Evan Schuman's StorefrontBacktalk

A 403 Labs QSA, PCI Columnist Walt Conway has worked in payments and technology for more than 30 years, 10 of them with Visa.

The PCI Council used its December 2011 newsletter to remind merchants and service providers to control physical access to their call centers with video cameras or other devices. This recommendation is both sound security and good advice, and I hope merchants everywhere will take it to heart. As a QSA, I wish the Council had done more than highlight just one particular sub-requirement. There is more to protecting sensitive areas than installing video cameras. The second, and possibly thornier, concern for small and midsize merchants is how effective the reminder is likely to be when many of them mistakenly think they won’t need to follow the advice.

The Council’s electronic newsletter to participating organizations (POs) is a great communication tool. I hope the PO contacts who receive the E-mails distribute them widely throughout their organizations. The PCI Council also notes in its December newsletter that call centers are to be considered “sensitive areas,” just like data centers. That is, call centers “process, transmit and/or store cardholder data” and, therefore, merchants and service providers must protect them from unauthorized physical access.

The Council’s reasoning is that “without physical access controls, unauthorized persons could potentially gain access to the CDE [cardholder data environment] and to sensitive information, or could alter system configurations, introduce vulnerabilities into the network or destroy or steal equipment.”

PCI addresses physical access controls in Requirement 9. The particular sub-requirement highlighted in the newsletter (9.1.1) requires installing video cameras or other access control mechanisms to monitor individual access. The intent is to ensure that all entry/exit points to the call center are controlled and monitored and that you can identify all individuals who enter the call center.

As a QSA, I find myself wishing the PCI Council had gone a bit further. The Council reminded POs that their call centers are sensitive areas, but it stopped short of saying that call centers—just like server rooms—should be subject to all of Requirement 9.

Requirement 9 has two main parts. The first four sub-requirements (9.1–9.4) address restricting physical access to the facility and systems, while the last six sub-requirements (9.5–9.10) deal with protecting storage media, both paper and electronic.

Because the Council highlighted 9.1.1 in its “FAQ of the Month,” I imagine it is getting a lot of questions about this particular requirement. However, I would prefer the Council had gone a bit further and highlighted the need for call centers to comply with all of 9.1 through 9.4, as appropriate, and not just the one sub-requirement. For example, it seems that if call centers are sensitive areas, managers and users must lock consoles to prevent unauthorized use (9.1), restrict wireless and handheld devices (9.1.3), implement a badging system (9.2) that identifies employees and visitors (9.3) and maintain a visitor log (9.4).

I feel confident that Level 1 merchant and service provider call centers likely meet all these requirements. Many other call centers, however, do not meet the access control requirements. Once more, they are unlikely to do so. The reason they won’t meet the requirements is that these call centers mistakenly think Requirement 9.1.1 does not apply to them.