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Privacy Policy

Privacy Policy GoSmooth

https://www.go-smooth.com

About our Privacy Policy

GoSmooth cares a lot about your privacy. We therefore only process data that we need for (improving) our services and we handle the information we have collected about you and your use of our services. We never make your data available to third parties for commercial purposes.

This privacy policy applies to the use of the website and the services provided by GoSmooth. The starting date for the validity of these conditions is 20/07/2018, with the publication of a new version the validity of all previous versions expires. This Privacy Policy describes what information about you is collected by us, where this data is used for and with whom and under what conditions this data can possibly be shared with third parties. We also explain to you how we store your data and how we protect your data against misuse and what rights you have with regard to the personal data you provide us.

If you have any questions about our privacy policy, please contact our contact person for privacy matters, you will find the contact details at the end of our privacy policy.

About our data processing

Underneath you can read how we process your data, where we save it, what security techniques we use and for whom the data are transparent.

Webshopsoftware

WooCommerce

Our webshop was developed with software from Shopify, we have opted for TransIP for our web hosting. Personal data that you make available to us for the benefit of our services will be shared with this party. TransIP has access to your data to provide us (technical) support, they will never use your data for any other purpose. TransIP is obliged to take appropriate security measures on the basis of the agreement we have concluded with them. These security measures consist of the application of SSL encryption and a strong password policy. Backups are regularly made to prevent data loss.

Webhosting

TransIP

We accept web hosting and e-mail services from TransIP. TransIP processes personal data on our behalf and does not use your data for its own purposes. However, this party can collect metadata about the use of the services. These are not personal data. TransIP has taken appropriate technical and organizational measures to prevent loss and unauthorized use of your personal data. TransIP is obliged to observe secrecy on the grounds of the confidentiality agreement.

E-mail & Mailing lists

Gmail

We use the services of Gmail for our regular business e-mail traffic. This party has taken appropriate technical and organizational measures to prevent abuse, loss and corruption of your and our data as much as possible. Gmail does not have access to our mailbox and we treat all our e-mail traffic confidentially.

Payment processors

Mollie

We use the Mollie platform to handle a (part of) the payments in our webshop. Mollie processes your name, address and residence details and your payment details such as your bank account or credit card number. Mollie has taken appropriate technical and organizational measures to protect your personal data. Mollie reserves the right to use your data to further improve the service and to share (anonymised) data with third parties. All the above-mentioned safeguards with regard to the protection of your personal data also apply to the parts of Mollie’s services for which they engage third parties. Mollie does not store your data for longer than is permitted by the legal terms.

Klarna

In cooperation with Klarna Bank AB (publ), Sveavägen 46, 111 34 Stockholm, Sweden, we offer you the following payment methods. Payment is to be made to Klarna.

  • Pay in [14] days: The payment period is 14 days from shipment of the goods or tickets/ availability date of the service. You can find the complete terms and conditions for the markets where this payment method is available here: United KingdomGermanySwedenNorwayDenmarkFinlandAustria and the Netherlands.
  • Slice it: With the financing service from Klarna you can pay your purchase in flexible or fixed monthly instalments according to the conditions stated in the checkout. The instalment payment is due at the end of each month after submission of a separate monthly invoice by Klarna. Further information regarding Slice It including terms and conditions and Standard European Consumer Credit Information you can find here for the markets where this payment method is available: Austria, the United KingdomGermanySwedenNorwayDenmark and Finland.
  • Direct banking: Available in Germany, Austria and the Netherlands. Your account will be debited directly after placement of your order.
  • Direct Debit: Available in Germany, Sweden, Austria and the Netherlands. Your account will be debited after shipment of the goods or tickets/ availability date of the service ​or in case of a subscription in accordance with the timelines communicate​d. You will be notified about the date(s) by email.
  • Card Payments: Available in Germany. The amount will be reserved on your card and will be debited after shipment of the goods or tickets/ availability date of the service. In case of a subscription the amount will be debited in accordance with the timelines communicate​d.

The payment methods Pay in [14] days, Slice It and direct debit are only available in case of a positive credit assessment. For this purpose, during the order process and handling of your purchase, we forward your data for an address and credit check to Klarna. We can only offer you the payment methods available based on the result of the credit check. General information about Klarna and the user terms per country can be found on klarna.com. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarnas privacy statement.

Reviews

Yotpo

We collect reviews via the Yotpo platform. If you leave a review via Yotpo you are obliged to enter your name, place of residence and e-mail address. Yotpo will share this information with us so that we can link the review to your order. Yotpo also publishes your name and place of residence on your own website. In some cases Yotpo may contact you to provide an explanation of your review. In the event that we invite you to leave a review, we will share your name and e-mail address with Yotpo. They only use this information for the purpose of inviting you to leave a review. Yotpo has taken appropriate technical and organizational measures to protect your personal data. Yotpo reserves the right to engage third parties for the provision of services, for this we have given permission to Yotpo. All the above-mentioned safeguards with regard to the protection of your personal data also apply to the parts of the service for which Yotpo engages third parties.

Shipping & logistics

UPS

If you place an order with us, it is our job to have your package delivered to you. We use the services of UPS for the execution of the deliveries. It is therefore necessary that we share your name, address and residence details with UPS. UPS uses this information only for the purpose of executing the agreement. In the event UPS engages subcontractors, UPS will also make your data available to these parties.

Invoicing & accounting

Manager.io

For our records of our administration and accounting, we use the services of Manager.io. We share your name, address and residence details and details regarding your order. This data is used for managing sales invoices. For our records of our administration and accounting, we use the services of Manager.io. We share your name, address and residence details and details regarding your order. This data is used for managing sales invoices. Your personal data is sent and stored protected.

Manager.io is obliged to maintain confidentiality and will treat your information confidentially. Manager.io does not use your personal data for purposes other than those described above.

Purpose of the data processing

General purpose of the data processing

We only use your data for the benefit of our services. This means that the purpose of the processing is always directly related to the assignment you provide. We do not use your information

(focused) marketing. If you share information with us and we use this information to contact you at a later time, other than at your request, we will ask you for explicit permission. Your information will not be shared with third parties, other than to comply with accounting and other administrative obligations.

These third parties have all been kept confidential on the basis of the agreement between them and us or an oath or legal obligation.

Automatically collected data

Data that is automatically collected by our website is processed with the aim of further improving our services. This information (eg your IP address, web browser and operating system) is not personal data.

Participation in tax and criminal investigation

Where appropriate, GoSmooth can be held on the basis of a legal obligation to share your data in connection with government tax or criminal investigations. In such a case, we are forced to share your data, but we will oppose this within the possibilities that the law offers us.

Retention periods

 We keep your information as long as you are our client. This means that we keep your customer profile until you indicate that you no longer wish to use our services. If you indicate this to us, we will also consider this as a request for forgiveness. On the basis of applicable administrative obligations, we are obligated to save invoices with your personal data.

To save (personal) data, we will keep this information for as long as the applicable term is in effect. However, employees no longer have access to your client profile and documents that we have produced in connection with your assignment.

Your rights

On the basis of the applicable Dutch and European legislation, you as a data subject have certain rights with regard to the personal data that are processed by or on behalf of us. We explain below which rights these are and how you can invoke these rights.

In principle, in order to prevent abuse, we will send copies and copies of your data only to your already known e-mail address. In the event that you wish to receive the data at another e-mail address or for example by post, we will ask you to identify yourself. We keep records of completed requests, in the case of a request for forgiveness we administer anonymous data. All copies and copies of data you receive in the machine-readable data format that we use within our systems.

You have the right to file a complaint with the Dutch Data Protection Authority at any time if you suspect that we are using your personal data in the wrong way.

Right of inspection

You always have the right to inspect the data that we process or have processed that relate to your person or that can be traced back to you. You can submit a request to that effect to our privacy contact person. You will receive a response to your request within 30 days. If your request is granted, we will send you a copy of all data with an overview of the processors who have this data, with the e-mail address known to us, stating the category under which we have stored this data.

Rectification right

You always have the right to have the data that we process or have processed that relate to your person or that can be traced back to this. You can submit a request to that effect to our privacy contact person. You will receive a response to your request within 30 days. If your request is granted, we will send you a confirmation that the details have been changed on the e-mail address known to us.

Right to restriction of processing

You always have the right to limit the data that we process or have related to your person or that can be traced back to you. You can submit a request to that effect to our privacy contact person. You will receive a response to your request within 30 days. If your request is granted, we will send you a confirmation to the e-mail address known to us that the data until you cancel the restriction will no longer be processed.

Right of transferability

You always have the right to have the data that we process or have processed and that relate to your person or that can be traced back to you, performed by another party. You can submit a request to that effect to our privacy contact person. You will receive a response to your request within 30 days. If your request is granted, we will send you copies or copies of all information about you that we have processed or that have been processed by us by other processors or third parties on the e-mail address known to us. In all likelihood, we will no longer be able to continue the service in such a case, because the secure linking of data files can then no longer be guaranteed.

Right of objection and other rights

In some cases, you have the right to object to the processing of your personal data by or on behalf of GoSmooth. If you object, we will immediately stop the data processing pending the settlement of your objection. If your objection is well-founded, we will make copies and / or copies of data that we process or have made available to you and then permanently discontinue the processing.

You also have the right not to be subject to automated individual decision making or profiling. We do not process your data in such a way that this right applies. If you are of the opinion that this is the case, please contact our contact person for privacy matters.

Cookies

Google Analytics

Through our website, cookies are placed from the company Google as part of the “Analytics” service. We use this service to track and get reports on how visitors use the website. This processor may be obliged to provide access to these data on the basis of applicable laws and regulations. We collect information about your browsing habits and share this information with Google. Google can interpret this information in conjunction with other datasets and thus track your movements on the internet. Google uses this information to provide, among other things, targeted advertisements (Adwords) and other Google services and products.

Cookies from third parties

In the case software solutions from third parties use cookies, this is stated in this privacy statement.

Changes to the privacy policy

We reserve the right to change our privacy policy at any time. On this page you will always find the most recent version. If the new privacy policy affects the way in which we process already collected data relating to you, we will notify you by e-mail.

Contact details

GoSmooth

Ir. Lelyweg 14H

2031CD, Haarlem

The Netherlands

T +31 (0) 23 8443 776

E info@go-smooth.com

Contact person for privacy matters:

Sil van den Raadt

 

Information Security Policy  

Contents

Introduction. 3

Information Security Policy. 3

  1. Network Security. 4
  2. Acceptable Use Policy. 4
  3. Protect Stored Data. 4
  4. Information Classification. 5
  5. Access to the Sensitive Cardholder Data. 5
  6. Physical Security. 6
  7. Protect Data in Transit 6
  8. Disposal of Stored Data. 7
  9. Security Awareness and Procedures 7
  10. Credit Card (PCI) Security Incident Response Plan. 8
  11. Transfer of Sensitive Information Policy. 12
  12. User Access Management 12
  13. Access Control Policy. 13

 

Introduction

 

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

 

GoSmooth 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.

GoSmooth 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 GoSmooth information and telecommunication systems and ensure it doesn’t interfere with your job performance;
  • GoSmooth 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.

 

1.    Network Security

 

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 GoSmooth’s established culture of openness, trust and integrity. Management is committed to protecting the employees, partners and GoSmooth from illegal or damaging actions, either knowingly or unknowingly by individuals. GoSmooth 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 GoSmooth, 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 GoSmooth and its employees must be securely protected against unauthorised use at all times. Any sensitive card data that is no longer required by GoSmooth 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:

  1. The contents of the payment card magnetic stripe (track data) on any media whatsoever.
  2. The CVV/CVC (the 3 or 4 digit number on the signature panel on the reverse of the payment card) on any media whatsoever.
  3. The PIN or the encrypted PIN Block under any circumstance.

 

4.    Information Classification

 

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 GoSmooth 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.
  • GoSmooth 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.
  • GoSmooth will ensure that a there is an established process, including proper due diligence is in place, before engaging with a Service provider.
  • GoSmooth will have a process in place to monitor the PCI DSS compliance status of the Service provider.

 

6.    Physical Security 

 

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. GoSmooth 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 GoSmooth, 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.
  • GoSmooth 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.
  • GoSmooth 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 GoSmooth.
  • 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

 

  • GoSmooth PCI Security Incident Response Team (PCI Response Team) is comprised of the Information Security Officer and Merchant Services. GoSmooth PCI security incident response plan is as follows:

 

  1. Each department must report an incident to the Information Security Officer (preferably) or to another member of the PCI Response Team.
  2. That member of the team receiving the report will advise the PCI Response Team of the incident.
  3. 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.
  4. The PCI Response Team will resolve the problem to the satisfaction of all parties involved, including reporting the incident and findings to the appropriate parties (credit card associations, credit card processors, etc.) as necessary.
  5. The PCI Response Team will determine if policies and processes need to be updated to avoid a similar incident in the future, and whether additional safeguards are required in the environment where the incident occurred, or for the institution.

 

GoSmooth PCI Security Incident Response Team (or equivalent in your organisation):

 

CIO

 

 

 

Communications Director

 

 

Compliance Officer

 

 

 

Counsel

 

 

 

Information Security Officer

 

 

 

Collections & Merchant Services

 

 

 

Risk Manager

 

 

 

 

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 GoSmooth 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

Risk Manager

 

Director of GoSmooth Communications

Escalation – Second Level:

GoSmooth President

Executive Cabinet

 

Internal Audit

Auxiliary members as needed

 

External Contacts (as needed)

Merchant Provider Card Brands

Internet Service Provider (if applicable)

Internet Service Provider of Intruder (if applicable) Communication Carriers (local and long distance) Business Partners

Insurance Carrier

External Response Team as applicable (CERT Coordination Center 1, etc) Law Enforcement Agencies as applicable inn local jurisdiction

 

In response to a systems compromise, the PCI Response Team and designees will:

 

  1. Ensure compromised system/s is isolated on/from the network.
  2. Gather, review and analyze the logs and related information from various central and local safeguards and security controls
  3. Conduct appropriate forensic analysis of compromised system.
  1. Contact internal and external departments and entities as appropriate.
  2. Make forensic and log analysis available to appropriate law enforcement or card industry security personnel, as required.
  3. 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 

 

  1. In the event of a suspected security breach, alert the information security officer or your line manager immediately.
  2. The security officer will carry out an initial investigation of the suspected security breach.
  3. Upon confirmation that a security breach has occurred, the security officer will alert management and begin informing all relevant parties that may be affected by the compromise.

 

 VISA Steps

 

If the data security compromise involves credit card account numbers, implement the following procedure:

 

  • Shut down any systems or processes involved in the breach to limit the extent, and prevent further exposure.
  • Alert all affected parties and authorities such as the Merchant Bank (your Bank), Visa Fraud Control, and the law enforcement.
  • Provide details of all compromised or potentially compromised card numbers to Visa Fraud Control within 24 hrs.
  • For more Information visit: http://usa.visa.com/business/accepting_visa/ops_risk_management/cisp_if_ compromised.html

 

Visa Incident Report Template

 

This report must be provided to VISA within 14 days after initial report of incident to VISA. The following report content and standards must be followed when completing the incident report. Incident report must be securely distributed to VISA and Merchant Bank. Visa will classify the report as “VISA Secret”*.

  1. Executive Summary

 

  1. Include overview of the incident
  2. Include RISK Level(High, Medium, Low)
  3. Determine if compromise has been contained
  1. Background
  • Initial Analysis
  1. Investigative Procedures

 

  1. Include forensic tools used during investigation
  1. Findings
    1. Number of accounts at risk, identify those stores and compromised

 

  1. Type of account information at risk
  2. Identify ALL systems analyzed. Include the following:

 

  • Domain Name System (DNS) names

 

  • Internet Protocol (IP) addresses

 

  • Operating System (OS) version

 

  • Function of system(s)

 

  1. Identify ALL compromised systems. Include the following:

 

  • DNS names

 

  • IP addresses

 

  • OS version

 

  • Function of System(s)
  1. Timeframe of compromise

 

  1. Any data exported by intruder
  2. Establish how and source of compromise
  3. 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.)
  4. If applicable, review VisaNet endpoint security and determine risk
  1. Compromised Entity Action
  • Recommendations

 

  • Contact(s) at entity and security assessor performing investigation

 

*This classification applies to the most sensitive business information, which is intended for use within VISA. Its unauthorized disclosure could seriously and adversely impact VISA, its employees, member banks, business partners, and/or the Brand.

 

MasterCard Steps:

 

  1. Within 24 hours of an account compromise event, notify the MasterCard Compromised Account Team via phone at 1-636-722-4100.
  2. Provide a detailed written statement of fact about the account compromise (including the contributing circumstances) via secured e-mail to  compromised_account_team@mastercard.com.

 

  1. Provide the MasterCard Merchant Fraud Control Department with a complete list of all known compromised account numbers.
  2. 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).

 

  1. Provide weekly written status reports to MasterCard, addressing open questions and issues until the audit is complete to the satisfaction of MasterCard.
  2. 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:

 

  1. Identify the issuers of the accounts that were suspected to have been compromised and group all known accounts under the respective parent member IDs.

 

  1. Distribute the account number data to its respective issuers.

 

Employees of GoSmooth 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 GoSmooth and contractors. In addition to this, the security officer will oversee the scheduling of security training sessions, monitor and enforce the security policies outlined in both this document and at the training sessions and finally, oversee the implantation of the incident response plan in the event of a sensitive data compromise.

 

Discover Card Steps

 

  1. Within 24 hours of an account compromise event, notify Discover Fraud Prevention at (800) 347-3102
  2. Prepare a detailed written statement of fact about the account compromise including the contributing circumstances
  • Prepare a list of all known compromised account numbers

 

  1. Obtain additional specific requirements from Discover Card

 

American Express Steps

 

  1. Within 24 hours of an account compromise event, notify American Express Merchant Services at (800) 528-5200 in the U.S.
  2. 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 GoSmooth must provide an agreed Service Level Agreement.
  • All third-party companies providing hosting facilities must comply with GoSmooth’s Physical Security and Access Control Policy.
  • All third-party companies which have access to Card Holder information must
  1. Adhere to the PCI DSS security requirements.
  2. Acknowledge their responsibility for securing the Card Holder data.
  3. Acknowledge that the Card Holder data must only be used for assisting the completion of a transaction, supporting a loyalty program, providing a fraud control service or for uses specifically required by law.
  4. Have appropriate provisions for business continuity in the event of a major disruption, disaster or failure.
  5. 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;

Start date;

Services required (default services are: MS Outlook, MS Office and Internet access).

 

  • Each user will be given a copy of their new user form to provide a written statement of their access rights, signed by an IT representative after their induction procedure. The user signs the form indicating that they understand the conditions of access.
  • Access to all GoSmooth systems is provided by IT and can only be started after proper procedures are completed.

 

  • As soon as an individual leaves GoSmooth 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 GoSmooth computer systems by providing a safe, secure and readily accessible environment in which to work.
  • GoSmooth 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 GoSmooth CISO.
  • Access to GoSmooth IT resources and services will be given through the provision of a unique Active Directory account and complex password.
  • No access to any GoSmooth IT resources and services will be provided without prior authentication and authorization of a user’s GoSmooth 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 GoSmooth 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.