Terms

RETURN POLICY

No credit or refund will be issued on returned products without prior authorization.

If you are dissatisfied with any product* please contact our Customer Care Department within thirty (30) days of purchase to receive a return preapproval and Return Authorization Number (RAN).  The product ship date is the date of purchase.  We will not accept any package not having been issued a RAN.  All returned products must have prior authorized approval from our Customer Care Department.

 

DAMAGED/DEFECTIVE ITEMS

If you receive a damaged or defective item, contact Customer Service within fourteen (14) days of delivery at 1-800-493-1146.  Please provide Customer Service with your order and item number from your original sales receipt.  Customer Service will also need your e-mail address and phone number.  Alternative Health will make every reasonable effort to replace the item in a timely manner.

 

If there is extensive damage to the packaging, contact a Customer Service Representative immediately at 1-800-493-1146.  Please have your order number available when contacting Customer Service.

 

*There are no returns on books, CD’s or DVD’s except for manufacturer defects. 

You will receive a full refund, minus the shipping, handling, gift wrap, and/or other charges, for unopened items in the original form of payment and merchandise credit for opened items.  Only one opened package of any product is eligible for return.   All products must be returned, unused or used, in good condition and with all paperwork along with the RAN displayed on the outside of the package to ensure full credit. 

If you received a free item as a result of a special promotion or offer it must accompany your return in order to receive a full refund or merchandise credit.  Free items do not count towards merchandise credit or refund.  Example:  If you purchase a buy two, get one free package and return the items for refund or merchandise credit, and one of the products is opened, refund or merchandise credit will only apply to one item.

Shipping and handling charges are non-refundable.  Carefully package the product being returned.  All return shipping charges must be prepaid by you. We cannot accept C.O.D. deliveries.  We must physically receive the return within fourteen (14) days of you receiving a RAN.  You can expect a refund in the same form of payment originally used for purchase within 30 days of our receiving your returned product.  Should your return be because of a manufacturer or shipping error on our part you will be refunded your shipping cost.  Alternative Health reserves the right, at its sole discretion, to reject any return that does not comply with these requirements.  

 

For your protection, we recommend you insure the package in returning any products.  Keep the Return Tracking Number from the package you are returning to ensure we receive the returned product. 

In the case of your bank account being inactive or the purchasing card being inactive we will be unable to send refunds for any product and can exchange this for in-store credit.

Shipping Policy

FLAT RATE SHIPPING Orders are generally shipped within 3-5 days using USPS or UPS unless product is backordered. Flat rate shipping fee of $7.95 applies to orders shipping in the USA. Optional: We do not ship outside of USA at this time.

 

 Privacy Policy
==============

Last updated: August 22, 2024

This Privacy Policy describes Our policies and procedures on the collection,
use and disclosure of Your information when You use the Service and tells You
about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the
Service, You agree to the collection and use of information in accordance with
this Privacy Policy. This Privacy Policy has been created with the help of the
[Free Privacy Policy Generator](https://www.freeprivacypolicy.com/free-
privacy-policy-generator/).

Interpretation and Definitions
------------------------------

Interpretation
~~~~~~~~~~~~~~

The words of which the initial letter is capitalized have meanings defined
under the following conditions. The following definitions shall have the same
meaning regardless of whether they appear in singular or in plural.

Definitions
~~~~~~~~~~~

For the purposes of this Privacy Policy:

* Account means a unique account created for You to access our Service or
parts of our Service.

* Affiliate means an entity that controls, is controlled by or is under
common control with a party, where "control" means ownership of 50% or
more of the shares, equity interest or other securities entitled to vote
for election of directors or other managing authority.

* Company (referred to as either "the Company", "We", "Us" or "Our" in this
Agreement) refers to Saxion Supplements LLC and Nutri-span LLC, 4808 W
157th St Overland Park KS 66224.

* Cookies are small files that are placed on Your computer, mobile device or
any other device by a website, containing the details of Your browsing
history on that website among its many uses.

* Country refers to: Kansas, United States

* Device means any device that can access the Service such as a computer, a
cellphone or a digital tablet.

* Personal Data is any information that relates to an identified or
identifiable individual.

* Service refers to the Website.

* Service Provider means any natural or legal person who processes the data
on behalf of the Company. It refers to third-party companies or
individuals employed by the Company to facilitate the Service, to provide
the Service on behalf of the Company, to perform services related to the
Service or to assist the Company in analyzing how the Service is used.

* Usage Data refers to data collected automatically, either generated by the
use of the Service or from the Service infrastructure itself (for example,
the duration of a page visit).

* Website refers to Saxion Supplements, accessible from
[www.saxionsupplements.com](www.saxionsupplements.com)

* You means the individual accessing or using the Service, or the company,
or other legal entity on behalf of which such individual is accessing or
using the Service, as applicable.


Collecting and Using Your Personal Data
---------------------------------------

Types of Data Collected
~~~~~~~~~~~~~~~~~~~~~~~

Personal Data
*************

While using Our Service, We may ask You to provide Us with certain personally
identifiable information that can be used to contact or identify You.
Personally identifiable information may include, but is not limited to:

* Email address

* First name and last name

* Phone number

* Address, State, Province, ZIP/Postal code, City

* Usage Data


Usage Data
**********

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol
address (e.g. IP address), browser type, browser version, the pages of our
Service that You visit, the time and date of Your visit, the time spent on
those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect
certain information automatically, including, but not limited to, the type of
mobile device You use, Your mobile device unique ID, the IP address of Your
mobile device, Your mobile operating system, the type of mobile Internet
browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our
Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies
*********************************

We use Cookies and similar tracking technologies to track the activity on Our
Service and store certain information. Tracking technologies used are beacons,
tags, and scripts to collect and track information and to improve and analyze
Our Service. The technologies We use may include:

* Cookies or Browser Cookies. A cookie is a small file placed on Your
Device. You can instruct Your browser to refuse all Cookies or to indicate
when a Cookie is being sent. However, if You do not accept Cookies, You
may not be able to use some parts of our Service. Unless you have adjusted
Your browser setting so that it will refuse Cookies, our Service may use
Cookies.
* Web Beacons. Certain sections of our Service and our emails may contain
small electronic files known as web beacons (also referred to as clear
gifs, pixel tags, and single-pixel gifs) that permit the Company, for
example, to count users who have visited those pages or opened an email
and for other related website statistics (for example, recording the
popularity of a certain section and verifying system and server
integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on
Your personal computer or mobile device when You go offline, while Session
Cookies are deleted as soon as You close Your web browser. Learn more about
cookies on the [Free Privacy Policy
website](https://www.freeprivacypolicy.com/blog/sample-privacy-policy-
template/#Use_Of_Cookies_And_Tracking) article.

We use both Session and Persistent Cookies for the purposes set out below:

* Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services
available through the Website and to enable You to use some of its
features. They help to authenticate users and prevent fraudulent use of
user accounts. Without these Cookies, the services that You have asked for
cannot be provided, and We only use these Cookies to provide You with
those services.

* Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies
on the Website.

* Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You use
the Website, such as remembering your login details or language
preference. The purpose of these Cookies is to provide You with a more
personal experience and to avoid You having to re-enter your preferences
every time You use the Website.

For more information about the cookies we use and your choices regarding
cookies, please visit our Cookies Policy or the Cookies section of our Privacy
Policy.

Use of Your Personal Data
~~~~~~~~~~~~~~~~~~~~~~~~~

The Company may use Personal Data for the following purposes:

* To provide and maintain our Service , including to monitor the usage of
our Service.

* To manage Your Account: to manage Your registration as a user of the
Service. The Personal Data You provide can give You access to different
functionalities of the Service that are available to You as a registered
user.

* For the performance of a contract: the development, compliance and
undertaking of the purchase contract for the products, items or services
You have purchased or of any other contract with Us through the Service.

* To contact You: To contact You by email, telephone calls, SMS, or other
equivalent forms of electronic communication, such as a mobile
application's push notifications regarding updates or informative
communications related to the functionalities, products or contracted
services, including the security updates, when necessary or reasonable for
their implementation.

* To provide You with news, special offers and general information about
other goods, services and events which we offer that are similar to those
that you have already purchased or enquired about unless You have opted
not to receive such information.

* To manage Your requests: To attend and manage Your requests to Us.

* For business transfers: We may use Your information to evaluate or conduct
a merger, divestiture, restructuring, reorganization, dissolution, or
other sale or transfer of some or all of Our assets, whether as a going
concern or as part of bankruptcy, liquidation, or similar proceeding, in
which Personal Data held by Us about our Service users is among the assets
transferred.

* For other purposes : We may use Your information for other purposes, such
as data analysis, identifying usage trends, determining the effectiveness
of our promotional campaigns and to evaluate and improve our Service,
products, services, marketing and your experience.


We may share Your personal information in the following situations:

* With Service Providers: We may share Your personal information with
Service Providers to monitor and analyze the use of our Service, to
contact You.
* For business transfers: We may share or transfer Your personal information
in connection with, or during negotiations of, any merger, sale of Company
assets, financing, or acquisition of all or a portion of Our business to
another company.
* With Affiliates: We may share Your information with Our affiliates, in
which case we will require those affiliates to honor this Privacy Policy.
Affiliates include Our parent company and any other subsidiaries, joint
venture partners or other companies that We control or that are under
common control with Us.
* With business partners: We may share Your information with Our business
partners to offer You certain products, services or promotions.
* With other users: when You share personal information or otherwise
interact in the public areas with other users, such information may be
viewed by all users and may be publicly distributed outside.
* With Your consent : We may disclose Your personal information for any
other purpose with Your consent.

Retention of Your Personal Data
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

The Company will retain Your Personal Data only for as long as is necessary
for the purposes set out in this Privacy Policy. We will retain and use Your
Personal Data to the extent necessary to comply with our legal obligations
(for example, if we are required to retain your data to comply with applicable
laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage
Data is generally retained for a shorter period of time, except when this data
is used to strengthen the security or to improve the functionality of Our
Service, or We are legally obligated to retain this data for longer time
periods.

Transfer of Your Personal Data
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Your information, including Personal Data, is processed at the Company's
operating offices and in any other places where the parties involved in the
processing are located. It means that this information may be transferred to —
and maintained on — computers located outside of Your state, province, country
or other governmental jurisdiction where the data protection laws may differ
than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such
information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data
is treated securely and in accordance with this Privacy Policy and no transfer
of Your Personal Data will take place to an organization or a country unless
there are adequate controls in place including the security of Your data and
other personal information.

Delete Your Personal Data
~~~~~~~~~~~~~~~~~~~~~~~~~

You have the right to delete or request that We assist in deleting the
Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You
from within the Service.

You may update, amend, or delete Your information at any time by signing in to
Your Account, if you have one, and visiting the account settings section that
allows you to manage Your personal information. You may also contact Us to
request access to, correct, or delete any personal information that You have
provided to Us.

Please note, however, that We may need to retain certain information when we
have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

Business Transactions
*********************

If the Company is involved in a merger, acquisition or asset sale, Your
Personal Data may be transferred. We will provide notice before Your Personal
Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement
***************

Under certain circumstances, the Company may be required to disclose Your
Personal Data if required to do so by law or in response to valid requests by
public authorities (e.g. a court or a government agency).

Other legal requirements
************************

The Company may disclose Your Personal Data in the good faith belief that such
action is necessary to:

* Comply with a legal obligation
* Protect and defend the rights or property of the Company
* Prevent or investigate possible wrongdoing in connection with the Service
* Protect the personal safety of Users of the Service or the public
* Protect against legal liability

Security of Your Personal Data
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

The security of Your Personal Data is important to Us, but remember that no
method of transmission over the Internet, or method of electronic storage is
100% secure. While We strive to use commercially acceptable means to protect
Your Personal Data, We cannot guarantee its absolute security.

Children's Privacy
------------------

Our Service does not address anyone under the age of 13. We do not knowingly
collect personally identifiable information from anyone under the age of 13.
If You are a parent or guardian and You are aware that Your child has provided
Us with Personal Data, please contact Us. If We become aware that We have
collected Personal Data from anyone under the age of 13 without verification
of parental consent, We take steps to remove that information from Our
servers.

If We need to rely on consent as a legal basis for processing Your information
and Your country requires consent from a parent, We may require Your parent's
consent before We collect and use that information.

Links to Other Websites
-----------------------

Our Service may contain links to other websites that are not operated by Us.
If You click on a third party link, You will be directed to that third party's
site. We strongly advise You to review the Privacy Policy of every site You
visit.

We have no control over and assume no responsibility for the content, privacy
policies or practices of any third party sites or services.

Changes to this Privacy Policy
------------------------------

We may update Our Privacy Policy from time to time. We will notify You of any
changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior
to the change becoming effective and update the "Last updated" date at the top
of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes.
Changes to this Privacy Policy are effective when they are posted on this
page.

Contact Us
----------

If you have any questions about this Privacy Policy, You can contact us:
hsaxion88@aol.com

  

 Information Security Policy  

 

 Saxion Supplements

___________________________________________ 

 

(Company Name) 

      

 

 

 

 

 

 

 

 

 

_________09/2/26__________ 

 

(Date) 

      

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

  

Contents

Introduction 5

Information Security Policy 5

1. Network Security 6
2. Acceptable Use Policy 6

1. Protect Stored Data 7

1. Information Classification 8

1. Access to the Sensitive Cardholder Data 8

1. Physical Security 9

1. Protect Data in Transit 10

1. Disposal of Stored Data 10

1. Security Awareness and Procedures 11

1. 12

1. 16

1. 17

1. 17

Appendix B – List of Devices 22

Appendix C - List of Third Party Service Providers 23

Appendix D – Standalone and P2PE POI Management Policy 23

Appendix E – eCommerce Configuration and Hardening Policy 24

Introduction 

This Policy document encompasses all aspects of security surrounding confidential company information and must be distributed to all company employees. All company employees must read this document in its entirety and sign the form confirming they have read and fully understand this policy. This document will be reviewed and updated by Management on an annual basis or when relevant to include newly developed security standards into the policy and re-distributed to all employees and contractors where applicable.

Information Security Policy

The Company handles sensitive information daily.  Sensitive Information must have adequate safeguards in place to protect the account data that includes cardholder data, cardholder privacy, and to ensure compliance with various regulations, along with guarding the future of the organisation.

The Company commits to respecting the privacy of all its customers and to protecting any customer data from outside parties.  To this end management are committed to maintaining a secure environment in which to process cardholder information so that we can meet these promises.

Employees handling sensitive cardholder data should ensure:

• Handle Company and account data information in a manner that fits with their sensitivity and classification;
• Limit personal use of the Company information and telecommunication systems and ensure it doesn’t interfere with your job performance;
• The Company reserves the right to monitor, access, review, audit, copy, store, or delete any electronic communications, equipment, systems and network traffic for any purpose;
• Do not use e-mail, internet and other Company resources to engage in any action that is offensive, threatening, discriminatory, defamatory, slanderous, pornographic, obscene, harassing or illegal;
• Do not disclose personnel information unless authorised;
• Protect sensitive account data including cardholder information;
• Keep passwords and accounts secure;
• Request approval from management prior to establishing any new software or hardware, third party connections, etc.; 
• Do not install unauthorised software or hardware, including modems and wireless access unless you have explicit management approval;
• Always leave desks clear of sensitive cardholder data and lock computer screens when unattended;
• Information security incidents must be reported, without delay, to the individual responsible for incident response locally – Please find out who this is.
• Attend security awareness training on an annual basis

We each have a responsibility for ensuring our company’s systems and data are protected from unauthorised access and improper use.  If you are unclear about any of the policies detailed herein you should seek advice and guidance from your line manager.

1. Network Security

A high-level network diagram of the network is maintained and reviewed on a yearly basis.  The network diagram provides a high level overview of the cardholder data environment (CDE), which at a minimum shows the connections in and out of the CDE.  Critical system components within the CDE, such as POI/POS devices, databases, eCommerce web servers, re-direction/iFrame servers, etc., and any other necessary payment components, as applicable should also be illustrated. 

 

In addition, ASV should be performed and completed by a PCI SSC Approved Scanning Vendoron a quarterly basis (every 90-92 days), where applicable.  Evidence of these scans should be maintained for a period of 18 months. For eCommerce, the scans need to include the re-direction/iFrame servers at a minimum.

For standalone-dialup terminals:

For P2PE solutions:

For eCommerce that use re-direction/iFrame to a hosted payment page: see Appendix D

1. Acceptable Use Policy

Management’s intentions for publishing an Acceptable Use Policy are not to impose restrictions that are contrary to the Company’s established culture of openness, trust and integrity. Management is committed to protecting the employees, partners and the Company from illegal or damaging actions, either knowingly or unknowingly by individuals. The Company will maintain an approved list of technologies and devices and personnel with access to such devices as detailed in Appendix B.

• Employees are responsible for exercising good judgment regarding the reasonableness of personal use.
• Employees should take all necessary steps to prevent unauthorized access to confidential data which includes account data/card holder data. 
• Keep passwords secure and do not share accounts. Authorized users are responsible for the security of their passwords and accounts. 
• All PCs, laptops and workstations should be secured with a password-protected screensaver with the automatic activation feature. 
• All POS and POI/PIN entry devices should be appropriately protected and secured so they cannot be tampered or altered.
• The List of Devices in Appendix B will be regularly updated when devices are modified, added or decommissioned.  A stocktake of devices will be regularly performed and devices inspected to identify any potential tampering or substitution of devices.  
• Users should be trained in the ability to identify any suspicious behaviour where any tampering or substitution may be performed.  Any suspicious behaviour will be reported accordingly.
• Information contained on portable computers is especially vulnerable, special care should be exercised. 
• Postings by employees from a Company email address to newsgroups should contain a disclaimer stating that the opinions expressed are strictly their own and not necessarily those of the Company, unless posting is in the course of business duties. 
• Employees must use extreme caution when opening e-mail attachments received from unknown senders, which may contain viruses, e-mail bombs, Trojan horse code, or phishing attacks. 

1. Protect Stored Data  

• The Company and its employees are not to store cardholder data in form of PAN or sensitive authentication data in electronic format at all.
• All sensitive account data including cardholder data stored and handled in hard copy by the Company and its employees must be securely protected against unauthorised use at all times. Any sensitive card data that is no longer required by the Company for business reasons must be discarded in a secure and irrecoverable manner.
• If there is no specific need to see the full PAN (Primary Account Number), it has to be masked when displayed and showing six first and last four numbers of PAN maximum.
• PAN'S which are not protected as stated above should not be sent to the outside network via end user messaging technologies like email, chats, ICQ messenger etc.,

It is strictly prohibited to store: 

1. The contents of the payment card magnetic stripe (track data) or chip equivalent track data on any media whatsoever.  
2. The CVV2/CVC2/CAV2/CID (the 3 or 4 digit number on the signature panel on the reverse of the payment card) on any media whatsoever.  
3. The PIN or the encrypted PIN Block under any circumstance.

1. Information Classification

Data and media containing data must always be labelled to indicate sensitivity level.

• Confidential data might include information assets for which there are legal requirements for preventing disclosure or financial penalties for disclosure, or data that would cause severe damage to the Company if disclosed or modified.  Confidential data includes account data /  cardholder data.
• Internal Use data might include information that the data owner feels should be protected to prevent unauthorized disclosure. 
• Public data is information that may be freely disseminated.

1. Access to the Sensitive Cardholder Data

All Access to sensitive cardholder should be controlled and authorised. Any job functions that require access to cardholder data should be clearly defined.

• Any display of the account data / card holder should be restricted at a minimum to the first 6 and the last 4 digits of the primary account number (PAN) .
• Access to sensitive cardholder information such as PAN’s, personal information and business data is restricted to employees that have a legitimate need to view such information. 
• No other employees should have access to this confidential data unless they have a genuine business need. 
• If cardholder data is shared with a Service Provider (3^rd party) then a list of such Service Providers will be maintained as detailed in Appendix C.
• The Company will ensure a written agreement that includes an acknowledgement is in place that the Service Provider will be responsible for the for the cardholder data that the Third Party Service Provider (TPSP) possess.
• The Company will ensure that a there is an established process, including proper due diligence is in place, before engaging with a TPSP.
• The Company will have a process in place to monitor the PCI DSS compliance status of the TPSP.
• The Company need to ensure that the responsibilities for ensuring the security of account data / cardholder data is defined between the company and a TPSP. This need to be documented in a responsibility matrix.

1. Physical Security  

Access to sensitive information in both hard and soft media format must be physically restricted to prevent unauthorised individuals from obtaining sensitive data. 

 

• Media is defined as any printed or handwritten paper, received faxes, floppy disks, back-up tapes, computer hard drive, etc.  
• Media containing sensitive cardholder information must be handled and distributed in a secure manner by trusted individuals.  
• Visitors must always be escorted by a trusted employee when in areas that hold sensitive cardholder information. 
• Procedures must be in place to help all personnel easily distinguish between employees and visitors, especially in areas where account data including cardholder data is accessible. “Employee” refers to full-time and part-time employees, temporary employees and personnel, and consultants who are “resident” on Company sites. A “visitor” is defined as a vendor, guest of an employee, service personnel, or anyone who needs to physically enter the premises for a short duration, usually not more than one day.
• A list of devices including the Point of Interaction (POI) Terminals that accept payment card data should be maintained.
• The list should include make, model and location of the device (POI).
• The list should have the serial number or a unique identifier of the device(POI).
• The list should be updated when devices (POI’s) are added, removed or relocated.
• POS devices surfaces are periodically inspected to detect tampering or substitution. 
• Personnel using the devices should be trained and aware of handling the POI devices
• Personnel using the devices should verify the identity of any third party personnel claiming to repair or run maintenance tasks on the devices (POI’s), install new devices (POI’s) or replace devices (POI’s).
• Personnel using the devices should be trained to report suspicious behaviour and indications of tampering of the devices (POI’s) to the appropriate personnel. The Company sites. A “visitor” is defined as a vendor, guest of an employee, service personnel, or anyone who needs to enter the premises for a short duration, usually not more than one day.
• Strict control is maintained over the external or internal distribution of any media containing card holder data and has to be approved by management
• Strict control is maintained over the storage and accessibility of media.
• All computer that store sensitive cardholder data must have a password protected screensaver enabled to prevent unauthorised use. 

1. Protect Data in Transit  

All sensitive cardholder data must be protected securely if it is to be transported physically or electronically. 

 

• Card holder data (PAN, track data, etc.) must never be sent over the internet via email, instant chat or any other end user technologies.
• If there is a business justification to send cardholder data via email or by any other mode then it should be done after authorization and by using a strong encryption mechanism (i.e. – AES encryption, PGP encryption, IPSEC, etc.).    
• The transportation of media containing sensitive cardholder data to another location must be authorised by management, logged and inventoried before leaving the premises. Only secure courier services may be used for the transportation of such media. The status of the shipment should be monitored until it has been delivered to its new location. 

1. Disposal of Stored Data

• All data must be securely disposed of when no longer required by the Company, regardless of the media or application type on which it is stored.
• An automatic process must exist to permanently delete on-line data, when no longer required.
• All hard copies of cardholder data must be manually destroyed when no longer required for valid and justified business reasons. A quarterly process must be in place to confirm that all non-electronic cardholder data has been appropriately disposed of in a timely manner.
• The Company will have procedures for the destruction of hardcopy (paper) materials. These will require that all hardcopy materials are crosscut shredded, incinerated or pulped so they cannot be reconstructed.
• The Company will have documented procedures for the destruction of electronic media. These will require:
• All cardholder data on electronic media must be rendered unrecoverable when deleted e.g. through degaussing or electronically wiped using military grade secure deletion processes or the physical destruction of the media;
• If secure wipe programs are used, the process must define the industry accepted standards followed for secure deletion.
• All cardholder information awaiting destruction must be held in lockable storage containers clearly marked “To Be Shredded” - access to these containers must be restricted.

1. Security Awareness and Procedures  

The policies and procedures outlined below must be incorporated into company practice to maintain a high level of security awareness. The protection of sensitive data demands regular training of all employees and contractors. 

 

• Review handling procedures for sensitive information and hold periodic security awareness meetings to incorporate these procedures into day to day company practice. 
• Distribute this security policy document to all company employees to read. It is required that all employees confirm that they understand the content of this security policy document by signing an acknowledgement form (see Appendix A). 
• All employees that handle sensitive information will undergo background checks (such as criminal and credit record checks, within the limits of the local law) before they commence their employment with the Company. 
• All third parties with access to credit card account numbers are contractually obligated to comply with card association security standards (PCI/DSS).  
• Company security policies must be reviewed annually and updated as needed.  

 

10. Credit Card (PCI) Security Incident Response Plan

• The Company PCI Security Incident Response Team (PCI Response Team) is comprised of the Information Security Officer and Merchant Services. The Company PCI security incident response plan is as follows:

1. Each department must report an incident to the Information Security Officer (preferably) or to another member of the PCI Response Team. 
2. That member of the team receiving the report will advise the PCI Response Team of the incident. 
3. The PCI Response Team will investigate the incident and assist the potentially compromised department in limiting the exposure of cardholder data and in mitigating the risks associated with the incident. 
4. The PCI Response Team will resolve the problem to the satisfaction of all parties involved, including reporting the incident and findings to the appropriate parties (credit card associations, credit card processors, etc.) as necessary. 
5. The PCI Response Team will determine if policies and processes need to be updated to avoid a similar incident in the future, and whether additional safeguards are required in the environment where the incident occurred, or for the institution. 

The Company PCI Security Incident Response Team (or equivalent in your organisation):

CIO
Communications Director
Compliance Officer
Counsel
Information Security Officer
Collections & Merchant Services
Risk Manager

Information Security PCI Incident Response Procedures:

• A department that reasonably believes it may have an account breach, or a breach of cardholder information or of systems related to the PCI environment in general, must inform the Company PCI Incident Response Team. After being notified of a compromise, the PCI Response Team, along with other designated staff, will implement the PCI Incident Response Plan to assist and augment departments’ response plans.

Incident Response Notification

Escalation Members (or equivalent in your company):

Escalation – First Level:

Information Security Officer Controller

Executive Project Director for Credit Collections and Merchant Services Legal Counsel

Risk Manager

Director of the Company Communications

Escalation – Second Level:

The Company President

Executive Cabinet

Internal Audit

Auxiliary members as needed

      External Contacts (as needed)

Merchant Provider Card Brands

Internet Service Provider (if applicable)

Internet Service Provider of Intruder (if applicable) Communication Carriers (local and long distance) Business Partners

Insurance Carrier

External Response Team as applicable (CERT Coordination Center 1, etc) Law Enforcement Agencies as applicable inn local jurisdiction

In response to a systems compromise, the PCI Response Team and designees will:

1. Ensure compromised system/s is isolated on/from the network. 
2. Gather, review and analyze the logs and related information from various central and local safeguards and security controls 
3. Conduct appropriate forensic analysis of compromised system. 
4. Contact internal and external departments and entities as appropriate. 
5. Make forensic and log analysis available to appropriate law enforcement or card industry security personnel, as required. 
6. Assist law enforcement and card industry security personnel in investigative processes, including in prosecutions.

The credit card companies have individually specific requirements that the Response Team must address in reporting suspected or confirmed breaches of cardholder data. See below for these requirements.

Incident Response notifications to various card schemes  

1. In the event of a suspected security breach, alert the information security officer or your line manager immediately.  
2. The security officer will carry out an initial investigation of the suspected security breach.  
3. Upon confirmation that a security breach has occurred, the security officer will alert management and begin informing all relevant parties that may be affected by the compromise.   

 VISA Steps

If the data security compromise involves credit card account numbers, implement the following procedure: 

• Shut down any systems or processes involved in the breach to limit the extent, and prevent further exposure.  
• Alert all affected parties and authorities such as the Merchant Bank (your Bank), Visa Fraud Control, and the law enforcement. 
• Provide details of all compromised or potentially compromised card numbers to Visa Fraud Control within 24 hrs.  
• For more Information visit: http://usa.visa.com/business/accepting_visa/ops_risk_management/cisp_if_ compromised.html  

Visa Incident Report Template

This report must be provided to VISA within 14 days after initial report of incident to VISA. The following report content and standards must be followed when completing the incident report. Incident report must be securely distributed to VISA and Merchant Bank. Visa will classify the report as “VISA Secret”*.

1. Executive Summary 

1. Include overview of the incident 
2. Include RISK Level(High, Medium, Low) 
3. Determine if compromise has been contained 
1. Background 
2. Initial Analysis 
3. Investigative Procedures

1. Include forensic tools used during investigation 
1. Findings 
1. Number of accounts at risk, identify those stores and compromised 

1. Type of account information at risk 
2. Identify ALL systems analyzed. Include the following: 

• Domain Name System (DNS) names 

• Internet Protocol (IP) addresses 

• Operating System (OS) version 

• Function of system(s) 

1. Identify ALL compromised systems. Include the following: 

• DNS names 

• IP addresses 

• OS version 

• Function of System(s) 

1. Timeframe of compromise 

1. Any data exported by intruder 
2. Establish how and source of compromise 
3. Check all potential database locations to ensure that no CVV2, Track 1 or Track 2 data is stored anywhere, whether encrypted or unencrypted (e.g., duplicate or backup tables or databases, databases used in development, stage or testing environments, data on software engineers’ machines, etc.) 
4. If applicable, review VisaNet endpoint security and determine risk 
1. Compromised Entity Action
2. Recommendations

1. Contact(s) at entity and security assessor performing investigation

*This classification applies to the most sensitive business information, which is intended for use within VISA. Its unauthorized disclosure could seriously and adversely impact VISA, its employees, member banks, business partners, and/or the Brand.

MasterCard Steps:

1. Within 24 hours of an account compromise event, notify the MasterCard Compromised Account Team via phone at 1-636-722-4100. 
2. Provide a detailed written statement of fact about the account compromise (including the contributing circumstances) via secured e-mail to  compromised_account_team@mastercard.com. 

1. Provide the MasterCard Merchant Fraud Control Department with a complete list of all known compromised account numbers. 
2. Within 72 hours of knowledge of a suspected account compromise, engage the services of a data security firm acceptable to MasterCard to assess the vulnerability of the compromised data and related systems (such as a detailed forensics evaluation). 

1. Provide weekly written status reports to MasterCard, addressing open questions and issues until the audit is complete to the satisfaction of MasterCard. 
2. Promptly furnish updated lists of potential or known compromised account numbers, additional documentation, and other information that MasterCard may request. 

1. Provide finding of all audits and investigations to the MasterCard Merchant Fraud Control department within the required time frame and continue to address any outstanding exposure or recommendation until resolved to the satisfaction of MasterCard. 

Once MasterCard obtains the details of the account data compromise and the list of compromised account numbers, MasterCard will:

1. Identify the issuers of the accounts that were suspected to have been compromised and group all known accounts under the respective parent member IDs. 

1. Distribute the account number data to its respective issuers.

Employees of the company will be expected to report to the security officer for any security related issues. The role of the security officer is to effectively communicate all security policies and procedures to employees within the company and contractors. In addition to this, the security officer will oversee the scheduling of security training sessions, monitor and enforce the security policies outlined in both this document and at the training sessions and finally, oversee the implantation of the incident response plan in the event of a sensitive data compromise. 

Discover Card Steps

1. Within 24 hours of an account compromise event, notify Discover Fraud Prevention at (800) 347-3102 
2. Prepare a detailed written statement of fact about the account compromise including the contributing circumstances 
3. Prepare a list of all known compromised account numbers 

1. Obtain additional specific requirements from Discover Card 

American Express Steps

1. Within 24 hours of an account compromise event, notify American Express Merchant Services at (800) 528-5200 in the U.S. 
2. Prepare a detailed written statement of fact about the account compromise including the contributing circumstances 
3. Prepare a list of all known compromised account numbers Obtain additional specific requirements from American Express

1. Transfer of Sensitive Information Policy

• All third-party companies providing critical services to the Company must provide an agreed Service Level Agreement.
• All third-party companies providing hosting facilities must comply with the Company’s Physical Security and Access Control Policy.
• All third-party companies which have access to Card Holder information must

1. Adhere to the PCI DSS security requirements.
2. Acknowledge their responsibility for securing the Card Holder data.
3. Acknowledge that the Card Holder data must only be used for assisting the completion of a transaction, supporting a loyalty program, providing a fraud control service or for uses specifically required by law.
4. Have appropriate provisions for business continuity in the event of a major disruption, disaster or failure.
5. Provide full cooperation and access to conduct a thorough security review after a security intrusion by a Payment Card industry representative, or a Payment Card industry approved third party.

1. User Access Management

• Access to Company is controlled through a formal user registration process beginning with a formal notification from HR or from a line manager. 
• Each user is identified by a unique user ID so that users can be linked to and made responsible for their actions. The use of group IDs is only permitted where they are suitable for the work carried out.
• There is a standard level of access; other services can be accessed when specifically authorized by HR/line management. 
• The job function of the user decides the level of access the employee has to cardholder data
• A request for service must be made in writing (email or hard copy) by the newcomer’s line manager or by HR. The request is free format, but must state: 

Name of person making request;

Job title of the newcomers and workgroup; 

Start date; 

Services required (default services are: MS Outlook, MS Office and Internet access).

• Each user will be given a copy of their new user form to provide a written statement of their access rights, signed by an IT representative after their induction procedure. The user signs the form indicating that they understand the conditions of access. 
• Access to all the Company systems is provided by IT and can only be started after proper procedures are completed. 

• As soon as an individual leaves the Company employment, all his/her system logons must be immediately revoked and account must be disabled and removed. 
• As part of the employee termination process HR (or line managers in the case of contractors) will inform IT operations of all leavers and their date of leaving. 

1. 13.Access Control Policy

• Access Control systems are in place to protect the interests of all users of the Company computer systems by providing a safe, secure and readily accessible environment in which to work.
• The Company will provide all employees and other users with the information they need to carry out their responsibilities in an as effective and efficient manner as possible.
• Generic or group IDs shall not normally be permitted, but may be granted under exceptional circumstances if sufficient other controls on access are in place.
• The allocation of privilege rights (e.g. local administrator, domain administrator, super-user, root access) shall be restricted and controlled, and authorization provided jointly by the system owner and IT Services. Technical teams shall guard against issuing privilege rights to entire teams to prevent loss of confidentiality.
• Access rights will be accorded following the principles of least privilege and need to know.
• Every user should attempt to maintain the security of data at its classified level even if technical security mechanisms fail or are absent.
• Users electing to place information on digital media or storage devices or maintaining a separate database must only do so where such an action is in accord with the data’s classification.
• Users are obligated to report instances of non-compliance to the Company CISO.
• Access to the Company IT resources and services will be given through the provision of a unique Active Directory account and complex password.
• No access to any the Company IT resources and services will be provided without prior authentication and authorization of a user’s the Company Windows Active Directory account.
• Password issuing, strength requirements, changing and control will be managed through formal processes. Password length, complexity and expiration times will be controlled through Windows Active Directory Group Policy Objects. 
• Password: 8 Characters, Complex, Unique and Change at first use, not re-usable, change every 90 days.
• Access to Confidential, Restricted and Protected information will be limited to authorised persons whose job responsibilities require it, as determined by the data owner or their designated representative. Requests for access permission to be granted, changed or revoked must be made in writing.
• Users are expected to become familiar with and abide by the Company policies, standards and guidelines for appropriate and acceptable usage of the networks and systems.
• Access for remote users shall be subject to authorization by IT Services and be provided in accordance with the Remote Access Policy and the Information Security Policy. No uncontrolled external access shall be permitted to any network device or networked system.
• Access to data is variously and appropriately controlled according to the data classification levels described in the Information Security Management Policy.
• Access control methods include logon access rights, Windows share and NTFS permissions, user account privileges, server and workstation access rights, firewall permissions, IIS intranet/extranet authentication rights, SQL database rights, isolated networks and other methods as necessary.
• A formal process shall be conducted at regular intervals by system owners and data owners in conjunction with IT Services to review users’ access rights. The review shall be logged and IT Services shall sign off the review to give authority for users’ continued access rights.