Begin forwarded message:

> From: Daniel Beatty <danielbea...@mac.com>
> Date: August 27, 2010 4:10:34 AM EDT
> To: David BON <bo...@mac.com>
> Cc: Daniel Beatty <danielbea...@mac.com>
> Subject: Re: Cloud Computing and PCI Compliance
> 
> 
> 
> Greetings David,
> I would have to agree with you.  The combination of PayPal and SAML2 (such as 
> Shibboleth) would allow such a thing to be true.  The Shibboleth 
> implementation would allow the site to remove all but the references to the 
> IdP and since PayPal also abides by this also, then the references by the 
> Cloud hosted web app would be small.  I would think the last hitch on this 
> would be backups of the web app's database would the last piece of that PCI 
> compliance jigsaw puzzle.  But, that is just me rambling with logic.
> 
> Later,
> Dan
> 
> On Aug 23, 2010, at 8:54 AM, David BON wrote:
> 
>> If you use Paypal services for example (or another Internet Payment 
>> Gateway), I suppose that they are already Level 1 compliant, no ? In that 
>> case, you don't need to maintain any cardholder information in your own 
>> system and could be then easily PCI compliant even using the cloud computing?
>> 
>> Did I miss something?
>> 
>> Regards.
>> 
>> David B.
>> 
>> Le 23 août 10 à 12:43, Kieran Kelleher a écrit :
>> 
>>> My colleague at work who looks after PCI compliance sent me this 
>>> interesting info, which clarifies a lot.
>>> 
>>>     • PCI Compliance Level 1 - Merchants processing over 6 million Visa 
>>> transactions annually (all channels) or Global merchants identified as 
>>> Level 1 by any Visa region
>>>     • PCI Compliance Level 2 - Merchants processing 1 million to 6 million 
>>> Visa transactions annually (all channels)
>>>     • PCI Compliance Level 3 - Merchants processing 20,000 to 1 million 
>>> Visa e-commerce transactions annually
>>>     • PCI Compliance Level 4 - Merchants processing less than 20,000 Visa 
>>> e-commerce transactions annually and all other merchants processing up to 1 
>>> million Visa transactions annually
>>>  
>>> 
>>> As he said, and based on our average transaction of about $100, "If we get 
>>> to a level one, we will have enough money to have an OC3 pipe, all the 
>>> equipment we need and a full IT department!" ....   :-)
>>> 
>>> Based on some other internet "research", a possible approach to deal with 
>>> this scenario might be building a hybrid cloud architecture having most of 
>>> the deployment in the could while having a separate secure webservices 
>>> application hosted physically and securely inhouse for storing the 
>>> encrypted cc records and processing the credit card  transactions 
>>> themselves. The remote apps would merely send a request to that internal 
>>> webservices app where the request might have the CCInfo PK and an 
>>> transaction amount/id for processing, the cloud app would ping cc 
>>> webservices app every few seconds for transaction status and finally get 
>>> the result. Such an approach would compartmentalize PCI in a manageable way 
>>> it would seem. Of course credit cards would still be submitted through 
>>> forms in the cloud app, but never stored there, from there it would be 
>>> encryption of the cc info and transmission back to the internal webservices 
>>> app for permanent storage and or requests to perform cc transactions.
>>> 
>>> Any opinions on that?
>>> 
>>> 
>>> -Kieran
>>> 
>>> 
>>> 
>>> 
>>> On Aug 22, 2010, at 5:43 PM, Simon wrote:
>>> 
>>>> To be compliant you would need to do your card processing elsewhere that 
>>>> can provide such a guarantee.
>>>> 
>>>> no, that's not necessarily the case. it depends on what level of pci 
>>>> compliance you require. checkout the official amazon response on the 
>>>> following thread. they confirm you can build up to level 2 compliance on 
>>>> amazon web services.
>>>> 
>>>> http://developer.amazonwebservices.com/connect/message.jspa?messageID=139547
>>>> 
>>>> level 1 is the only one that can't be achieved because of the on-site 
>>>> visit requirement. but IIRC that's only necessary if you are processing 
>>>> over 6 million cards per annum.
>>>> 
>>>> simon
>>>> 
>>>>  
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> 
> Dan Beatty, M.S. CS (B.S. EECS)
> Ph.D. Student 
> Texas Tech University
> dan.bea...@mac.com
> http://web.me.com/danielbeatty/My_Home_Page/Welcome.html
> (806)438-6620
> 
> 
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