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Host Card Emulation (HCE) provisioning is the process of creating and storing cardholder data in a virtual secure element hosted in a remote server, and generating a payment token that can be used by a mobile device to perform a contactless transaction. HCE provisioning is one of the methods of cloud-based provisioning, which does not require the use of a physical secure element on the mobile device. HCE provisioning is different from Secure Element (SE) provisioning, which involves loading cardholder data into a physical secure element embedded or attached to the mobile device. HCE provisioning is also different from Over-the-air (OTA) provisioning, which involves transmitting cardholder data from a remote server to a physical secure element on the mobiledevice using a wireless communication channel. In this scenario, the vendor hosts virtual secure elements holding cardholder information in their data center, and creates a payment token that is sent to the cardholder’s mobile device. This best describes the vendor’s activities as HCE provisioning. References:

PCI Card Production and Provisioning Logical Security Requirements, v2.0, April 2019, page 8, section 1.3

PCI Card Production and Provisioning Logical Security Requirements, v2.0, April 2019, page 9, section 1.4

PCI Card Production and Provisioning Logical Security Requirements, v2.0, April 2019, page 10, section 1.5

PCI Card Production and Provisioning Logical Security Requirements, v2.0, April 2019, page 43, Appendix A: Applicability of Requirements

According to the PCI Card Production Physical Security Requirements, the goods-tools trap is a secure area that separates the HSA from the outside world, and is used to control the entry and exit of card products, tools, and other materials. The goods-tools trap must have two doors that are interlocked, meaning that only one door can be opened at a time. The goods-tools trap must also have a CCTV camera and an alarm system. The process of bringing card products into the HSA using the goods-tools trap must follow these steps1:

The card products must be delivered to the goods-tools trap by authorized personnel, who must present their identification to the guard and sign a delivery note.

The guard must verify the identification of the personnel and the quantity and quality of the card products, and record the details in a log.

The guard must then escort the personnel to the first door of the goods-tools trap, and open it using a key or a card reader. The personnel must place the card products inside the goods-tools trap and exit the area. The guard must then lock the first door.

The guard must then notify the production staff inside the HSA that the card products are ready to be collected. The production staff must present their identification to the guard and sign a receipt note.

The guard must then escort the production staff to the second door of the goods-tools trap, and open it using a key or a card reader. The production staff must collect the card products from the goods-tools trap and enter the HSA. The guard must then lock the second door.

In this scenario, the guard escorted the production staff, along with the box, into the pre-press room. This is not compliant, because the guard is not authorized to enter the HSA, and the card products must remain under dual control at all times. The guard should have stayed outside the HSA and only opened the second door of the goods-tools trap for the production staff. This would ensure that the card products are securely transferred from the goods-tools trap to the HSA, and that the guard does not compromise the security of the HSA. References:

PCI Card Production Physical Security Requirements, v2.0, April 2019, page 15, requirement 2.1.1

PCI Card Production Physical Security Requirements, v2.0, April 2019, page 16, requirement 2.1.2

PCI Card Production Physical Security Requirements, v2.0, April 2019, page 17, requirement 2.1.3

PCI Card Production Physical Security Requirements, v2.0, April 2019, page 18, requirement 2.1.4

The assessor is the person who conducts the PCI Card Production Security Assessment and prepares the Card Production Report on Compliance (ROC) and the Card Production Attestation of Compliance (AOC). The assessor should be familiar with the forms that are needed to complete an assessment and provide guidance to the vendor on how to fill them out. The assessor should also ensure that the forms are consistent with the PCI Card Production Standards and the PCI CPSA Qualification Requirements. The other options are not the best sources of information for the vendor, as they may not be directly involved in the assessment process or have the expertise to advise on the forms. References:

PCI Card Production Security Assessor (CPSA) Program Guide, Version 1.0, April 2019, page 81

PCI Card Production Security Assessor (CPSA) Qualification Requirements, Version 1.0, April 2019, page 10

PCI Card Production and Provisioning Template for Report on Compliance, Version 1.0, April 2019, page 3

PCI Card Production and Provisioning Attestation of Compliance, Version 1.0, April 2019, page 22

According to the PCI Card Production Physical Security Requirements, one of the security controls for card destruction is to ensure that misprinted, partially finished, or rejected cards are shredded only in the HSA destruction room. This is to prevent unauthorized access, theft, or misuse of the cards, which may contain sensitive data or features. The HSA destruction room should have adequate security measures, such as locks, alarms, cameras, etc., to protect the cards until they are shredded. The shredding process should render the cards unusable and unrecognizable, and the shredded material should be disposed of securely. References: PCI Card Production Physical Security Requirements, Version 1.0, April 2019, Section 1.1, Objective 5, Requirement 5.1.1, Page 111

 According to the PCI Card Production Logical Security Requirements, the vendor must have a formal employee termination process that includes notifying the security manager in writing prior to the termination of any employee who has access to cardholder data or sensitive authentication data. This is to ensure that the security manager can take appropriate actions to revoke the employee’s access rights, credentials, and keys, and to prevent any unauthorized use or disclosure of cardholder data or sensitive authentication data by the terminated employee. The vendor must also have a documented policy and procedure for the employee termination process, and must maintain a log of all termination activities. References:

PCI Card Production Logical Security Requirements, v2.0, April 2019, page 19, requirement 6.1.2

PCI Card Production Logical Security Requirements, v2.0, April 2019, page 20, requirement 6.1.3

According to the PCI CPSA Qualification Requirements, one of the administrative requirements for CPSA Companies is to retain all applicant and employee background information on file for at least 12 months after termination of the contract of employment. This is to ensure that the CPSA Company can provide evidence of the background checks performed on the CPSA Employees or other personnel involved in card production and provisioning activities. The background checks should include criminal history, employment history, education verification, and reference checks, and should be conducted at least every two years or upon rehire. References: PCI CPSA Qualification Requirements, Version 1.1, April 2020, Section 6.1.2, Page 111

According to the PCI CPSA Qualification Requirements, one of the administrative requirements for CPSA Companies is to notify the VPA of any changes to the roles of CPSA Employees or other personnel that directly affect the security of card products and related components. This is to ensure that the CPSA Company maintains the quality and integrity of the CPSA Program and the PCI Card Production Security Standards. The VPA should be notified within 10 business days of the change, and the CPSA Company should provide evidence of the qualifications and training of theaffected personnel. References: PCI CPSA Qualification Requirements, Version 1.1, April 2020, Section 6.1.3, Page 121

According to the PCI Card Production Logical Security Requirements, a vendor’s HSA access must be enforced by a security turnstile that has a logical access-control system that ensures anti pass-back. This means that the system must prevent a person from using the same badge to enter or exit the HSA more than once without completing the access cycle. The access cycle is the process of entering or exiting the HSA through the turnstile, which may involve biometric verification, PIN entry, or other authentication methods. The status of the access must change upon initial presentation of an authorised badge, prior to completion of the access cycle, to prevent another person from using the same badge to enter or exit the HSA. For example, if a person presents an authorised badge to enter the HSA, the system must register that the badge is inside the HSA and deny access to anyone else who tries to use the same badge until the person exits the HSA with the same badge. References: PCI Card Production Logical Security Requirements, v2.0, April 2019, page 12

According to the PCI Card Production and Provisioning Physical Security Requirements, the vendor must have an alarm system that monitors and detects unauthorized access to the card production and provisioning facilities, and that alerts the security control room or a central monitoring service. The alarm system must also be able to identify the location and cause of the alarm, and allow authorized personnel to reset it. The alarm system must be operational 24/7, and must be tested at least annually. The vendor must also have procedures to respond to alarms and incidents, and to report them to the relevant parties. If the alarm system does not send alerts to the security control room, or a central monitoring service, during working hours, the vendor may not be able to comply with these requirements, and may not be able to prevent, detect, or respond to unauthorized access or security breaches. This may cause a problem for their assessment, as they may not meet the PCI Card Production and Provisioning Physical Security Requirements. References: PCI Card Production and Provisioning Physical Security Requirements and Test Procedures v3.0, January 2022, pages 9-101