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Oops! My Customer Just Made Me Non-Compliant With PCI

July 13th, 2011

I see this situation all the time.My advice is that merchants should have a process in place to deal with this possibility. First, destroy the offending message. This is critical. By itself, a customer sending his payment-card information does not drag a merchant’s E-mail system into PCI scope if it is not that merchant’s policy or practice to process the transaction. Because E-mail systems remember everything, the idea is for the recipient to delete the message from its inbox and everywhere else it can immediately.

The next step is to contact the customer. By this, I do not mean hit “reply,” which sends the offending card data back through the merchant’s system a second time. The purpose is to tell the customer that transaction cannot be accepted. This is a good time to have a prepared statement worked out in advance that can be sent. That statement should explain the merchant’s policy, why sending card data over open networks is a really bad idea, that the business wants to protect its customers from identity theft and any other messages the merchant wants to convey. Then tell the customer how he can go online, call on the phone or mail his card information to the merchants securely. Treat the situation as an opportunity to communicate with customers.

Above all, the merchant must not process the transaction. Do not even think about it. This is where security training and staff awareness come into action.

If merchants take these steps, this QSA would say their E-mail or similar system is not in scope. If, however, the merchant describes the risks to the offending customer but processes the transaction anyway (“just this one time”), its actions do not match its policy and it is processing transactions by E-mail, SMS, Twitter or whatever. Therefore, those systems are clearly in scope for PCI.

We have patches for security flaws. It is a shame, but we can’t yet patch the human element (I’ve seen a tee-shirt with a particularly unsympathetic statement on this issue). Until that day, merchants need to enforce their policies and make sure their staff training covers a situation where a customer wants to help out a little too much. Handled properly, it can be a positive experience and a good lesson for the customer. Handled poorly, it can lead to an unacceptable expansion of the merchant’s PCI scope, which means it may be the most expensive sale ever made.

What do you do when a customer E-mails or texts their card number to your helpdesk or call center? I’d like to hear about your procedures. Either leave a comment or E-mail me at wconway@403labs.com.


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