Hotel groups unite to reduce PCI scope

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12 October 2011
By Stephanie Wharton
Reporter
swharton@hotelnewsnow.com

Story Highlights
  • At least 16 hotel groups have expressed interest in developing an industry-wide solution, and are working with Hotel Technology Next Generation to create a credit-card security framework.
  • The solution HTNG would like to have the industry implement would get hotels completely out of scope of the PCI.
  • “This is about security issues. Once you begin to take care of these security issues, compliance comes as a byproduct,” said Bob Russo, general manager at the PCI Standards Council.

REPORT FROM THE U.S.—In an industry where credit-card data flows across various companies’ systems and is often stored for weeks or months at a time, simply complying with PCI standards might not be enough for hotels to keep sensitive data out of the hands of thieves.

At least 16 hotel groups have expressed interest in developing an industry-wide solution, and are working with Hotel Technology Next Generation to create a credit-card security framework. Accor, Hilton Worldwide, Mandarin Oriental Hotel Group and Starwood Hotels & Resorts Worldwide are among the 16 groups listed in a HTNG news release that have confirmed their intent to participate.

Doug Rice, CEO of HTNG, said the non-profit organization initiated the process for the industry security framework last June. So far a charter has been created to ensure the hotels and organizations involved are on the same page. The group’s first meeting will take place in November. 

The solution HTNG would like to have the industry implement would get hotels' systems completely out of scope of the PCI. “If your systems do not touch a credit card, it means those systems are out of scope,” Rice said. 

The main option the group is exploring is tokenization. This method involves taking credit-card data and replacing it with a “token,” which could be any number or phrase that would be worthless to a potential thief. To completely get out of the PCI scope with tokenization, a third-party company would be required to store the credit-card data while the hotel holds on to the token. Once the hotel is ready to charge the customer’s card, they send the token to the third-party company to handle the payment, and the hotel avoids storing any credit-card data throughout the process.

David Wallace, general manager of data security at Chase Paymentech, said this solution of pairing tokenization with a third-party payment website will eliminate the merchant’s PCI scope from the e-commerce side, but a solution needs to be addressed for the guests who do not reserve their accommodations with a credit card online.

In this case, where an actual credit-card swipe is required at the property, Wallace said coupling tokenization with point-to-point encryption is the ideal solution. This encrypts the data when the credit card is swiped. However, in order for point-to-point encryption to remain out of the PCI scope, the card data decryption must not occur in the hotel and the functionality to decrypt the data must not exist in the hotel.

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Security first
Bob Russo, general manager at the PCI Standards Council, said the organization is in favor of a credit-card security framework for the hotel industry because of the high volume of transactions that are stored. He said there are many people who look for the easy way out, and comply with PCI standards simply because it’s the law.

“This is about security issues. Once you begin to take care of these security issues, compliance comes as a byproduct,” Russo said.

He wants the industry to keep in mind that security isn’t all about technology: “It’s about people, and the processes they go through.”

Once HTNG and the hotel groups working with the organization develop the security framework, the next step on the list will be to implement the plan across the industry.

Rice said everyone involved in accepting payments in the hotel industry needs to agree on the same framework for it to work effectively. Online travel agencies, distribution partners and payment processors will all need to be on board. The plan is for the major hotel companies to inform their partners of the plan at approximately the same time. Vendors will realize this is what they need to do if they want to meet the needs of the hotel industry, he said.

“That’s the key. There has to be cross-company trust,” Rice said.

Once the partners are on board with the solution, independent hotels will start getting involved, too.

Rice said education will not necessarily be the role of HTNG. However, the group expects to work with organizations such as the Hospitality Financial and Technology Professionals to help implement the solution and spread the word in the industry. 

“This is not going to be an overnight solution, it’s a journey, but it’s something that the industry has recognized needs to be addressed,” Rice said.

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3 Comments
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10 November 2011 at 5:36 PM EST
In response to: Hotel groups unite to reduce PCI scope
M. Ariel Evans commented:
The statement: The solution HTNG would like to have the industry implement would get hotels' systems completely out of scope of the PCI: is not possible since PCI requires testing of technology in context. “If your systems do not touch a credit card, it means those systems are out of scope,” is not accurate. Furthermore, in the states of WA, MA, NV, and MN, PCI is the state law regardless if it is card data. If you do business with the state you must be following PCI. Furthermore, tokenization is no guaruntee of descoping. PCI says you must test, the auditor must say it's out of scope, not the hotel group. Mr. Russo is well intended but not a technology expert and furthermore, he represents the brands not the consumer.

16 October 2011 at 2:45 PM EST
In response to: Hotel groups unite to reduce PCI scope
Mark Bower, Voltage Security commented:
@ Former QSA - Suggest you read the P2PE Guidance and the P2PE Initial Requirements document published by the PCI SSC this year - especially the appendix which explicitly outlines which elements of a payment stream which can be taken out of scope if there is no ability to decrypt nor have access to keys. Since there is no access to data nor keys except a) in the PED - a Secure Cryptographic Device and b) at the acquirer where decryption takes place, the merchant and its systems never have access to readable data. Encryption techniques like correctly implemented AES are impossible to break in any feasible way (billions and billions of years to brute force with all the computing power available on the planet). Without the key, the data is unreadable. The P2PE guidance covers aspects of key management and correct implementation at the endpoints to empower merchants implementing P2PE with the ability to de-scope. For other scenarios, its up to the QSA to decide - but trying to simply state that everything is in scope is inaccurate and not in line with the current guidance already published - and ultimately not the merchants or acquirers best interest.

13 October 2011 at 11:41 AM EST
In response to: Hotel groups unite to reduce PCI scope
former QSA commented:
All systems that store, process, or transmit credit card data are in scope whether the data is incrypted or not. POS and point-to-point encryption would remain in scope...



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