Call Center Recordings - Version 3

Yesterday (Feb 17) the PCI Council re-revised their call center FAQ with more clarification on whether you may store digital recordings containing the security codes (CVV2, CVC2, etc.).

Here is the text of the FAQ (link here). The first two paragraphs are the explanation that the Council heard the issues from their previous clarification (see here) just a couple of weeks ago. The next two paragraphs are unchanged:

PCI SSC FAQ’s are designed to provide merchants, assessors, acquirers and other Council stakeholders with clear and timely guidance on PCI standards. They are a critical two way communication channel from which the PCI SSC draws valuable market feedback and insight, and is able to share this with the industry. On January 22 2010, as part of the online FAQ feedback and submission process, the regular
review of FAQ language, and inquiries from Participating Organizations the SSC sought to clarify its position on call center audio recordings.

The updates to the FAQ language were intended to eliminate any inconsistencies in implementations of audio recordings in call center environments by providing a higher level of specificity in FAQ guidance. The Council’s position remains that if you can digitally query sensitive authentication data (SAD) contained within audio recordings - if SAD is easily accessible - then it must not be stored. As a result of additional market feedback, on February 17, 2010 the SSC modified the new language to further clarify its position on audio recordings. Please find this language below:

This response is intended to provide clarification for call centers that record cardholder data in audio recordings, and applies only to the storage of card validation codes and values (referred to as CAV2, CVC2, CVV2 or CID codes by the payment brands).

It is a violation of PCI DSS requirement 3.2 to store any sensitive authentication data, including card validation codes and values, after authorization even if encrypted.

Now this is where it gets interesting. The phrase "if that data can be queried" is new, and the Council emphasized (bolded) it. This sentence in the previous FAQ ended here. Storage of digital recordings was verboten, period. Now, it looks like there may be some room. The paragraph after is some good advice.

It is therefore prohibited to use any form of digital audio recording (using formats such as wav, mp3 etc) for storing CAV2, CVC2, CVV2 or CID codes after authorization if that data can be queried [Council's emphasis]; recognizing that multiple tools exist that potentially could query a variety of digital recordings.

Where technology exists to prevent recording of these data elements, such technology should be enabled.

The final paragraphs are also changed. Where previously the only exceptions to recordings containing the security codes were analog tapes (as if anybody still used them), now there is much greater leeway. The new FAQ - or FAQ v3 as I call it - now says you can keep the digital recordings so long as you protect them per PCI. The last paragraph is simply recognition that sovereign law supercedes PCI:

If these recordings cannot be data mined, storage of CAV2, CVC2, CVV2 or CID codes after authorization may be permissible as long as appropriate validation has been performed. This includes the physical and logical protections defined in PCI DSS that must still be applied to these call recording formats.

This requirement does not supersede local or regional laws that may govern the retention of audio recordings.

Where does this leave us. Let me try and summarize:

• Call centers can now store digital recordings containing sensitive authentication data like the security codes. Yesterday they couldn't. Last year they couldn't.
  
  
• The PCI Council got sufficient market feedback from the previous FAQ that they took the issue back to the Technical Working Group and the 5 brands. The result is this revised position.
  
  
• Up to this time, the only exception to the rule prohibiting storing the security codes was for system testing, and that had to be tightly controlled. Now call centers can retain tons of digital recordings and protect them per PCI. BTW, if you do this don't even dream of using a simplified SAQ!
  
  
• There are bound to be questions about what it means to have records that "cannot be data mined." Will this mean encryption? Maybe. Does it mean keeping the data offline? Possibly. Should you restrict access? Plan on it. In fact, if you have these recordings I'd plan on getting some expert guidance to make sure not only that you are compliant, but that you are secure!
  

For more information, see this column in StorefrontBacktalk (full disclosure: as you know, I am PCI columnist for SFBT).