If Your Token Vendor Goes Bankrupt, What Happens To Your Data?

Written by Walter Conway
October 7th, 2010

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

What would you do if your tokenization vendor goes out of business or gets acquired by a company with a whole different approach to tokenization? This is the ever awkward but increasingly important question every IT executive looking at tokenization needs to ask.

The reality is that there are many firms in the tokenization space today, and you cannot count on all of them being around forever. Some will change business focus, go out of business, or be acquired. Because there are no standards for tokens across vendors, transferring to another vendor could be difficult. That means retail CIOs need to address what to do if (when?) the unforeseen happens.

You may want to include this eventuality in your annual risk analysis. There are no easy answers. But you need to spend some time confirming the stability of your potential provider and developing a contingency plan if the worst happens.

You also should negotiate a service-level agreement that addresses your tokenization provider’s reliability and fallback processing. Attendees at the recent PCI Community Meeting heard about an encryption vendor that, due to a system glitch, stopped encrypting cardholder data. The company just passed the cleartext PANs back and forth to the merchant. The situation went undiscovered for quite some time, and it resulted in a data compromise.

In a previous column I noted that, as IT executives walk down Tokenization Street on Halloween hoping to receive goodies, they need to ask some questions before holding out their trick-or-treat bags. That is, they should not just accept whatever is put into it. That column highlighted five questions. Number six is the question from above: What happens if your tokenization vendor disappears? We get to four more below, for a total of 10 questions you need to ask before you make your decision.


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Most Recent Comments

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