Executive Security & Transportation

Policy and Procedures

Credit Card Policy and Procedures

I. PURPOSE
The purpose of this policy is to establish business processes that will protect our client—with procedures for accepting Credit and Debit cards through EST, LLC as well as minimize risk and provide the greatest value, security of data, and availability of services. Member within the rules and regulations established by the Payment Card Industry (PCI) and articulated in the PCI Data Security Standards (DSS). Additionally, these processes are intended to ensure that payment card acceptance procedures are appropriately integrated with the EST, LLC.’s accounting and other systems.

II. BACKGROUND
In response to increasing incidents of identity theft, the major payment card companies created the Payment Card Industry Data Security Standard (PCI DSS) to help prevent theft of customer data. PCI DSS applies to all businesses that accept payment cards to procure goods or services. Compliance with this Standard is enforced by the payment card companies and generally, noncompliance is discovered when an organization experiences a security breach that includes cardholder data.

Security breaches can result in serious consequences for EST, LLC., including release of confidential information, damage to reputation, the assessment of substantial fines, possible legal liability and the potential loss of the ability to accept payment card and eCommerce payments. EST, LLC. will take every effort to ensure that Data Security Standards are adhered to.

III. DEFINITIONS

Cardholder
The customer to whom a credit or debit card has been issued or the individual authorized to use the card

Cardholder Data
All personally identifiable data about the cardholder (i.e., account number, expiration date, and cardholder name.)

EST, LLC. Management
Executive officer that approves all third-party service providers and coordinates the policies and procedures for accepting Credit and Debit cards at EST, LLC

Encryption
The process of converting information into an unintelligible form to anyone except holders of a specific cryptographic key. Use of encryption protects information between the encryption process and the decryption process against unauthorized disclosure

Staff Employee
For the purposes of the PCI DSS and this policy, a Staff Employee is defined as entity that accepts Credit or Debit cards bearing the logos of any of the five members of the Payment Card Industry Security Standards Council (American Express, Discover, JCB, MasterCard or VISA) as payment for EST, LLC. training and/or services.

For the purposes of the PCI DSS and this policy, a Staff Employee is defined as entity that accepts Credit or Debit cards bearing the logos of any of the five members of the Payment Card Industry Security Standards Council (American Express, Discover, JCB, MasterCard or VISA) as payment for EST, LLC. training and/or services.

Payment Card
Any Credit or Debit card/device that bears the logo of American Express, Discover Financial Services, JCB International, MasterCard Worldwide, or VISA, Inc.

Credit or Debit Card Account Change
Any change in the payment account including, but not limited to:

the use of existing Credit or Debit card accounts for new purposes
the alternation of business processes that involve Credit or Debit card processing activities;
the addition or alteration of payment systems;
the addition or alternation of relationships with third-party Credit or Debit card service providers, and
the addition or alternation of Credit or Debit card processing technologies or channel

Credit or Debit Card Industry (PCI) Data Security Standard (DSS)
A multi-faceted security standard that includes requirements for security management, policies, procedures, network architecture, software design and other critical protective measures.

Sensitive Authentication Data
Security-related information (card validation codes/values, full magnetic-stripe data, or personal identification number (PIN)) used to authenticate cardholders, appearing in plain-text or otherwise unprotected form

IV. TERMS AND CONDITIONS
This policy applies to all EST, LLC. employees, Members, Non-Members, Consultants, or Agents who, in the course of doing business on behalf or with EST, LLC., accept, process, transmit, or otherwise handle cardholder information in physical or electronic format.

This policy applies to all EST, LLC. departments and administrative areas which accept Credit or Debit cards regardless of whether revenue is deposited in a EST, LLC. financial account.

V. ACCEPTABLE CREDIT OR DEBIT CARDS
EST, LLC. currently accepts VISA, MasterCard, Discover and American Express Card and has negotiated contracts for processing Credit or Debit card transactions. Individual EST, LLC. employees may not use or negotiate individual contracts with these or other Credit or Debit card companies or processors. All individual EST, LLC. employees must use the EST, LLC. negotiated contract.

VI. PROHIBITED CREDIT OR DEBIT CARD ACTIVITIES
EST, LLC. prohibits certain credit card activities that include, but are not limited to:

accepting Credit or Debit cards for cash advances
discounting training or service based on the method of payment
adding a surcharge or additional fee to Credit or Debit card transactions

VII. CREDIT OR DEBIT CARD FEES
Each Credit or Debit card transaction will have an associated fee charged by the credit card company.

VIII. REFUNDS
When a service is purchased using a Credit or Debit card and a refund is necessary, the refund must be credited back to the account that was originally charged. Refunds in excess of the original sale amount or cash refunds are prohibited

IX. CHARGEBACKS
Occasionally a customer will dispute a Credit or Debit card transaction, ultimately leading to a chargeback. In the case of a chargeback, EST, LLC.’s accounting department will be responsible for all chargeback transactions.

X. MAINTAINING SECURITY

Departments and administrative areas accepting Credit or Debit cards on behalf of EST, LLC. are subject to the Credit or Debit Card Industry Data Security Standards (PCI DSS).
Fax transmissions (both sending and receiving) of credit card and electronic payment information occurs using only fax machines which are attended by those individuals who must have contact with Credit or Debit card data to do their jobs;
EST, LLC. requires that all external services providers that handle Credit or Debit card information be PCI compliant.
EST, LLC. restricts access to cardholder data to those with a business “need to know.”
For electronic media, cardholder data shall not be stored on servers, local hard drives, or external (removable) media including floppy discs, CDs or thumb (flash) drives unless encrypted and otherwise in full compliance with PCI DSS.
For paper media, cardholder data shall not be stored.

XI. RESPONSIBILITIES
EST, LLC. Staff are responsible for:

Executing on behalf of the relevant EST, LLC. Department, Credit or Debit Card Account Acquisition or Change Procedures.
Ensuring that all employees, contractors and agents with access to Credit or Debit card data within the relative EST, LLC. Department acknowledge on an annual basis and in writing that they have read and understood this Policy. These acknowledgements should be submitted, as requested, to EST, LLC.’s accounting department
Ensuring that all Credit or Debit card data collected by the EST, LLC. Department in the course of performing EST, LLC.’S business, regardless of whether the data is stored physically or electronically is secured. Data is considered to be secured only if all of the following criteria are met:
Only those with a “need-to-know” are granted access to Credit or Debit card and electronic payment data;
Email should not be used to transmit credit card or personal payment information. If it should be necessary to transmit credit card information via email only the last four digits of the credit card number can be displayed;
Credit card or personal information is never downloaded onto any portable devices or media such as USB flash drives, compact disks, laptop computers or personal digital assistants;
The processing and storage of personally identifiable credit card or payment information on EST, LLC. computers and servers is prohibited;
Only secure communication protocols and/or encrypted connections to the authorized vendor are used during the processing of eCommerce transactions
The three or four digit validation code printed on the Credit or Debit card is never stored in any form;
The full contents of any track data from the magnetic stripe are never stored in any form
The personal identification number (PIN) or encrypted PIN block are never stored in any form;
The primary account number (PAN) is rendered unreadable anywhere it is stored;
All but the last four digits of any credit card account number are masked when it is necessary to display credit card data; and
All media containing Credit or Debit card or personal payment data is retained no longer than a maximum of six (6) months and then destroyed or rendered unreadable

The Executive Director, Information Security Contractor, and Account Manager, shall maintain currency with the requirements of the PCI DSS and related requirements to ensure that this policy remains current and shall coordinate and lead any EST, LLC. response to a security breach involving cardholder data.

The Management of EST, LLC. shall:

Provide training to ensure that EST, LLC. employees are trained in accepting and processing Credit or Debit cards in compliance with this policy;
Work with external vendors and coordinate Credit or Debit card policies, standards, and procedures;
Serve as liaison between Financial Management Services, Information Technology Services, and the EST, LLC. employee for Credit or Debit Card account acquisition or change procedures; and
Review and modify the Application for Credit or Debit Card Account Acquisition or Change as necessary.

EST, LLC. will conduct Internal Auditing to:

Periodically will review EST, LLC. employee compliance with this policy and the Credit or Debit Card Industry (PCI) Data Security Standards (DSS);
Identify unapproved payment applications or external vendors that collect Credit or Debit card data on behalf of the EST, LLC. and notify Accounting Department; and
When required will conduct the EST, LLC.’s PCI DSS Self-Assessment and complete the EST, LLC.’s Attestation of Compliance

XII. CREDIT OR DEBIT CARD ACCOUNT ACQUISITION OR CHANGE PROCEDURES
To acquire or change a Credit or Debit card account, the Staff Employee must submit a written process change to the Executive Director/Accounting Department. The application must be signed by the Staff Employee and the appropriate Manager of the EST, LLC. Department. Applications that request eCommerce activities must also be approved by the, Information Technology Contractor. All eCommerce activities shall be processed by a third party vendor authorized by EST, LLC. All requests shall be reviewed by the Executive Director, Account Manager, and the Information Technology Contractor.

XIII. WIRELESS TECHNOLOGY
EST, LLC. will use wireless technology to process or transmit cardholder data over a secured network. Our Secure Sockets Layer (SSL) software is the industry standard and among the best software available today for secure commerce transactions. It encrypts all of your personal information, including credit card number, name, and address, so that it cannot be read over the internet. EST, LLC. employees will never transmit cardholder data over an unsecured network.

The storage of cardholder data on local hard drives, floppy disks or other external media is prohibited. It is also prohibited to use cut-and-paste and print functions during remote access.

XIV. SANCTIONS
The Executive Director may suspend credit card account privileges of any EST, LLC. department or Member Company not in compliance with this policy or that places the EST, LLC. at risk.