Wednesday, July 14, 2010

Visa Publishes Guidance on Tokenization, Data Retention

Visa today released its latest two of its "best practices" documents dealing with very important topics. You should download them (below) and read them.

The first is Visa's best practices for tokenization. Tokenization is the process whereby you replace a payment card number with a surrogate value or token. A processor or other trusted third party maintains the ability to reverse the token (e.g., a card data vault). The idea is that the token cannot be reversed, and you use it for all subsequent transactions. If done properly, tokenization can reduce your PCI scope.

While not giving you a complete "how to" guide, the paper has some good implementation guidance if you are considering tokenization. Visa titled the paper "Tokenization Version 1.0" and it is open for comment until the end of August. Presumably we may see a revised/clarified version after all comments are in.

The second paper I recommend to you is Visa's Best Practices for Primary Account Number Storage and Truncation. This is my personal favorite. It repeats (and repeats) what I have been saying for years: as a merchant, you have no need to retain a payment card number for exception items like chargebacks and refunds. I could not say it better than Visa's own words:

Due to misinterpretation of Visa dispute processing rules, some acquirers require their merchants to unnecessarily store full Primary Account Numbers (PANs) for exception processing to resolve disputes. The unnecessary storage of full card PAN information by merchants has led to incidents of data compromise, theft or unintended disclosure during disposal. Additional confusion exists due to inconsistent dispute resolution practices by issuers and acquirers in use across different geographies, leading some merchants to conclude that PAN data must be retained for all transactions.

To clarify, Visa does not require merchants to store PANs, but does recommend that merchants rely on their acquirer / processor to manage this information on the merchants’ behalf. Visa also recommends that acquirers / processors evolve their systems to provide merchants with a substitute transaction identifier to reference transaction details (in lieu of using PANs).
Couldn't have said it better myself! If you are storing PAN data for dispute resolution, I hope you are getting something back from you acquirer because you are doing their work.

I regularly run into this urban myth that merchants "Have to retain the PAN for xxx years/months/whatever." Thank you, Visa. Now maybe we can get on with PCI.

2 comments:

  1. Great to see this guidance in print! I did want to mention that you don't necessarily have to outsource tokenization: "A processor or other trusted third party maintains the ability to reverse the token (e.g., a card data vault)." You can host your own solution but I would strongly recommend that you not try to build your own. It is exceedingly difficult to meet all of the requirements. There are packages available that integrate the key management and tokenization solution to form the basic of your vault environment.

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