Penetration Testing: Faxing and PCI DSS compliance

[cwright () bdosyd com au]

JW,
Your first problem will stem from having to encrypt the numbers in transit. The fax to email gateway will have to sign 
these emails.

A set of competating controls could be implemented for this (protected network with firewalls, IDS etc which could take 
the place of encrption, but this would be a significant investment in itself. The PCI-DSS requirement 3 states "not 
sending PAN in unencrypted e-mails". 4.2 also specifically states "4.2 Never send unencrypted PANs by e-mail".

So as I said, there are possible compensating controls, but I believe that they are going to be far more of an 
investment then encryption.

Next in this case the fax server and email system would have to be on a firewalled segment and not (as is common) on 
the same network as all the users. 

With physical faxes, 9.6 applies "Physically secure all paper and electronic media (including computers, electronic 
media, networking and communications hardware, telecommunication lines, paper receipts, paper reports, and faxes) that 
contain cardholder data." 

You would have to have a minimum level of security on the virtualised process as for paper handling. So this would 
cover (as with the above) encryption, destruction after use etc.

Regards,
Dr Craig Wright (GSE-Compliance)

--- in reply to ---
Speaking of faxes.. how do y'all deal with PCI compliance with respect to FAX to email/web applications?
 
For example, if you have a customer who insists on faxing full credit card info on their regular fax machine to a 
company that is utilizing a service that converts that fax to PDF and emails it to you?
 
j

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