Project: Addressing a New Business’s Compliance Responsibilities
Project: Addressing a New Business’s Compliance Responsibilities
Purpose
This project provides an opportunity for you to apply principles related to auditing to ensure information systems are in compliance with pertinent laws and regulations, as well as industry requirements.
Required Source Information and Tools
Web References: Links to Web references are subject to change without prior notice. These links were last verified on July 1, 2015.
To complete the project, you will need the following:
1. Course textbook
2. Access to the Internet to perform research for the project
ü PCI Security Standards Council: https://www.pcisecuritystandards.org
ü COSO Internal Control—Integrated Framework Executive Summary (2013): http://www.coso.org/documents/990025P_Executive_Summary_final_may20_e.p df
ü COSO Internal Control—Integrated Framework PowerPoint (2013): http://www.coso.org/documents/COSOOutreachDeckMay2013.pptx
ü COSO Internal Control—Integrated Framework (2013) whitepaper: http://www.kpmg.com/Ca/en/External%20Documents/Final-New-COSO- 2013Framework-WHITEPAPER-web.pdf
Learning Objectives and Outcomes
You will be able to:
· Explain the purpose of PCI DSS
· Analyze business factors that influence PCI DSS compliance
· Describe potential consequences of failing to demonstrate PCI DSS compliance
· Apply standards and frameworks to the development of information security internal control systems Analyze the use of information security controls within IT infrastructure domains
Introduction
Public and private sector companies are expected to comply with many laws and regulations as well as industry requirements to promote information security. Assessments and audits of the information technology (IT) environment help to ensure a company is in compliance. A successful information security professional must be able to assess a business’s needs, evaluate various standards and frameworks, and develop a customized, integrated internal control system that addresses the company’s compliance responsibilities. Furthermore, the professional must be able to communicate with various people—both inside and outside the organization—to facilitate awareness of how control activities mitigate weaknesses or potential losses that could compromise the company’s information security.
Deliverables
The project is divided into three parts. Details for each deliverable can be found in this document. Refer to the course syllabus for submission dates.
· Project Part 1: PCI DSS Compliance Requirements
· Project Part 2: Design of an Integrated Internal Control System
· Project Part 3: Compliance within IT Infrastructure Domains
Project Part 1: PCI DSS Compliance Requirements
Scenario
S&H Aquariums is a new online retailer that is about to begin selling aquariums and other items for aquarium hobbyists. In recent months, many companies have been featured in the news because of information security breaches that have exposed customers’ credit card data. S&H Aquariums’ management team is worried about the negative impact a potential breach could have on the company’s reputation and business standing.
S&H Aquariums has hired you, an information systems security expert, to ensure that the company is prepared to accept credit card payments for purchases made through the company’s Web site. To kick off the planning phase, the board of directors would like you to write a report explaining what the company will need to do to minimize risks to sensitive data and comply with applicable laws and regulations, as well as industry standards. In preparation, you sit down with the company’s president and discuss the following details:
· Per the company’s strategic plan, the company expects to have between 20,000 and 1,000,000 credit card transactions during the first year of operations. However, the board would like to know what differences to anticipate as the volume of credit card transactions grows in the coming years.
· The company will initially accept payments made with MasterCard and Visa only, but it may decide to accept other credit cards in the future.
· The board of directors is discussing the possibility of opening a bricks-and-mortar store in the future, and the board would like to consider any compliance-related issues prior to making that decision.
· The board consists of professionals from a variety of fields. It is unlikely that any of the board members are familiar with complex information security concepts or with PCI DSS, the set of requirements that prescribes operational and technical controls to protect cardholder data.
Tasks
· Review the information related to PCI DSS compliance provided in the course textbook and in the Internet resources listed for this project. Consider how this information relates to the description of S&H Aquariums provided in the scenario above.
· Write a report for S&H Aquariums’ board of directors. Include the following:
o Introduction
o PCI DSS Overview
§ Include a discussion of the six principles, twelve primary requirements, and the sub-requirements of PCI DSS.
o Rationale
§ Explain why the company needs to address the PCI DSS requirements and describe potential consequences if the company is not able to demonstrate compliance.
o Immediate Considerations for PCI DSS Compliance
§ Analyze factors (including those introduced in the scenario above) that will influence S&H Aquariums’ immediate plans for PCI DSS compliance. Discuss payment brands (credit card companies), transaction volumes, merchant levels (i.e., 1 through 4), and types of reporting required in relation to S&H Aquariums’ business projections.
o Future Considerations for PCI DSS Compliance
§ Analyze contingencies that may influence PCI DSS compliance in the future. Address potential questions from the board, including but not limited to:
· What would be expected of the company if credit card volume increases past 1,000,000 transactions in future years?
· What should S&H Aquariums do to demonstrate PCI DSS compliance if it begins to accept American Express or Discover?
· How would opening a bricks-and-mortar store affect the company’s responsibilities for PCI DSS compliance?
o Conclusion
As a reminder, you may use the textbook for this course and the Internet to conduct research. You are encouraged to respond creatively, but you must cite credible sources to support your work.
Submission Requirements
· Format: Microsoft Word
· Font: Arial, 12-point, double-space
· Citation Style: APA
· Length: 2–3 pages
Self-Assessment Checklist
· I have created a report that uses a professional tone and includes correct terminology.
· In my report, I have described PCI DSS, provided a sound rationale for addressing PCI DSS compliance, and analyzed immediate and future considerations for PCI DSS compliance.
· I have conducted adequate independent research for this part of the project.
Project Part 2: Design of an Integrated Internal Control System
Scenario
S&H Aquariums’ board of directors reviewed the report you submitted on PCI DSS compliance (in Project Part 1), and they were grateful for the background and analysis you provided. After discussing the information, they realized that PCI DSS compliance is but one aspect of the overarching information security system needed to launch and sustain the new business.
The board would like to understand the bigger picture of how you will develop the control system needed to protect credit card data and document compliance with the PCI DSS requirements. You know this will be a rather complex process. You are planning to use a combination of frameworks and standards to guide the development of the control system. Furthermore, you are making it a priority to design an integrated system so the company can efficiently prepare for multiple types of audits, not just those related to PCI DSS compliance.
After explaining to the board that, realistically, you and your team will need much more time to research, discuss, plan, and implement the company’s control system, you agree to write a report that highlights some of the key principles and procedures involved in this undertaking.
Tasks
· Review information about the following frameworks or standards introduced in the textbook: COSO, COBIT, SOC, ISO, and NIST. Consider how you may use some or all of these frameworks/standards to guide the creation of an internal control system at S&H Aquariums. Note the similarities or overlaps among each set of frameworks/standards, as well as the differences.
· Using the Internet resources listed for this project, examine the specifics of the COSO framework, which outlines five components of internal control and 17 principles.
· Create a table or other visual aid to map the 17 principles of COSO to the 12 primary PCI DSS requirements. Use your table or visual aid to assess how specific elements of COSO and PCI DSS correspond with one another, as this will inform forthcoming decisions about which controls S&H Aquariums should implement.
· Write a report for the board of directors. Include the following:
o Introduction
o Plan for Developing an Integrated Internal Control System
§ Explain how and why you will use multiple frameworks and standards to guide your development of this control system.
§ Explain how you will ensure the control system can be used to demonstrate PCI DSS and other forms of compliance.
o Table (or Visual Aid) Showing COSO – PCI DSS Alignment
§ In addition, explain how creating this table/visual aid—as well as other, more complex tables with multiple standards/frameworks—would be useful for designing an integrated internal control system.
o Conclusion
As a reminder, you may use the textbook for this course and the Internet to conduct research. You are encouraged to respond creatively, but you must cite credible sources to support your work.
Submission Requirements
§ Format: Microsoft Word
§ Font: Arial, 12-point, double-space
§ Citation Style: APA
§ Length: 2-3 pages
Self-Assessment Checklist
§ I have created a report that uses a professional tone and includes correct terminology.
§ In my report, I have explained how and why I would use a combination of standards/frameworks to guide the development of an integrated internal control system, and explained how I would ensure the control system could be used to demonstrate multiple forms of compliance.
§ In my report, I have included a table or visual aid that shows alignment of COSO and PCI DSS, and I have explained how this would be useful for designing an integrated internal control system.
§ I have conducted adequate independent research for this part of the project.
Project Part 3: Compliance Within IT Infrastructure Domains
Scenario
S&H Aquariums’ board of directors has been receptive to your plan for building an internal control system. They are eager to move forward and expand the company’s IT infrastructure so they can begin processing credit card transactions through their Web site. The company has recently hired a new team member, Marcus, who will work with you to address some of the company’s information technology needs.
Marcus brings a good deal of expertise in IT, but he needs some additional training and development on information security and compliance issues. To bring Marcus up to date on the company’s plans, you ask him to read the two reports you prepared for the board of directors (in Project Parts 1 and 2). Next, you will meet with him to discuss the integrated internal control system and explain how such a system can be used to proactively prepare for audits. Clearly, there is a lot to consider! You decide to create a presentation that is structured around the seven domains of a typical IT infrastructure. You will provide examples of controls that you think S&H Aquariums should implement, and explain how these controls relate to COSO and PCI DSS. You will also explain how this will, ultimately, help the company demonstrate compliance.
§ Tasks
Consider the seven domains of a typical IT infrastructure, as well as controls that are often associated with each of those domains.
§ Based on your earlier analysis of S&H Aquariums and its compliance requirements (in Project Parts 1 and 2), which controls do you think S&H Aquariums should implement as part of the integrated internal control system? You may create a table, map, or other visual aid to help you evaluate control options for each domain.
Note: For this part of the project, consider how prospective controls align with COSO and PCI DSS. In an actual organization, the controls you implement would most likely align with additional frameworks/standards, but you are not required to research and document that for this project.
§ Create a presentation that includes:
o Title, date, and your name and contact information
o A brief introduction
o A section for each of the seven domains in a typical IT infrastructure
In each domain section:
§ Explain what the domain is and why it is significant for compliance.
§ Describe at least two controls related to this domain that you would recommend S&H Aquariums implement as part of its integrated internal control system.
§ Provide your rationale for selecting each control; explain how the control relates to one or more principles of COSO and one or more PCI DSS requirements.
o Implications for Compliance
§ Explain how use of the controls you have presented will support the company’s efforts to demonstrate compliance.
o Conclusion
o References
As a reminder, you may use the textbook for this course and the Internet to conduct research. You are encouraged to respond creatively, but you must cite credible sources to support your work.
Submission Requirements
§ Format: Microsoft PowerPoint
§ Font: Arial; 36-point headings, 20- to 32-point body text
§ Citation Style: APA
§ Length: 12 to 16 slides
Self-Assessment Checklist
§ I have created a presentation that uses a professional tone and includes correct terminology.
§ In my presentation, I have described the seven domains of a typical IT infrastructure. For each domain, I have recommended at least two controls and provided my rationale for the selections. I have also discussed implications of implementing these controls for demonstrating compliance.
§ I have conducted adequate independent research for this part of the project.
