Section 1: Unfair or Deceptive Acts or Practices and Marketing Compliance
It is American Diesel Training Center’s (ADTC) policy that all forms of marketing and advertising be approved by senior management prior to use.
REQUESTS FOR APPROVAL OF ADVERTISING
Officers may request approval of advertising and marketing by submitting a copy of the item (if
applicable) together with a completed Advertising Approval Request. One copy of the
request form should be submitted to senior management. The Advertising Approval Request Form should include a complete description of the advertisement or promotion and how or where it will be used. The officer submitting a request is responsible for obtaining the necessary approvals from compliance and senior management on the Advertising Approval Request Form before proceeding with an advertisement, promotion or marketing effort.
UNFAIR OR DECEPTIVE ACTS OR PRACTICES
ADTC shall comply with Section 5 of the Federal Trade Commission Act, 15 U.S.C. § 45(a): "Unfair methods of competition in or affecting commerce, and unfair or deceptive acts or practices in or affecting commerce, are hereby declared unlawful." The officer submitting a request is responsible for obtaining the necessary approvals from compliance and senior management before proceeding with an advertisement, promotion or marketing effort.
Certain regulatory disclosures are required for some ADTC advertising. Some forms of
advertising and marketing, such as lotteries are legally restricted. Proper approval must be
obtained from the compliance department and senior management before running any promotion.
The compliance department will ensure that all regulatory and disclosure requirements have been
met and will maintain copies of all advertising for review by examiners. Senior management will
approve content and cost.
Marketing efforts will be reviewed to ensure that target markets are not selected using a
prohibited basis: race, color, religion, national origin, sex, marital status, age, handicap, familial
status, receipt of public assistance income, or because an applicant has in good faith exercised
any rights under the Consumer Credit Protection Act.
COMMON MEDIUMS USED FOR ADVERTISING AND MARKETING
As defined by various regulations and laws many of the communications ADTC issues to the
public and its’ customers are forms of advertising. The following are common mediums used for advertising and marketing:
1. Social Media platforms;
2. Billboards; signs, and banners
3. Ads in magazines, newspapers, phonebooks, and other printed material
4. Direct mail marketing and form letters;
5. Flyers, handouts and pamphlets;
6. Clothing items, hats, buttons, pens;
7. Information on ADTC’s website;
When in doubt as to whether a promotion is considered advertising officers are directed to
contact the compliance department for assistance. Question regarding this policy should be directed to the Vice President, Marketing Department.
Section 2: Non-Discrimination Policy
ADTC does not and shall not discriminate on the basis of race, color, religion (creed), gender, gender expression, age, national origin (ancestry), disability, marital status, sexual orientation, or military status, in any of its activities or operations. These activities include, but are not limited to, hiring and firing of staff, selection of volunteers and vendors, and provision of services. We are committed to providing an inclusive and welcoming environment for all members of our staff, clients, volunteers, subcontractors, vendors, and clients.
ADTC is an equal opportunity employer. We will not discriminate and will take measures to ensure against discrimination in employment, recruitment, advertisements for employment, compensation, termination, upgrading, promotions, and other conditions of employment against any employee or job applicant on the bases of race, color, gender, national origin, age, religion, creed, disability, veteran's status, sexual orientation, gender identity or gender expression.
Section 3: Tuition Refund Policy
If the student is not accepted into the training program, all monies paid by the student shall be
refunded. Refunds for books, supplies and consumable fees shall be made in accordance with
the following provisions
(1) A student who withdraws before the first class and after the 5-day cancellation period
shall be obligated for the registration fee.
(2) A student who starts class and withdraws before the academic term is 15% completed
will be obligated for 25% of the tuition and refundable fees plus the registration fee.
(3) A student who starts class and withdraws after the academic term is 15% completed but
before the academic term is 25% completed will be obligated for 50% of the tuition and
refundable fees plus the registration fee.
(4) A student who starts class and withdraws after the academic term is 25% completed but
before the academic term is 40% completed will be obligated for 75% of the tuition and
refundable fees plus the registration fee.
(5) A student who starts class and withdraws after the academic term is 40% completed will
not be entitled to a refund of the tuition and fees.
The School shall make the appropriate refund within thirty (30) days of the date the School is
able to determine that a student has withdrawn or has been terminated from a program.
Refunds shall be based upon the last date of a student’s attendance or participation in an
academic School activity.
Section 4: Complaints and Grievances Policy
All student complaints should be first directed to the School personnel involved. If no resolution
is forthcoming, a written complaint shall be submitted to the Administrator of the School.
Students may submit a completed complaint form and supplemental documentation to the
Commission after they have completed the institution’s grievance policy and remain dissatisfied
with the results.
Section 5: Student Privacy and Student Information Security Policy
PERSONAL INFORMATION WE COLLECT
“Personal Information,” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, to any individual or household. It does not include anonymous or aggregated data that cannot be associated with an individual or household.
We may collect, use, store and transfer different kinds of Personal Information about you, which we have grouped together as follows:
Identifiers such as first name, maiden name, last name, alias, username or similar unique personal identifier, student ID, account name, online identifier, social security number, driver’s license number, your state identification card number, military ID or other government identification card, criminal background status, physical characteristics or description, marital status, disability status, date of birth, place of birth, race, ethnicity, religion, gender, or country of origin.
Contact Information such as physical address, mailing address, email address, and telephone numbers.
Educational Information such as educational records that contain information directly related to a student, like your enrollment status, grades, attendance, and high school graduation information and which are maintained by an educational institution or agency or party acting for the institution or agency.
Financial Information such as student financial aid information, payment history, tax information, bank account and routing numbers, credit or debit card information, student account number, tuition totals, and payment details.
Health Information such as height, weight, drug testing, and immunization history.
Commercial Information such as details about payments to and from you, other details of products and services you have purchased from us, or purchasing or consuming tendencies or histories.
Student Housing Information such as residence information, move-in date, and housing costs.
Professional or Employment-Related Information such as your employment status, employer’s information, employment start and end dates, salary, job title and duties, education, training, prior work experience, references, certification, licensure, or other professional information, military affiliation and status, and post-graduation employment and earnings information.
Motor Vehicle Information such as driving history and records, make, model, and year of your vehicle, and license plate number.
Audio, Electronic, and Visual Information such as call and video recordings and photos.
Technical Information includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Services.
Usage Data includes information about how you use our Services.
Marketing and Communications Information such as marketing campaign data, click throughs, your preferences and consent in receiving marketing from us and our third parties, your communication preferences and other preferences and interests.
We may also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your Personal Information, but is not considered Personal Information as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Information so that it can directly or indirectly identify you, we treat the combined data as Personal Information which will be used in accordance with this privacy notice.
Children’s Privacy. The Services are intended for adult use only and is not directed towards children, minors, or anyone under the age of 16. If you are under the age of 13, you are not authorized to provide us with any Personal Information. If the parent or guardian of a child under 13 believes that the child has provided us with any Personal Information, the parent or guardian of that child should contact us at the email address below and ask to have this Personal Information deleted from our files.
HOW WE COLLECT YOUR PERSONAL INFORMATION
We may collect Personal Information from a variety of sources and methods. This includes:
Information You Voluntarily Provide to Us
You may give us your Personal Information by filling in forms, enrolling in one of our educational programs, or by corresponding with us by post, phone, text, email, or otherwise. This includes Personal Information you provide when you:
Submit a request for information form
Submit a contact us form
Use the chat feature on our website
Call, email, or text us
Apply to enroll and/or enroll in one of our educational programs
Request a student ID
Register for classes
Apply for financial aid
Create a student account
Enroll in a training program with one of our partners
Order or purchase educational or other products and services
Attend our courses, programs or other events where we collect information about you
Submit a review or student testimonial
Use one of our career or student resources
Use one of our online learning management, student portal, or other interactive tools
Information We Collect When You Use Our Services:
Automated technologies or interactions. As is true of most websites, we receive and store certain types of Personal Information whenever you interact with us online. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. When you access and use our Services from your mobile devices, we receive data from that mobile device. This may include your device ID, location data, IP address and device type. You may manage how your mobile device and mobile browser share location information with us, as well as how your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings.
Information We Collect From Third Parties
We collect Personal Information from various third parties, including those listed below. The collection, use, and disclosure of Personal Information received from third parties is governed by the privacy policies listed on the website where the information was submitted by the user. Third parties may send their own cookies and pixel tags to you, and may collect information and use it in a way inconsistent with this Policy. Please carefully review these third-party privacy policies to understand how your information may be collected, used and disclosed by these third parties.
Third Party Service Providers. We collect Personal Information from service providers, including online application submission and management platforms, student information platforms, learning management platforms, background and credit check providers, employment verification providers, housing providers, payment processors, email platforms, call centers, and social media platforms.
Third Party Advertising Partners. We collect Personal Information received from third party advertising partners, including partners who host and manage various advertisements and online forms where you can request additional information.
Google Analytics. We use third-party cookies provided by Google Analytics to assist us in better understanding our website visitors. These cookies collect IP address and usage data, such as the length of time a user spends on a page, the pages a user visits, and the websites a user visits before and after visiting our website. Based on this information, Google Analytics compiles data about website traffic and interactions, which we use to offer better user experiences and tools in the future.
For more information on Google Analytics, visit https://support.google.com/analytics.
Third Party Cookies. We may engage third party service providers, including Google, Facebook, and Instagram, to serve ads to you about our products and services as you browse the Internet. These third party providers may use their own cookies to track your online activities and purchases in order to deliver targeted advertising based on your interests.
You can learn more about Google’s advertising cookies and opt-out options by visiting http://www.google.com/policies/technologies/types/.
You can learn more about Facebook’s advertising cookies and opt-out options by visiting https://www.facebook.com/policy/cookies/.
You can learn about Instagram’s advertising cookies and opt-out options by visiting https://help.instagram.com/1896641480634370?ref=ig.
Your ‘Do Not Track’ Browser Setting. Some web browsers incorporate a “Do Not Track” feature (DNT) that signals to the websites that you visit that you do not want to have your online activity tracked. Many websites and applications, including the Services, do not currently respond to web browser DNT signals because such signals are not yet uniform. For more information about DNT signals, please visit http://allaboutdnt.com. Other third party websites may keep track of your browsing activities when they provide you with content, which enables them to customize what they present to you on their websites.
HOW WE USE YOUR PERSONAL INFORMATION
Our primary purpose for collecting Personal Information is to provide you with products and services you request. We may also use your Personal Information for the following business purposes:
To determine your admissibility for your selected educational program
To process your application and enroll you in an education program
To verify your educational background during the enrollment process
To determine your eligibility for financial aid, scholarships, and grants
To provide career services assistance
To provide you with information, products and/or services you request
To facilitate recruitment efforts
To facilitate the creation of and secure any student accounts
To communicate with individuals in written, electronic, and verbal form
To analyze academic and learning outcomes and preferences
To develop new tools, software applications, products and services
To obtain payment for services that we provide to you, including, but not limited to, financial aid
To conduct background checks where required
For internal marketing purposes, which include, but are not limited to, sending you material about products, services, updates, etc. that we think may be of interest to you
To customize the advertising and content you see
To maintain students records and transcripts
For internal business purposes such as complying with our internal policies, conducting audits, or improving our Services
To analyze how our Services are being accessed and used
To verify information
To protect our interests, including establishing, exercising and defending legal rights and claims
As necessary to comply with legal or accreditation requirements, to enforce the terms of our Enrollment Agreement and Code of Conduct, to prevent fraud, to co-operate with law enforcement and regulatory authorities, and to stop other prohibited, illegal, or harmful activities
For purposes disclosed at the time you provide your information or as otherwise set forth in this Policy
HOW WE SHARE PERSONAL INFORMATION WITH THIRD PARTIES
We endeavor to incorporate safeguards to help protect and secure your Personal Information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Therefore, we cannot guarantee its absolute security. It may be possible for third parties to intercept or access transmissions or private communications unlawfully. Any such transmission is done at your own risk.
CALIFORNIA PRIVACY RIGHTS
California Consumer Privacy Act. The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Upon verification of your identity you may:
No more than twice in any 12-month period, request disclosure of the following information:
Categories of Personal Information we collect.
Categories of sources from which Personal Information is collected.
Categories of Personal Information sold or disclosed to third parties.
Categories of third parties with whom such Personal Information is sold or disclosed.
Business or commercial purpose for collecting or selling Personal Information.
Specific pieces of Personal Information we collect.
Request deletion of your Personal Information, subject to the exceptions provided by law.
Opt out from having your Personal Information sold to third parties, if applicable.
Please note that these rights apply only to select California consumers and exclude job applicants, employees, and business contacts. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
The verifiable consumer request must:
Include your full legal name, phone number, and email address, which we will need to contact you in order to verify that you are the person about whom we collected Personal Information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. If you submit a verifiable consumer request, one of our representatives will contact you with further instructions on how to verify your identity.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal or accreditation obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.
The CCPA provides the right to be free from discrimination if you choose to exercise your rights under the statute, and ADTC will not discriminate by:
Denying you goods or services.
Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Providing you a different level or quality of goods or services.
Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Other California Privacy Rights. California Civil Code Section 1798.83 permits California residents who have provided personally identifiable information to us or our third-party advertisers and marketing partners, if any, to request certain information regarding our disclosure of personally identifiable information to third parties for direct marketing purposes.
ADTC may modify or update this Policy from time to time. We encourage you to revisit this page often to remain fully informed of our Policy or you can contact us at any time to obtain the latest copy of this Policy.
QUESTIONS ABOUT THIS POLICY
For questions or comments regarding our Policy, please contact us at firstname.lastname@example.org
If you become a student, your educational records are subject to the U.S. federal Family Educational Rights and Privacy Act (FERPA), state laws and your School policies. To obtain a copy of the Students' Rights to Privacy and Access to Educational Records policy, click here.
If you do not wish to receive marketing email communications or direct mail communications from us, you may express your choice where indicated on the applicable email or other communication, or unsubscribe.
READ BELOW FOR OUR INFORMATION SECURITY POLICY
Information Security Policy.
1. Network Security.
2. Acceptable Use Policy.
3. Protect Stored Data.
4. Information Classification.
5. Access to the Sensitive Cardholder Data.
6. Physical Security.
7. Protect Data in Transit
8. Disposal of Stored Data.
9. Security Awareness and Procedures
10. Credit Card (PCI) Security Incident Response Plan.
11. Transfer of Sensitive Information Policy.
12. User Access Management
13. Access Control Policy.
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 fully understand this policy. 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 re-distributed to all employees and contractors where applicable.
Information Security Policy
The Company handles sensitive cardholder information daily. Sensitive Information must have adequate safeguards in place to protect the cardholder data, cardholder privacy, and to ensure compliance with various regulations, along with guarding the future of the organisation.
The Company commits to respecting the privacy of all its customers and to protecting any customer data 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 handling sensitive cardholder data should ensure:
Handle Company and cardholder information in a manner that fits with their sensitivity and classification;
Limit personal use of the Company information and telecommunication systems and ensure it doesn’t interfere with your job performance;
The Company reserves the right to monitor, access, review, audit, copy, store, or delete any electronic communications, equipment, systems and network traffic for any purpose;
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;
Do not disclose personnel information unless authorised;
Protect sensitive cardholder information;
Keep passwords and accounts secure;
Request approval from management prior to establishing any new software or hardware, third party connections, etc.;
Do not install unauthorised software or hardware, including modems and wireless access unless you have explicit management approval;
Always leave desks clear of sensitive cardholder data and lock computer screens when unattended;
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.
A high-level network diagram of the network is maintained and reviewed on a yearly basis. The network diagram provides a high level overview of the cardholder data environment (CDE), which at a minimum shows the connections in and out of the CDE. Critical system components within the CDE, such as POS devices, databases, web servers, etc., and any other necessary payment components, as applicable should also be illustrated.
In addition, ASV should be performed and completed by a PCI SSC Approved Scanning Vendor, where applicable. Evidence of these scans should be maintained for a period of 18 months.
2.Acceptable Use Policy
Management’s intentions for publishing an Acceptable Use Policy are not to impose restrictions that are contrary to the Company’s established culture of openness, trust and integrity. Management is committed to protecting the employees, partners and the Company from illegal or damaging actions, either knowingly or unknowingly by individuals. The Company 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 take all necessary steps to prevent unauthorized access to confidential data which includes card holder data.
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.
The List of Devices in Appendix B will be regularly updated when devices are modified, added or decommissioned. A stocktake of devices will be regularly performed and devices inspected to identify any potential tampering or substitution of devices.
Users should be trained in the ability to identify any suspicious behaviour where any tampering or substitution may be performed. Any suspicious behaviour will be reported accordingly.
Information contained on portable computers is especially vulnerable, special 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 the Company, 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.
3.Protect Stored Data
All sensitive cardholder data stored and handled by the Company and its employees must be securely protected against unauthorised use at all times. Any sensitive card data that is no longer required by the Company for business reasons must be discarded in a secure and irrecoverable manner.
If there is no specific need to see the full PAN (Permanent Account Number), it has to 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 chats, ICQ messenger etc.,
It is strictly prohibited to store:
The contents of the payment card magnetic stripe (track data) on any media whatsoever.
The CVV/CVC (the 3 or 4 digit number on the signature panel on the reverse of the payment card) on any media whatsoever.
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 the Company if disclosed or modified. Confidential data includes 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.
5.Access to the Sensitive Cardholder Data
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 to the first 6 and the last 4 digits of the cardholder data.
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 Service Provider (3rd party) then a list of such Service Providers will be maintained as detailed in Appendix C.
The Company will ensure a written agreement that includes an acknowledgement is in place that the Service Provider will be responsible for the for the cardholder data that the Service Provider possess.
The Company will ensure that a there is an established process, including proper due diligence is in place, before engaging with a Service provider.
The Company will have a process in place to monitor the PCI DSS compliance status of the Service provider.
Access to sensitive information in both hard and soft media format must be physically restricted to prevent unauthorised individuals from obtaining sensitive data.
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 handled 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 Company sites. A “visitor” is defined as a vendor, guest of an employee, service personnel, or anyone who needs to physically enter the premises for a short duration, usually not more than one day.
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 surfaces are periodically inspected to detect tampering or substitution.
Personnel using the devices should be trained and aware of handling the POS devices
Personnel using the devices should verify the identity of and=y 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. The Company 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.
Strict control is maintained over the external or internal distribution of any media containing card holder data and has to be approved by management
Strict control is maintained over the storage and accessibility of media
All computer that store sensitive cardholder data must have a password protected screensaver enabled to prevent unauthorised use.
7.Protect Data in Transit
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 by any other mode then it should be done after authorization and by using a strong encryption mechanism (i.e. – AES encryption, PGP encryption, IPSEC, 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.
8.Disposal of Stored Data
All data must be securely disposed of when no longer required by the Company, regardless of the media or application type on which it is stored.
An automatic process must exist to permanently delete on-line data, when no longer required.
All hard copies of cardholder data must be manually destroyed when no longer required for valid and justified business reasons. A quarterly process must be in place to confirm that all non-electronic cardholder data has been appropriately disposed of in a timely manner.
The Company will have procedures for the destruction of hardcopy (paper) materials. These will require that all hardcopy materials are crosscut shredded, incinerated or pulped so they cannot be reconstructed.
The Company will have documented procedures for the destruction of electronic media. These will require:
All cardholder data on electronic media must be rendered unrecoverable when deleted e.g. through degaussing or electronically wiped using military grade secure deletion processes or the physical destruction of the media;
If secure wipe programs are used, the process must define the industry accepted standards followed for secure deletion.
All cardholder information awaiting destruction must be held in lockable storage containers clearly marked “To Be Shredded” - access to these containers must be restricted.
9.Security Awareness and Procedures
The policies and procedures outlined below must be incorporated into company practice to maintain a high 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 handle 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.
10.Credit Card (PCI) Security Incident Response Plan
The Company PCI Security Incident Response Team (PCI Response Team) is comprised of the Information Security Officer and Merchant Services. The Company PCI security incident response plan is as follows:
Each department must report an incident to the Information Security Officer (preferably) or to another member of the PCI Response Team.
That member of the team receiving the report will advise the PCI Response Team of the incident.
The PCI Response Team will investigate the incident and assist the potentially compromised department in limiting the exposure of cardholder data and in mitigating the risks associated with the incident.
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.
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.
Information Security PCI Incident Response Procedures:
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 the Company 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.
Incident Response Notification
Escalation Members (or equivalent in your company):
Escalation – First Level:
Information Security Officer Controller
Executive Project Director for Credit Collections and Merchant Services Legal Counsel
Director of the Company Communications
Escalation – Second Level:
The Company President
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
External Response Team as applicable (CERT Coordination Center 1, etc) Law Enforcement Agencies as applicable inn local jurisdiction
In response to a systems compromise, the PCI Response Team and designees will:
Ensure compromised system/s is isolated on/from the network.
Gather, review and analyze the logs and related information from various central and local safeguards and security controls
Conduct appropriate forensic analysis of compromised system.
Contact internal and external departments and entities as appropriate.
Make forensic and log analysis available to appropriate law enforcement or card industry security personnel, as required.
Assist law enforcement and card industry security personnel in investigative processes, including in prosecutions.
The credit card companies have individually specific requirements that the Response Team must address in reporting suspected or confirmed breaches of cardholder data. See below for these requirements.
Incident Response notifications to various card schemes
In the event of a suspected security breach, alert the information security officer or your line manager immediately.
The security officer will carry out an initial investigation of the suspected security breach.
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.
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”*.
Include overview of the incident
Include RISK Level(High, Medium, Low)
Determine if compromise has been contained
Include forensic tools used during investigation
Number of accounts at risk, identify those stores and compromised
Type of account information at risk
Identify ALL systems analyzed. Include the following:
Domain Name System (DNS) names
Internet Protocol (IP) addresses
Operating System (OS) version
Function of system(s)
Identify ALL compromised systems. Include the following:
Function of System(s)
Timeframe of compromise
Any data exported by intruder
Establish how and source of compromise
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.)
If applicable, review VisaNet endpoint security and determine risk
Compromised Entity Action
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.
Within 24 hours of an account compromise event, notify the MasterCard Compromised Account Team via phone at 1-636-722-4100.
Provide a detailed written statement of fact about the account compromise (including the contributing circumstances) via secured e-mail to email@example.com.
Provide the MasterCard Merchant Fraud Control Department with a complete list of all known compromised account numbers.
Within 72 hours of knowledge of a suspected account compromise, engage the services of a data security firm acceptable to MasterCard to assess the vulnerability of the compromised data and related systems (such as a detailed forensics evaluation).
Provide weekly written status reports to MasterCard, addressing open questions and issues until the audit is complete to the satisfaction of MasterCard.
Promptly furnish updated lists of potential or known compromised account numbers, additional documentation, and other information that MasterCard may request.
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:
Identify the issuers of the accounts that were suspected to have been compromised and group all known accounts under the respective parent member IDs.
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
Within 24 hours of an account compromise event, notify Discover Fraud Prevention at (800) 347-3102
Prepare a detailed written statement of fact about the account compromise including the contributing circumstances
Prepare a list of all known compromised account numbers
Obtain additional specific requirements from Discover Card
American Express Steps
Within 24 hours of an account compromise event, notify American Express Merchant Services at (800) 528-5200 in the U.S.
Prepare a detailed written statement of fact about the account compromise including the contributing circumstances
Prepare a list of all known compromised account numbers Obtain additional specific requirements from American Express
11.Transfer of Sensitive Information Policy
All third-party companies providing critical services to the Company 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 have access to Card Holder information must
Adhere to the PCI DSS security requirements.
Acknowledge their responsibility for securing the Card Holder data.
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.
Have appropriate provisions for business continuity in the event of a major disruption, disaster or failure.
Provide full cooperation and access to conduct a thorough security review after a security intrusion by a Payment Card industry representative, or a Payment Card industry approved third party.
12.User Access Management
Access to Company 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 carried out.
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;
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 the Company 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.
13.Access Control Policy
Access Control systems are in place to protect the interests of all users of the Company computer systems by providing a safe, secure and readily accessible environment in which to work.
The Company will provide all employees and other users with the information they need to carry out their responsibilities in an 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 Company 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 the Company 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 the Company 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.