So my non-profit, the California Botanical Society, of which I am the volunteer treasurer, was notified by our merchant service provider that we have to complete our self-assessment questionnaire by June 28th. I've read the guidance and learned we need only complete questionnaire SAQ B, because we only use a stand-alone dial-out terminal for our few credit card transactions. We keep no member credit card information in any electronic form, but we do have paper order forms, invoices, and credit card machine tapes that have cardholder data on them. Since our "office staff" consists of a volunteer membership person, a volunteer corresponding secretary, and a work-study student, our processes are pretty informal and, of course, not documented in any way. From my first reading, it looks like we need to do the following to become "compliant:" (1) write an Information Security Policy states defines identification, handling, storage and destruction of cardholder data when it is no longer needed, and that we do not accept cardholder data by way of unencrypted e-mail, (2) document that all cardholder data is kept in locked drawers when not in use, (3) verify that the keys that lock the drawers containing cardholder data are unique to our organization, and available only to persons with need to access the data, (4) buy a crosscut shredder to shred the order forms and machine tapes when we no longer need them.
Some of questions on the questionnaire are a little tricky. It looks like they are worded so that if you say "Yes" to every one, then, Yes, you are compliant. For example, "9.7.2 Is the media sent by secured courier or other delivery method that can be accurately tracked?" the obvious compliant answer would be Yes. However, in our case I would answer, "No, we never send media with cardholder data anywhere." Truthful, but the wrong answer for the questionnaire. I was hoping for a place to explain answers. Has anyone been through the web form compliance questionnaire, and was there a place for explanations?
Finally, we have some work to do before we can give compliant answers to all the questions. There is an option to giving truthful, non-compliant answers, and a date by which we can be compliant. For us botanists who should all be out in the field from now until September or so, I'm tempted to say we can be compliant in 9-10 months. But, I wondering if anyone has completed the questionnaire with non-compliant status and a date for compliance, and what was the reaction from your merchant service provider?