?]]></description>
		<content:encoded><![CDATA[<p>Hi,<br />
Thanks for your informative website, it&#8217;s great to finally find one that is clear!</p>
<p>I am struggling through filling out a SAQ, and I&#8217;m not convinced that I have the correct one.  We are a small business, with two physical locations, and a website.  We handle credit card details in the follow ways:<br />
- in store, using stand alone eftpos terminals not connected to the internet, or to any pos systems etc.<br />
- on our website, which doesn&#8217;t store the details, a 3rd party processes the payments for us<br />
- over the phone, we enter the card details into a virtual terminal using a stand alone computer connected to the internet.</p>
<p>I&#8217;ve informed our bank of the above, and they have told me that SAQ B is the correct form to fill out.  However I&#8217;m not convinced that it allows for the phone orders.  I&#8217;m stuck on the first question of Part 2c, the eligibility to complete SAQ B.  It mentions in part: </p>
<p>OR Merchant uses only standalone, dial-out terminals&#8230; (it goes on). &lt;&#8211; Whilst it is true that our dial out terminals are stand alone, this doesn&#039;t allow for our use of the virtual terminal for phone orders??</p>
<p>What&#039;s your take on this &#8211; I am going to email the bank yet again to ask&#8230;</p>
<p>For those that have given up on phone orders (I&#039;m about to!) &#8211; has anyone considered MOTO transactions?  Before we had the virtual terminal, we used to use our stand alone terminal to process phone payments.  The reason we moved to a virtual terminal is because the receipt printed by the terminal used to list the full card number and expiry date &#8211; we felt this wasn&#039;t particularly secure (I don&#039;t know if this is still the case).  I wonder if moving back to using this function may make the process of PCI compliance easier?</p>
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	<item>
		<title>By: PCIGuru</title>
		<link>http://pciguru.wordpress.com/2011/05/06/self-assessment-questionnaires/#comment-6513</link>
		<dc:creator><![CDATA[PCIGuru]]></dc:creator>
		<pubDate>Thu, 04 Apr 2013 10:28:56 +0000</pubDate>
		<guid isPermaLink="false">http://pciguru.wordpress.com/?p=770#comment-6513</guid>
		<description><![CDATA[You are forgetting the process and transmit pieces of the equation.  The PCI DSS says that any entity that PROCESSES, STORES OR TRANSMITS cardholder data needs to comply.

We have a number of Level 1 merchants that do not store cardholder data, but they do process and transmit it and they all are required to conduct a PCI assessment and create a Report On Compliance (ROC).

On the Level 2 front, if you are a Level 2 merchant and accept MasterCard cards, you are required to conduct a full assessment and file your Attestation Of Compliance (AOC) and ROC with MasterCard.  That rule went into affect July 1, 2012.  See this &lt;a href=&quot;http://pciguru.wordpress.com/2012/01/24/are-you-a-level-2-merchant/&quot; title=&quot;Are You A Level 2 Merchant?&quot; target=&quot;_blank&quot; rel=&quot;nofollow&quot;&gt;post&lt;/a&gt; for clarification.]]></description>
		<content:encoded><![CDATA[<p>You are forgetting the process and transmit pieces of the equation.  The PCI DSS says that any entity that PROCESSES, STORES OR TRANSMITS cardholder data needs to comply.</p>
<p>We have a number of Level 1 merchants that do not store cardholder data, but they do process and transmit it and they all are required to conduct a PCI assessment and create a Report On Compliance (ROC).</p>
<p>On the Level 2 front, if you are a Level 2 merchant and accept MasterCard cards, you are required to conduct a full assessment and file your Attestation Of Compliance (AOC) and ROC with MasterCard.  That rule went into affect July 1, 2012.  See this <a href="http://pciguru.wordpress.com/2012/01/24/are-you-a-level-2-merchant/" title="Are You A Level 2 Merchant?" target="_blank" rel="nofollow">post</a> for clarification.</p>
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		<title>By: jb</title>
		<link>http://pciguru.wordpress.com/2011/05/06/self-assessment-questionnaires/#comment-6505</link>
		<dc:creator><![CDATA[jb]]></dc:creator>
		<pubDate>Thu, 04 Apr 2013 02:30:29 +0000</pubDate>
		<guid isPermaLink="false">http://pciguru.wordpress.com/?p=770#comment-6505</guid>
		<description><![CDATA[What about large retail chains that accept credit cards but do not store them? I&#039;m guessing their reporting requirements would be based on transaction volume (either SAQ B or C or ROC, if level 1.) It&#039;s that &quot;storage&quot; that gets me. If they accept over 6mm credit cards but do not store, are they classified as a level 1 and go through the ROC by a QSA? If they are a level 2 but do not store any card data, would they complete a SAQ b or a C?]]></description>
		<content:encoded><![CDATA[<p>What about large retail chains that accept credit cards but do not store them? I&#8217;m guessing their reporting requirements would be based on transaction volume (either SAQ B or C or ROC, if level 1.) It&#8217;s that &#8220;storage&#8221; that gets me. If they accept over 6mm credit cards but do not store, are they classified as a level 1 and go through the ROC by a QSA? If they are a level 2 but do not store any card data, would they complete a SAQ b or a C?</p>
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