Pci Saq - P2pe
Pci Saq - P2pe
May 2012 2.0 To create SAQ P2PE-HW for merchants using only
hardware terminals as part of a validated P2PE
solution listed by PCI SSC.
This SAQ is for use with PCI DSS v2.0.
February 2014 3.0 To align content with PCI DSS v3.0 requirements and
testing procedures and incorporate additional
response options.
April 2015 3.1 Updated to align with PCI DSS v3.1. For details of
PCI DSS changes, see PCI DSS – Summary of
Changes from PCI DSS Version 3.0 to 3.1.
Removed “HW” from SAQ title, as may be used by
merchants using either a HW/HW or HW/Hybrid
P2PE solution.
April 2016 3.2 1.0 Updated to align with PCI DSS v3.2. For details of
PCI DSS changes, see PCI DSS – Summary of
Changes from PCI DSS Version 3.1 to 3.2.
Removed PCI DSS Requirements 3.3 and 4.2, as
covered in implementation of PCI P2PE solution and
PIM.
This shortened version of the SAQ includes questions that apply to a specific type of small-merchant
environment, as defined in the above eligibility criteria. If there are PCI DSS requirements applicable to
your environment that are not covered in this SAQ, it may be an indication that this SAQ is not suitable for
your environment.
Additional resources that provide guidance on PCI DSS requirements and how to complete the self-
assessment questionnaire have been provided to assist with the assessment process. An overview of
some of these resources is provided below:
Document Includes:
PCI DSS Guidance on Scoping
(PCI Data Security Standard Guidance on the intent of all PCI DSS Requirements
Requirements and Security Assessment
Details of testing procedures
Procedures)
Guidance on Compensating Controls
SAQ Instructions and Guidelines Information about all SAQs and their eligibility criteria
documents How to determine which SAQ is right for your
organization
PCI DSS and PA-DSS Glossary of Descriptions and definitions of terms used in the PCI
Terms, Abbreviations, and Acronyms DSS and self-assessment questionnaires
These and other resources can be found on the PCI SSC website (www.pcisecuritystandards.org).
Organizations are encouraged to review the PCI DSS and other supporting documents before beginning
an assessment,
Expected Testing
The instructions provided in the “Expected Testing” column are based on the testing procedures in the
PCI DSS, and provide a high-level description of the types of testing activities that should be performed in
order to verify that a requirement has been met. Full details of testing procedures for each requirement
can be found in the PCI DSS.
A description of the meaning for each response is provided in the table below:
Yes with CCW The expected testing has been performed, and the requirement has
(Compensating been met with the assistance of a compensating control.
Control Worksheet)
All responses in this column require completion of a Compensating
Control Worksheet (CCW) in Appendix B of the SAQ.
Information on the use of compensating controls and guidance on
how to complete the worksheet is provided in the PCI DSS.
No Some or all elements of the requirement have not been met, or are
in the process of being implemented, or require further testing before
it will be known if they are in place.
Legal Exception
If your organization is subject to a legal restriction that prevents the organization from meeting a PCI DSS
requirement, check the “No” column for that requirement and complete the relevant attestation in Part 3.
What types of payment channels does your Which payment channels are covered by this SAQ?
business serve?
Mail order/telephone order (MOTO) Mail order/telephone order (MOTO)
E-Commerce E-Commerce
Card-present (face-to-face) Card-present (face-to-face)
Note: If your organization has a payment channel or process that is not covered by this SAQ, consult your
acquirer or payment brand about validation for the other channels.
PCI DSS v3.2 SAQ P2PE, Rev. 1.1 – Section 1: Assessment Information January 2017
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Part 2b. Description of Payment Card Business
How and in what capacity does your business
store, process and/or transmit cardholder data?
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Part 2f. Third-Party Service Providers
Does your company use a Qualified Integrator & Reseller (QIR)? Yes No
If Yes:
Name of QIR Company:
QIR Individual Name:
Description of services provided by QIR:
Does your company share cardholder data with any third-party service providers (for Yes No
example, Qualified Integrator & Resellers (QIR), gateways, airline booking agents, loyalty
program agents, etc.)?
If Yes:
Name of service provider: Description of services provided:
Note: Requirement 12.8 applies to all entities listed in response to this question.
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Section 2: Self-Assessment Questionnaire P2PE
Note: The following questions are numbered according to the actual PCI DSS requirements and testing procedures, as defined in the PCI DSS
Requirements and Security Assessment Procedures document. As only a subset of PCI DSS requirements are provided in this SAQ P2PE, the
numbering of these questions may not be consecutive.
Response
(Check one response for each question)
PCI DSS Question Expected Testing Yes
with
Yes CCW No N/A
3.1 Are data-retention and disposal policies, procedures,
and processes implemented as follows:
(a) Is data storage amount and retention time limited Review data retention and disposal
to that required for legal, regulatory, and/or policies and procedures
business requirements? Interview personnel
(b) Are there defined processes in place for securely Review policies and procedures
deleting cardholder data when no longer needed Interview personnel
for legal, regulatory, and/or business reasons?
Examine deletion mechanism
(c) Are there specific retention requirements for Review policies and procedures
cardholder data? Interview personnel
For example, cardholder data needs to be held for X
Examine retention requirements
period for Y business reasons.
(d) Is there a quarterly process for identifying and Review policies and procedures
securely deleting stored cardholder data that Interview personnel
exceeds defined retention requirements?
Observe deletion processes
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Response
(Check one response for each question)
PCI DSS Question Expected Testing Yes
with
Yes CCW No N/A
(e) Does all stored cardholder data meet the Examine files and system records
requirements defined in the data-retention policy?
Guidance: “Yes” answers for requirements at 3.1 mean that if a merchant stores any paper (for example, receipts or paper reports) that contain account
data, the merchant only stores the paper as long as it is needed for business, legal, and/or regulatory reasons and destroys the paper once it is no longer
needed.
If a merchant never prints or stores any paper containing account data, the merchant should mark the “N/A” column and complete the “Explanation of Non-
Applicability” worksheet in Appendix C.
3.2.2 For all paper storage, the card verification code or Examine paper data sources
value (three-digit or four-digit number printed on the
front or back of a payment card) is not stored after
authorization?
Guidance: A “Yes” answer for Requirement 3.2.2 means that if the merchant writes down the card security code while a transaction is being conducted, the
merchant either securely destroys the paper (for example, with a shredder) immediately after the transaction is complete, or obscures the code (for
example, by “blacking it out” with a marker) before the paper is stored.
If the merchant never requests the three-digit or four-digit number printed on the front or back of a payment card (“card security code”), the merchant should
mark the “N/A” column and complete the “Explanation of Non-Applicability” worksheet in Appendix C.
3.7 Are security policies and operational procedures for Review security policies and
protecting stored cardholder data: operational procedures
Documented Interview personnel
In use
Known to all affected parties?
Guidance: A “Yes” answer to Requirement 3.7 means that, if the merchant has paper storage of account data, the merchant has policies and procedures in
place for Requirements 3.1, 3.2.2, and 3.3. This helps to ensure personnel are aware of and following security policies and documented operational
procedures for managing the secure storage of cardholder data on a continuous basis.
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Implement Strong Access Control Measures
Requirement 9: Restrict physical access to cardholder data
Note: Requirements 9.5 and 9.8 apply only to SAQ P2PE merchants that have paper records (for example, receipts, printed reports, etc.) with
account data, including primary account numbers (PANs).
Response
(Check one response for each question)
PCI DSS Question Expected Testing Yes
with
Yes CCW No N/A
9.5 Are all media physically secured (including but not Review policies and procedures for
limited to computers, removable electronic media, physically securing media
paper receipts, paper reports, and faxes)? Interview personnel
For purposes of Requirement 9, “media” refers to all
paper and electronic media containing cardholder
data.
9.8 (a) Is all media destroyed when it is no longer Review periodic media destruction
needed for business or legal reasons? policies and procedures
(c) Is media destruction performed as follows:
9.8.1 (a) Are hardcopy materials cross-cut shredded, Review periodic media destruction
incinerated, or pulped so that cardholder data policies and procedures
cannot be reconstructed?
Interview personnel
Observe processes
(b) Are storage containers used for materials that Review periodic media destruction
contain information to be destroyed secured to policies and procedures
prevent access to the contents?
Examine security of storage
containers
Guidance: “Yes” answers for requirements at 9.5 and 9.8 mean that the merchant securely stores any paper with account data, for example by storing
them in a locked drawer, cabinet, or safe, and that the merchant destroys such paper when no longer needed for business purposes. This includes a written
document or policy for employees so they know how to secure paper with account data and how to destroy the paper when no longer needed.
If the merchant never stores any paper with account data, the merchant should mark the “N/A” column and complete the “Explanation of Non-Applicability”
worksheet in Appendix C.
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Response
(Check one response for each question)
PCI DSS Question Expected Testing Yes
with
Yes CCW No N/A
9.9 Are devices that capture payment card data via direct
physical interaction with the card protected against
tampering and substitution as follows?
Note: This requirement applies to card-reading
devices used in card-present transactions (that is,
card swipe or dip) at the point of sale. This
requirement is not intended to apply to manual key-
entry components such as computer keyboards and
POS keypads.
(a) Do policies and procedures require that a list of Review policies and procedures
such devices be maintained?
(b) Do policies and procedures require that devices Review policies and procedures
are periodically inspected to look for tampering or
substitution?
(c) Do policies and procedures require that personnel Review policies and procedures
are trained to be aware of suspicious behavior
and to report tampering or substitution of devices?
9.9.1 (a) Does the list of devices include the following? Examine the list of devices
Make, model of device
Location of device (for example, the address
of the site or facility where the device is
located)
Device serial number or other method of
unique identification
(b) Is the list accurate and up to date? Observe devices and device
locations and compare to list
(c) Is the list of devices updated when devices are Interview personnel
added, relocated, decommissioned, etc.?
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Response
(Check one response for each question)
PCI DSS Question Expected Testing Yes
with
Yes CCW No N/A
9.9.2 (a) Are device surfaces periodically inspected to Interview personnel
detect tampering (for example, addition of card Observe inspection processes and
skimmers to devices), or substitution (for compare to defined processes
example, by checking the serial number or other
device characteristics to verify it has not been
swapped with a fraudulent device) as follows?
Note: Examples of signs that a device might have
been tampered with or substituted include unexpected
attachments or cables plugged into the device,
missing or changed security labels, broken or
differently colored casing, or changes to the serial
number or other external markings.
(b) Are personnel aware of procedures for inspecting Interview personnel
devices?
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Response
(Check one response for each question)
PCI DSS Question Expected Testing Yes
with
Yes CCW No N/A
(b) Have personnel at point-of-sale locations Interview personnel at POS
received training, and are they aware of locations
procedures to detect and report attempted
tampering or replacement of devices?
Guidance: “Yes” answers to requirements at 9.9 mean the merchant has policies and procedures in place for Requirements 9.9.1 – 9.9.3, and that they
maintain a current list of devices, conduct periodic device inspections, and train employees about what to look for to detect tampered or replaced devices.
9.10 Are security policies and operational procedures for Examine security policies and
restricting physical access to cardholder data: operational procedures
Documented Interview personnel
In use
Known to all affected parties?
Guidance: A “Yes” answer to Requirement 9.10 means that the merchant has policies and procedures in place for Requirements 9.5, 9.8, and 9.9, as
applicable for your environment. This helps to ensure personnel are aware of and following security policies and documented operational procedures.
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Maintain an Information Security Policy
Requirement 12: Maintain a policy that addresses information security for all personnel
Note: Requirement 12 specifies that merchants must have information security policies for their personnel, but these policies can be as simple or
complex as needed for the size and complexity of the merchant’s operations. The policy document must be provided to all personnel so they are
aware of their responsibilities for protecting the, payment terminals, any paper documents with cardholder data, etc. If a merchant has no
employees, then it is expected that the merchant understands and acknowledges their responsibility for security within their store(s).
Response
(Check one response for each question)
PCI DSS Question Expected Testing
Yes with
Yes CCW No N/A
12.1 Is a security policy established, published, maintained, Review the information security
and disseminated to all relevant personnel? policy
12.1.1 Is the security policy reviewed at least annually and Review the information security
updated when the environment changes? policy
Interview responsible personnel
Guidance: “Yes” answers for requirements at 12.1 mean that the merchant has a security policy that is reasonable for the size and complexity of the
merchant’s operations, and that the policy is reviewed annually and updated if needed. For example, such a policy could be a simple document that covers
how to protect the store and payment devices in accordance with the P2PE Instruction Manual (PIM), and who to call in an emergency.
12.4 Do security policy and procedures clearly define Review information security policy
information security responsibilities for all personnel? and procedures
Interview a sample of responsible
personnel
Guidance: A “Yes” answer for Requirement 12.4 means that the merchant’s security policy defines basic security responsibilities for all personnel,
consistent with the size and complexity of the merchant’s operations. For example, security responsibilities could be defined according to basic
responsibilities by employee levels, such as the responsibilities expected of a manager/owner and those expected of clerks.
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Response
(Check one response for each question)
PCI DSS Question Expected Testing
Yes with
Yes CCW No N/A
12.6 (a) Is a formal security awareness program in place Review security awareness program
to make all personnel aware of the cardholder
data security policy and procedures?
Guidance: A Yes” answer for Requirement 12.6 means that the merchant has a security awareness program in place, consistent with the size and
complexity of the merchant’s operations. For example, a simple awareness program could be a flyer posted in the back office, or a periodic e-mail sent to
all employees. Examples of awareness program messaging include descriptions of security tips all employees should follow, such as how to lock doors and
storage containers, how to determine whether a payment terminal has been tampered with, and how to identify legitimate personnel who may come to
service hardware payment terminals.
12.8.1 Is a list of service providers maintained, including a Review policies and procedures
description of the service(s) provided? Observe processes
Review list of service providers
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Response
(Check one response for each question)
PCI DSS Question Expected Testing
Yes with
Yes CCW No N/A
12.8.3 Is there an established process for engaging service Observe processes
providers, including proper due diligence prior to Review policies and procedures and
engagement? supporting documentation
Guidance: “Yes” answers for requirements at 12.8 mean that the merchant has a list of, and agreements with, service providers they share cardholder data
with. For example, such agreements would be applicable if a merchant uses a document-retention company to store paper documents that include account
data.
12.10.1 (a) Has an incident response plan been created to be Review the incident response plan
implemented in the event of system breach? Review incident response plan
procedures
Guidance: “Yes” answers for requirements at 12.10 mean that the merchant has documented an incident response and escalation plan to be used for
emergencies, consistent with the size and complexity of the merchant’s operations. For example, such a plan could be a simple document posted in the
back office that lists who to call in the event of various situations with an annual review to confirm it is still accurate, but could extend all the way to a full
incident response plan including backup “hotsite” facilities and thorough annual testing. This plan should be readily available to all personnel as a resource
in an emergency.
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Appendix A: Additional PCI DSS Requirements
Appendix A1: Additional PCI DSS Requirements for Shared Hosting Providers
Appendix A2: Additional PCI DSS Requirements for Entities using SSL/early TLS
This Appendix applies only to entities designated by a payment brand(s) or acquirer as requiring
additional validation of existing PCI DSS requirements. Entities required to validate to this Appendix
should use the DESV Supplemental Reporting Template and Supplemental Attestation of Compliance
for reporting, and consult with the applicable payment brand and/or acquirer for submission procedures.
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Appendix B: Compensating Controls Worksheet
Use this worksheet to define compensating controls for any requirement where “YES with CCW” was
checked.
Note: Only companies that have undertaken a risk analysis and have legitimate technological or
documented business constraints can consider the use of compensating controls to achieve compliance.
Refer to Appendices B, C, and D of PCI DSS for information about compensating controls and guidance
on how to complete this worksheet.
Requirement Number and Definition:
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Appendix C: Explanation of Non-Applicability
If the “N/A” (Not Applicable) column was checked in the questionnaire, use this worksheet to explain why
the related requirement is not applicable to your organization.
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Section 3: Validation and Attestation Details
Compliant: All sections of the PCI DSS SAQ P2PE are complete, and all questions answered affirmatively,
resulting in an overall COMPLIANT rating, thereby (Merchant Company Name) has demonstrated full
compliance with the PCI DSS.
Non-Compliant: Not all sections of the PCI DSS SAQ P2PE are complete, or not all questions are answered
affirmatively, resulting in an overall NON-COMPLIANT rating, thereby (Merchant Company Name) has not
demonstrated full compliance with the PCI DSS.
Target Date for Compliance:
An entity submitting this form with a status of Non-Compliant may be required to complete the Action Plan in
Part 4 of this document. Check with your acquirer or the payment brand(s) before completing Part 4, since
not all payment brands require this section.
Compliant but with Legal exception: One or more requirements are marked “No” due to a legal
restriction that prevents the requirement from being met. This option requires additional review from
acquirer or payment brand.
If checked, complete the following:
Affected Requirement Details of how legal constraint prevents requirement being met
PCI DSS Self-Assessment Questionnaire P2PE, Version (version of SAQ), was completed according to the
instructions therein.
All information within the above-referenced SAQ and in this attestation fairly represents the results of my
assessment.
I have read the PCI DSS and I recognize that I must maintain PCI DSS compliance, as applicable to my
environment, at all times.
PCI DSS v3.2 SAQ P2PE, Rev. 1.1 – Section 3: Validation and Attestation Details January 2017
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Part 3a. Acknowledgement of Status (continued)
If my environment changes, I recognize I must reassess my environment and implement any additional PCI
DSS requirements that apply.
No evidence of, full track data1, CAV2, CVC2, CID, or CVV2 data2, or PIN data3) was found on ANY system
reviewed during this assessment.
1 Data encoded in the magnetic stripe or equivalent data on a chip used for authorization during a card-present
transaction. Entities may not retain full magnetic-stripe data after transaction authorization. The only elements of
track data that may be retained are account number, expiration date, and name.
2 The three- or four-digit value printed on or to the right of the signature panel or on the face of a payment card used
to verify card-not-present transactions.
3 Personal Identification Number entered by cardholder during a card-present transaction, and/or encrypted PIN
block present within the transaction message.
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Part 4. Action Plan for Non-Compliant Status
Select the appropriate response for “Compliant to PCI DSS Requirements” for each requirement. If you answer
“NO” to any of the requirements, you may be required to provide the date your Company expects to be compliant
with the requirement and a brief description of the actions being taken to meet the requirement.
Check with your acquirer or the payment brand(s) before completing Part 4, since not all payment brands require
this section.
Compliance to PCI
DSS Requirements Remediation Date and Actions
PCI DSS
Description of Requirement (Select One) (If “NO” selected for any
Requirement*
Requirement)
YES NO
* PCI DSS Requirements indicated here refer to the questions in Section 2 of the SAQ.
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