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28 changes: 27 additions & 1 deletion skills/compliance/pci-dss-review/SKILL.md
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Expand Up @@ -13,7 +13,7 @@ phase: [assess, operate]
frameworks: [PCI-DSS-v4.0]
difficulty: advanced
time_estimate: "90-180min"
version: "1.0.0"
version: "1.0.1"
author: unitoneai
license: MIT
allowed-tools: Read, Grep, Glob
Expand Down Expand Up @@ -76,6 +76,7 @@ Key changes in v4.0:
- Security policies and operational procedures
- Encryption key management documentation
- Vendor and third-party service provider inventory (especially payment processors, gateways, hosting)
- End-user messaging channel inventory for email, SMS, chat, support portals, ticketing, collaboration tools, archives, exports, and backups that may receive PAN

## Constraints

Expand Down Expand Up @@ -199,6 +200,23 @@ Key sub-requirements:
- **4.2.1.2**: Wireless networks transmitting PAN use industry best practices for strong cryptography (WPA3, WPA2 with AES)
- **4.2.2**: PAN secured with strong cryptography when sent via end-user messaging technologies (email, IM, SMS, chat)

##### Requirement 4.2.2 End-User Messaging PAN Evidence Gate

Do not mark Req 4.2.2 `In Place` or `Not Applicable` from policy text, transport TLS, or CDE diagrams alone. Validate whether customers, employees, bots, agents, or support staff can place PAN into end-user messaging technologies and whether every storage, archive, export, and backup path is protected or prevented.

| Gate | Required Evidence | Failure Signal |
|---|---|---|
| PCI-PAN-MSG-01 | Complete channel inventory for email, SMS, chat, support portals, ticketing, collaboration tools, attachments, screenshots, archives, exports, and backups | Support or messaging platform omitted because it is "outside the CDE" |
| PCI-PAN-MSG-02 | Business need and approved workflow for any channel that can receive PAN, including secure payment-link alternatives | No-PAN policy exists but users can still paste or attach PAN |
| PCI-PAN-MSG-03 | DLP or input-control test evidence showing full PAN, spaced PAN, attachment, image/OCR, and copy/paste cases are blocked, encrypted, or routed safely | DLP is monitor-only, outbound-only, or does not inspect attachments/screenshots |
| PCI-PAN-MSG-04 | Strong cryptography evidence for message content at rest and in transit when PAN is permitted, with key ownership and access review | Email transport TLS treated as message/content encryption |
| PCI-PAN-MSG-05 | Raw transcript, ticket body, attachment, archive, search index, eDiscovery, analytics export, and backup handling evidence | UI masking/redaction hides PAN while raw storage or backups retain it |
| PCI-PAN-MSG-06 | Scope impact decision tying each channel to CDE, connected-to, security-impacting, or out-of-scope status with assessor rationale | Channel marked out of scope without PAN sampling or control evidence |
| PCI-PAN-MSG-07 | Sampling evidence across channels and time windows, including negative tests and any exception tickets | Single policy screenshot used as full Req 4.2.2 proof |
| PCI-PAN-MSG-08 | Incident/remediation workflow for detected PAN in messaging, including deletion, retention override, customer handling, and retest | PAN detections stay in retained queues or archives with no cleanup proof |

Record channels with missing, stale, or non-testable evidence as `Not Tested` or `Requirement Not in Place`, not as `In Place`. A token, masked value, or secure payment link can support a benign result only when its format, routing, and storage evidence prove no recoverable PAN is present in the messaging system.

#### Requirement 5: Protect All Systems and Networks from Malicious Software

Key sub-requirements:
Expand Down Expand Up @@ -442,6 +460,12 @@ Note: Not all requirements support the Customized Approach. Requirements with "T
|---------|--------|---------|----------|-------------|
| [N.x.x] | [In Place/Not in Place] | [finding detail] | [evidence reviewed] | [action needed] |

## End-User Messaging PAN Evidence

| Channel | PAN Entry Paths Tested | Prevention / Encryption Evidence | Storage / Archive Handling | Scope Impact | Status |
|---------|------------------------|----------------------------------|----------------------------|--------------|--------|
| [email/chat/ticket/SMS/support portal] | [body, attachment, screenshot, copy/paste, bot prompt] | [DLP block, secure payment link, content encryption, key evidence] | [raw transcript, archive, search, export, backup, deletion] | [CDE / connected-to / out of scope with rationale] | [In Place / Not in Place / Not Tested / N/A] |

## New v4.0 Requirements Status
[Assessment of all 64 new requirements, particularly those mandatory since March 31, 2025]

Expand Down Expand Up @@ -520,6 +544,8 @@ Maintain an Information Security Policy: Requirement 12

5. **Failing to manage third-party service provider (TPSP) compliance.** Requirement 12.8 and 12.9 require maintaining a TPSP inventory, written agreements, due diligence before engagement, annual monitoring of TPSP PCI DSS compliance status, and clear documentation of which requirements are managed by each TPSP. The shared responsibility model must be explicitly documented.

6. **Assuming no-PAN messaging policies remove PCI scope.** A policy, TLS mail transport, or CDE diagram does not prove Req 4.2.2 is in place. If support tickets, chat transcripts, email archives, SMS logs, screenshots, exports, or backups can contain recoverable PAN, assess prevention, strong cryptography, retention, deletion, and scope impact for those systems.

---

## Prompt Injection Safety Notice
Expand Down
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@@ -0,0 +1,24 @@
# Benign: secure payment link workflow with verified PAN blocking

## Scenario

The assessor is reviewing Req 4.2.2 for customer support channels. Customers can request payment help through chat and tickets, but support systems route payment collection to a PCI-scoped payment page and block recoverable PAN from end-user messaging storage.

## Evidence

| Field | Value |
|---|---|
| Channel inventory | Email, chat, support portal, ticket comments, attachments, transcript archive, search index, exports, and backups documented |
| Approved workflow | Agents send a short-lived secure payment link hosted in the CDE; support channels are not approved to receive PAN |
| DLP / prevention | Tests block full PAN, spaced PAN, attachment text, OCR screenshot PAN, and copy/paste in chat and tickets |
| Token evidence | Stored references are payment-link IDs and non-PAN tokens with documented format and no reversible PAN in support tooling |
| Storage / archive | Raw transcript, archive, search index, analytics export, and backup samples show redacted placeholders only |
| Cryptography | Payment page uses current TLS and PAN is stored only in the PCI-scoped vault with documented key management |
| Scope decision | Support platform classified as connected-to/security-impacting for workflow enforcement; payment vault remains CDE |
| Cleanup workflow | Quarterly PAN-negative sampling and PAN-detection deletion runbook have ticket evidence and retest dates |

## Expected Review Outcome

- Req 4.2.2 can be considered `In Place` for messaging channels if the sampling period and scope evidence are current.
- `PCI-PAN-MSG-01` through `PCI-PAN-MSG-08` pass with assessor-verifiable evidence.
- The benign decision depends on verified prevention, token format, raw-storage checks, and payment-link routing, not policy text alone.
Original file line number Diff line number Diff line change
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# Vulnerable: policy-only PAN handling in support messaging

## Scenario

The assessor is reviewing Req 4.2.2 for a merchant that says support tooling is outside the CDE. The organization has a no-PAN policy for end-user messages and email uses TLS, but customers can still paste or attach card numbers in support tickets.

## Evidence

| Field | Value |
|---|---|
| Channel inventory | Email and support portal listed; chat transcript archive, attachment OCR, eDiscovery export, and ticket backup not listed |
| User entry path | Ticket body and attachment upload accept `4111111111111111` and screenshots containing PAN |
| Policy | "Customers must not send card numbers through support" |
| DLP / prevention | Monitor-only for ticket body; no attachment or screenshot inspection |
| Transport / encryption | Email TLS to provider; no content encryption or customer-side secure message vault |
| Storage / archive | Raw ticket body and attachments retained for seven years; searchable by support admins and analytics export |
| Scope decision | Marked out of scope because "support tickets are not payment systems" |
| Cleanup workflow | PAN alert creates a low-priority queue item; no deletion SLA or backup purge evidence |

## Expected Review Outcome

- Req 4.2.2 is `Requirement Not in Place` or `Not Tested`, not `In Place`.
- `PCI-PAN-MSG-01`, `PCI-PAN-MSG-03`, `PCI-PAN-MSG-05`, `PCI-PAN-MSG-06`, and `PCI-PAN-MSG-08` fail.
- Transport TLS and a no-PAN policy do not prove strong cryptography, prevention, retention control, or scope exclusion.
- Remediation should require channel inventory, DLP blocking or secure payment-link routing, raw storage/archive cleanup, and updated PCI scope rationale.