Attachment_C_-_Sikich_PCI_DSS_v3.2.1_AOC_-_Service_Providers_--_TKC_Holdings_2022.12.12_countersigned.pdf

Payment Card Industry (PCI) Data Security Standard

Attestation of Compliance for Onsite Assessments – Service Providers Version 3.2.1 (released June 2018 by the PCI SSC)

TKC Holdings, Inc.

December 12, 2022

PCI DSS v3.2.1 Attestation of Compliance for Onsite Assessments – Service Providers, Rev. 1.0 June 2018

© 2006-2018 PCI Security Standards Council, LLC. All Rights Reserved. Page 1

Section 1: Assessment Information

Instructions for Submission

This Attestation of Compliance must be completed as a declaration of the results of the service provider’s assessment with the Payment Card Industry Data Security Standard Requirements and Security

Assessment Procedures (PCI DSS). Complete all sections: The service provider is responsible for ensuring that each section is completed by the relevant parties, as applicable. Contact the requesting payment brand for reporting and submission procedures.

Part 1. Service Provider and Qualified Security Assessor Information

Part 1a. Service Provider Organization Information

Company Name: TKC Holdings, Inc. DBA (doing business as):

Keefe Group, Inc.;

Access Catalog, Inc. DBA

Access Securepak;

Access Corrections, Inc.

DBA Access Secure

Deposits, DBA Smart

Deposit;

Advanced Technologies

Group, LLC DBA Corrlinks;

Courtesy Products, LLC

DBA Café Valet;

Inmate Calling Solutions, LLC DBA ICSolutions;

Trinity Services Group DBA

MyCarePack;

The Whole Shabang

(registered trademark of

Keefe Group, Inc.)

Contact Name: Ryan Essner Title: Chief Information Security

Officer

Telephone: 314.214.2700 E-mail: compliance@ tkcholdings.com

Business Address: 1260 Andes Blvd City: St. Louis

State/Province: MO Country: USA Zip: 63132

URL: www.tkcholdings.com

Part 1b. Qualified Security Assessor Company Information (if applicable)

Company Name: Sikich LLP

Lead QSA Contact Name: Eric Foss Title: Senior Consultant

Telephone: 877.403.5227 E-mail: eric.foss@sikich.com

Business Address: 17335 Golf Parkway

Suite 500

City: Brookfield

State/Province: WI Country: USA Zip: 53045

PCI DSS v3.2.1 Attestation of Compliance for Onsite Assessments – Service Providers, Rev. 1.0 June 2018

© 2006-2018 PCI Security Standards Council, LLC. All Rights Reserved. Page 2

URL: www.sikich.com

Part 2. Executive Summary

Part 2a. Scope Verification

Services that were INCLUDED in the scope of the PCI DSS Assessment (check all that apply):

Name of service(s) assessed: Access Corrections, Access Catalog, CorrLinks, ICS, Smart Deposit

Type of service(s) assessed:

Hosting Provider:

Applications / software

Hardware

Infrastructure / Network

Physical space (co-location)

Storage

Web

Security services

3-D Secure Hosting Provider

Shared Hosting Provider

Other Hosting (specify):

Managed Services (specify):

Systems security services

IT support

Physical security

Terminal Management System

Other services (specify):

Payment Processing:

POS / card present

Internet / e-commerce

MOTO / Call Center

ATM

Other processing (specify):

Account Management Fraud and Chargeback Payment Gateway/Switch

Back-Office Services Issuer Processing Prepaid Services

Billing Management Loyalty Programs Records Management

Clearing and Settlement Merchant Services Tax/Government Payments

Network Provider

Others (specify): Utilization of a third party as a token vault; standalone kiosks

Note: These categories are provided for assistance only, and are not intended to limit or predetermine an entity’s service description. If you feel these categories don’t apply to your service, complete “Others.” If you’re unsure whether a category could apply to your service, consult with the applicable payment brand.

PCI DSS v3.2.1 Attestation of Compliance for Onsite Assessments – Service Providers, Rev. 1.0 June 2018

© 2006-2018 PCI Security Standards Council, LLC. All Rights Reserved. Page 3

Part 2a. Scope Verification (continued)

Services that are provided by the service provider but were NOT INCLUDED in the scope of the PCI DSS Assessment (check all that apply):

Name of service(s) not assessed: Not applicable

Type of service(s) not assessed:

Hosting Provider:

Applications / software

Hardware

Infrastructure / Network

Physical space (co-location)

Storage

Web

Security services

3-D Secure Hosting Provider

Shared Hosting Provider

Other Hosting (specify):

Managed Services (specify):

Systems security services

IT support

Physical security

Terminal Management System

Other services (specify):

Payment Processing:

POS / card present

Internet / e-commerce

MOTO / Call Center

ATM

Other processing (specify):

Account Management Fraud and Chargeback Payment Gateway/Switch

Back-Office Services Issuer Processing Prepaid Services

Billing Management Loyalty Programs Records Management

Clearing and Settlement Merchant Services Tax/Government Payments

Network Provider

Others (specify):

Provide a brief explanation why any checked services were not included in the assessment:

Part 2b. Description of Payment Card Business

Describe how and in what capacity your business stores, processes, and/or transmits cardholder data.

TKC Holdings, Inc. (TKC Holdings) and their wholly-owned subsidiaries operated a suite of ecommerce payment platforms, call centers, kiosks and mail order forms that accepted cardholder data (CHD) to facilitate payments for goods and services provided to the general public as well as to inmates housed in facilities across the United States of America.

TKC Holdings developed web applications that accepted CHD from cardholders for ecommerce transactions and transmitted payment information to third parties CardConnect, LLC (CardConnect), Authorize.Net (a subsidiary of Cybersource, a Visa solution), Kount Inc. (Kount) and Bluefin Payment

Systems LLC (Bluefin) using HTTP over TLS v1.2

(HTTPS) to perform tokenization, authorization, settlement and fraud monitoring.

TKC Holdings developed web applications that accepted CHD from cardholders for card-present

PCI DSS v3.2.1 Attestation of Compliance for Onsite Assessments – Service Providers, Rev. 1.0 June 2018

© 2006-2018 PCI Security Standards Council, LLC. All Rights Reserved. Page 4 transactions at kiosks. Kiosks transmitted CHD to

TKC Holdings web servers, which transmitted payment information to third parties using HTTPS to perform tokenization, authorization, settlement and fraud monitoring.

The TKC Holdings proprietary web applications hosted on BigCommerce Pty. Ltd. (BigCommerce) platforms accepted ecommerce payments for Café

Valet and The Whole Shabang products (sold by the

Keefe Group). These applications transmitted payments via HTTPS to BigCommerce’s acquirer and did not access in-scope systems or have the ability to impact the security of the CDE.

TKC Holdings accepted CHD from cardholders at call centers, through mail orders and over the phone using an interactive voice response (IVR) system that transmitted CHD to an application programming interface (API) developed by TKC Holdings, which transmitted the traffic to payment processors for tokenization, authorization and settlement. Call center personnel entered CHD received over the phone directly into the IVR web application, while customer service personnel entered CHD from mail-in forms into the IVR web application.

TKC Holdings did not store CHD electronically. TKC

Holdings received CHD through mail order forms and retained paper records for no longer than 90 days for fraud and chargeback purposes. Following entering payment details, TKC Holdings rendered the CHD unreadable and stored it in a locked filing cabinet in a locked office until destruction.

Describe how and in what capacity your business is otherwise involved in or has the ability to impact the security of cardholder data.

Other than in their capacity transmitting CHD to third parties for fraud investigation purposes, TKC

Holdings did not provide services that were otherwise involved in or had the ability to impact the security of

CHD.

PCI DSS v3.2.1 Attestation of Compliance for Onsite Assessments – Service Providers, Rev. 1.0 June 2018

© 2006-2018 PCI Security Standards Council, LLC. All Rights Reserved. Page 5

Part 2c. Locations

List types of facilities (for example, retail outlets, corporate offices, data centers, call centers, etc.) and a summary of locations included in the PCI DSS review.

Type of facility: Number of facilities of this type Location(s) of facility (city, country):

Example: Retail outlets 3 Boston, MA, USA

Call centers 5 St. Louis, MO, USA

Fort Worth, TX, USA

San Antonio, TX, USA

Aurora, CO USA

Manila, PHL

Data centers 2 St. Louis, MO, USA

Omaha, NE, USA

Corporate offices 1 St. Louis, MO, USA

Part 2d. Payment Applications

Does the organization use one or more Payment Applications? Yes No

Provide the following information regarding the Payment Applications your organization uses:

Payment Application

Name

Version

Number

Application

Vendor

Is application

PA-DSS Listed?

PA-DSS Listing Expiry date (if applicable)

Not applicable N/A N/A Yes No N/A

Part 2e. Description of Environment

Provide a high-level description of the environment covered by this assessment.

For example:

• Connections into and out of the cardholder data environment (CDE).

• Critical system components within the CDE, such as POS devices, databases, web servers, etc., and any other necessary payment components, as applicable.

TKC Holdings supported card-present payments via proprietary kiosk applications that sent credit card data to CardConnect and Bluefin.

TKC Holdings supported card-not-present payments via proprietary web applications that sent credit card data to CardConnect, Authorize.Net and Kount using HTTPS.

The TKC Holdings proprietary applications and standalone kiosks transmitted CHD to third-party processors for authorization and settlement.

Critical system components within the CDE included kiosks, an IVR system, web servers, database servers, firewalls and network routers/switches.

Does your business use network segmentation to affect the scope of your PCI DSS environment?

(Refer to “Network Segmentation” section of PCI DSS for guidance on network segmentation)

Yes No

PCI DSS v3.2.1 Attestation of Compliance for Onsite Assessments – Service Providers, Rev. 1.0 June 2018

© 2006-2018 PCI Security Standards Council, LLC. All Rights Reserved. Page 6

Part 2f. Third-Party Service Providers

Does your company have a relationship with a Qualified Integrator & Reseller (QIR) for the purpose of the services being validated?

Yes No

If Yes:

Name of QIR Company: N/A

QIR Individual Name: N/A

Description of services provided by QIR: N/A

Does your company have a relationship with one or more third-party service providers (for example, Qualified Integrator Resellers (QIR), gateways, payment processors, payment service providers (PSP), web-hosting companies, airline booking agents, loyalty program agents, etc.) for the purpose of the services being validated?

Yes No

If Yes:

Name of service provider: Description of services provided:

BigCommerce Pty. Ltd. Hosting and payment processing services

Bluefin Payment Systems LLC Device encryption and payment gateway

CardConnect, LLC Payment gateway and tokenization services

Imperva, Inc. Web application firewall services

Iron Mountain Information

Management, Inc.

Document shredding services

Kount, Inc. Fraud services

Qualfon Data Services Group, LLC

Call center operations

Qualfon, Philippines Inc. Call center operations

TierPoint, LLC Data center services

Note: Requirement 12.8 applies to all entities in this list.

PCI DSS v3.2.1 Attestation of Compliance for Onsite Assessments – Service Providers, Rev. 1.0 June 2018

© 2006-2018 PCI Security Standards Council, LLC. All Rights Reserved. Page 7

Part 2g. Summary of Requirements Tested

For each PCI DSS Requirement, select one of the following:

• Full – The requirement and all sub-requirements of that requirement were assessed, and no sub-requirements were marked as “Not Tested” or “Not Applicable” in the ROC.

• Partial – One or more sub-requirements of that requirement were marked as “Not Tested” or “Not

Applicable” in the ROC.

• None – All sub-requirements of that requirement were marked as “Not Tested” and/or “Not Applicable” in the ROC.

For all requirements identified as either “Partial” or “None,” provide details in the “Justification for Approach” column, including:

• Details of specific sub-requirements that were marked as either “Not Tested” and/or “Not Applicable” in the ROC

• Reason why sub-requirement(s) were not tested or not applicable

Note: One table to be completed for each service covered by this AOC. Additional copies of this section are available on the PCI SSC website.

Name of Service Assessed: Access Corrections, Access Catalog, CorrLinks, ICS, Smart Deposit

PCI DSS

Requirement

Details of Requirements Assessed

Full Partial None

Justification for Approach

(Required for all “Partial” and “None” responses. Identify which sub-requirements were not tested and the reason.)

Requirement 1: Requirement 1.2.3 was not applicable. TKC Holdings did not have wireless networks that transmitted CHD or had connectivity to in-scope systems.

Requirement 1.3.6 was not applicable. TKC Holdings did not store CHD electronically.

Requirement 2: Requirement 2.1.1 was not applicable. TKC Holdings did not have wireless networks that transmitted CHD or had connectivity to in-scope systems.

Requirement 2.6 was not applicable. TKC Holdings was not a shared hosting provider.

Requirement 3: Requirement 3.4 and its sub-requirement were not applicable. TKC Holdings did not store PAN data electronically.

Requirement 3.5 and its sub-requirements were not applicable. TKC Holdings did not store PAN data electronically or manage encryption keys used to secure CHD.

Requirement 3.6 and its sub-requirements were not applicable. TKC Holdings did not store PAN data electronically or manage encryption keys used to secure CHD.

Requirement 4: Requirement 4.1.1 was not applicable. TKC Holdings did not have wireless networks that transmitted CHD or had connectivity to in-scope systems.

PCI DSS v3.2.1 Attestation of Compliance for Onsite Assessments – Service Providers, Rev. 1.0 June 2018

© 2006-2018 PCI Security Standards Council, LLC. All Rights Reserved. Page 8

Requirement 5: Requirement 5.1.2 was not applicable. TKC Holdings deployed anti-malware software to in-scope Linux systems.

Requirement 6: Requirement 6.4.6 was not applicable. TKC Holdings had not made any changes that they deemed to be significant within the previous 12 months.

Requirement 6.5.3 was not applicable. TKC Holdings did not store CHD electronically.

Requirement 7:

Requirement 8: Requirement 8.1.5 was not applicable. TKC Holdings did not allow vendors to have remote access to in-scope systems.

Requirement 8.5.1 was not applicable. TKC Holdings did not have remote access to customer environments.

Requirement 8.7 was not applicable. TKC Holdings did not store CHD electronically.

Requirement 9: Requirement 9.5.1 was not applicable. TKC Holdings did not store CHD on backup media.

Requirement 9.8.2 was not applicable. TKC Holdings did not write CHD to electronic storage media.

Requirement 9.9.3 was not applicable. TKC Holdings did not have personnel that manned the card reader devices, as they operated as standalone kiosks.

Requirement 10: Requirement 10.2.1 was not applicable. TKC Holdings did not store CHD electronically.

Requirement 10.6.2 was not applicable. TKC Holdings did not have other system components identified as being outside the scope of requirement 10.6.1 and, therefore, reviewed audit trails for all in-scope components on a daily basis.

Requirement 11: Requirement 11.1.1 was not applicable. TKC Holdings prohibited the use of wireless access points on any network with connectivity to the CDE and considered any wireless access point detected to be unauthorized.

Requirement 11.2.3 was not applicable. TKC Holdings had not made any changes that they deemed to be significant within the previous 12 months.

Requirement 12:

Appendix A1: TKC Holdings was not a shared hosting provider.

Appendix A2: TKC Holdings did not use SSL/early TLS for card-present POS POI terminal connections.

PCI DSS v3.2.1 Attestation of Compliance for Onsite Assessments – Service Providers, Rev. 1.0 June 2018

© 2006-2018 PCI Security Standards Council, LLC. All Rights Reserved. Page 9

Section 2: Report on Compliance

This Attestation of Compliance reflects the results of an onsite assessment, which is documented in an accompanying Report on Compliance (ROC).

The assessment documented in this attestation and in the ROC was completed on:

December 5, 2022

Have compensating controls been used to meet any requirement in the ROC? Yes No

Were any requirements in the ROC identified as being not applicable (N/A)? Yes No

Were any requirements not tested? Yes No

Were any requirements in the ROC unable to be met due to a legal constraint? Yes No

PCI DSS v3.2.1 Attestation of Compliance for Onsite Assessments – Service Providers, Rev. 1.0 June 2018

© 2006-2018 PCI Security Standards Council, LLC. All Rights Reserved. Page 10

Section 3: Validation and Attestation Details

Part 3. PCI DSS Validation

This AOC is based on results noted in the ROC dated December 5, 2022.

Based on the results documented in the ROC noted above, the signatories identified in Parts 3b-3d, as applicable, assert(s) the following compliance status for the entity identified in Part 2 of this document

(check one):

Compliant: All sections of the PCI DSS ROC are complete, all questions answered affirmatively, resulting in an overall COMPLIANT rating; thereby TKC Holdings, Inc. has demonstrated full compliance with the PCI DSS.

Non-Compliant: Not all sections of the PCI DSS ROC are complete, or not all questions are answered affirmatively, resulting in an overall NON-COMPLIANT rating, thereby (Service Provider

Company Name) has not demonstrated full compliance with the PCI DSS.

Target Date for Compliance:

An entity submitting this form with a status of Non-Compliant may be required to complete the Action

Plan in Part 4 of this document. Check with the payment brand(s) before completing Part 4.

Compliant but with Legal exception: One or more requirements are marked “Not in Place” due to a legal restriction that prevents the requirement from being met. This option requires additional review from acquirer or payment brand.

If checked, complete the following:

Affected Requirement Details of how legal constraint prevents requirement being met

Part 3a. Acknowledgement of Status

Signatory(s) confirms:

(Check all that apply)

The ROC was completed according to the PCI DSS Requirements and Security Assessment

Procedures, Version 3.2.1, and was completed according to the instructions therein.

All information within the above-referenced ROC and in this attestation fairly represents the results of my assessment in all material respects.

I have confirmed with my payment application vendor that my payment system does not store sensitive authentication data after authorization.

I have read the PCI DSS and I recognize that I must maintain PCI DSS compliance, as applicable to my environment, at all times.

If my environment changes, I recognize I must reassess my environment and implement any additional PCI DSS requirements that apply.

PCI DSS v3.2.1 Attestation of Compliance for Onsite Assessments – Service Providers, Rev. 1.0 June 2018

© 2006-2018 PCI Security Standards Council, LLC. All Rights Reserved. Page 11

Part 3a. Acknowledgement of Status (continued)

No evidence of full track data1, CAV2, CVC2, CID, or CVV2 data2, or PIN data3 storage after transaction authorization was found on ANY system reviewed during this assessment.

ASV scans are being completed by the PCI SSC Approved Scanning Vendor Sikich LLP

Part 3b. Service Provider Attestation

Signature of Service Provider Executive Officer Date: December 12, 2022

Service Provider Executive Officer Name: Ryan Essner Title: CISO

Part 3c. Qualified Security Assessor (QSA) Acknowledgement (if applicable)

If a QSA was involved or assisted with this assessment, describe the role performed:

Sikich LLP provided PCI DSS assessment and consulting services.

Signature of Duly Authorized Officer of QSA Company Date: December 12, 2022

Duly Authorized Officer Name: Eric Foss QSA Company: Sikich LLP

Part 3d. Internal Security Assessor (ISA) Involvement (if applicable)

If an ISA(s) was involved or assisted with this assessment, identify the ISA personnel and describe the role performed:

1 Data encoded in the magnetic stripe or equivalent data on a chip used for authorization during a card-present transaction. Entities may not retain full track data after transaction authorization. The only elements of track data that may be retained are primary account number (PAN), expiration date, and cardholder name.

2 The three- or four-digit value printed by the signature panel or on the face of a payment card used to verify card-not-present transactions.

3 Personal identification number entered by cardholder during a card-present transaction, and/or encrypted PIN block present within the transaction message.

PCI DSS v3.2.1 Attestation of Compliance for Onsite Assessments – Service Providers, Rev. 1.0 June 2018

© 2006-2018 PCI Security Standards Council, LLC. All Rights Reserved. Page 12

Part 4. Action Plan for Non-Compliant Requirements

Select the appropriate response for “Compliant to PCI DSS Requirements” for each requirement. If you answer “No” to any of the requirements, you may be required to provide the date your Company expects to be compliant with the requirement and a brief description of the actions being taken to meet the requirement.

Check with the applicable payment brand(s) before completing Part 4.

PCI DSS

Requirement Description of Requirement

Compliant to PCI

DSS Requirements

(Select One)

Remediation Date and

Actions

(If “NO” selected for any

Requirement) YES NO

Install and maintain a firewall configuration to protect cardholder data

Do not use vendor-supplied defaults for system passwords and other security parameters

3 Protect stored cardholder data

Encrypt transmission of cardholder data across open, public networks

Protect all systems against malware and regularly update anti-virus software or programs

Develop and maintain secure systems and applications

Restrict access to cardholder data by business need to know

Identify and authenticate access to system components

Restrict physical access to cardholder data

Track and monitor all access to network resources and cardholder data

Regularly test security systems and processes

Maintain a policy that addresses information security for all personnel

Appendix A1 Additional PCI DSS Requirements for

Shared Hosting Providers

Appendix A2

Additional PCI DSS Requirements for

Entities using SSL/early TLS for Card-

Present POS POI Terminal Connections