What Universities Can Teach Retailers About PCI

Written by Walter Conway
February 2nd, 2011

A 403 Labs QSA, PCI Columnist Walt Conway has worked in payments and technology for more than 30 years, 10 of them with Visa.

Things are busy right now. I have an assessment for a hotel that, due to the amount of cardholder data it retains, can be complicated. Another one is for a major medical center with more than 100 payment card merchants, ranging from individual clinics and doctors to an assortment of gift shops and food service outlets. Then I have a series of sports venues with season- and single-ticket sales, in addition to merchandise outlets—many of which are only open part of the year. And one of my parking-garage clients has several locations, all of which use a payment application that wants to store the magnetic stripe from every card it ever sees. Add these to some other retailers and the occasional charity, and the workload gets complicated.

Here is the punch line: All of these merchants belong to the same enterprise, and each of the varied and disparate activities needs to be included in a single assessment. Who is the client? It is a major university. And the reason I am bringing it up here is that the school’s experience holds some lessons for retailers and merchants in every industry.

As I hope you have gathered, the higher education merchant landscape is complex. Schools frequently contain tens or even hundreds of individual payment card merchants spread across multiple campuses. As a result, many schools have adopted PCI compliance strategies and approaches that retail IT managers may want to adopt.

The higher education merchant landscape covers more than student payments. College bookstores are retailers. Schools also operate restaurants and hotels. They may have medical centers with doctors, dentists, pharmacies and gift shops. Campuses are in the entertainment business through their theaters and athletic stadiums where they sell tickets. Schools take donations, manage libraries that sell publications and subscriptions, and run parking facilities. Sometimes, even unaffiliated third-party merchants conduct card transactions using the school’s network (e.g., food courts). Finally, there are part-time merchants who may only be taking payments for a few months each year. These include faculty who run conferences, summer athletic camps and student-run organizations that accept payments.

All of these different merchants take payment cards through every possible channel, including traditional POS, mail order/phone order (MOTO), E-Commerce, fax and probably the odd carrier pigeon. They have one-time and recurring payments.

The distributed nature of the payment application environment is similarly complicated. For example, student finance, athletics and the alumni association each has unique business needs. Each organization might develop its own systems or contract with specialized third-party vendors for business and payment applications. The applications may be outsourced or run on departmental servers that may or may not be under control of IT and network administration.<pHere are some of the PCI lessons that I believe higher education institutions can teach to every merchant.

Commitment from the top. Schools generally have top management commitment, which is critical to a successful PCI compliance effort. This could be the subject of an entire column, but the point is that it is a lot easier to achieve PCI compliance with the engagement and commitment of C-level executives (i.e., CFO, CIO, CEO).


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