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

October 7th, 2010

This question highlights an interesting quirk in PCI DSS. That is, although retailers are required to get their vendors to accept responsibility, there is no corresponding requirement on the part of vendors to provide it. Smart vendors will have no problem addressing this question to a retailer’s satisfaction. If you encounter resistance, you may want to check out some of your many alternatives.

  • When we pull it all together, which tokenization approach is right for my company?
    I like to break this question into three parts.

    First, will you host your token vault containing the (encrypted) PANs and tokens or will a third party hold it? Hosting the vault yourself gives you the most flexibility. Additionally, because all of your PAN data is in one place, you can focus your efforts on protecting it. That vault, though, will be in your PCI scope. Having a third party host the token vault removes it from your scope and may reduce PCI scope the most.

    Then consider the tokenization methodology itself. Are the tokens secure, and do they comply with Visa’s best practices? How much will it cost to upgrade or replace hardware or software to implement the particular tokens?

    Last, consider your tokenization provider. Almost every card processor offers, or soon will offer, tokenization. For the vast majority of small and midsize business, this approach will be a very attractive in terms of both cost and convenience. Larger retailers may prefer the flexibility that comes with controlling their own environment.

    There is much more to tokenization trick-or-treat than we have covered. For example, we have not addressed the importance of securing and restricting access to the token vault, connecting the token vault to your data warehouse, avoiding token collisions with valid PANs, single-use vs. multi-use tokens, running out of token space (there are only so many numbers after all, especially if you retain the last four digits of the PAN) or even the many applications for tokenizing sensitive data outside of PCI DSS.

    What do you think about tokenization and the questions you should ask? I’d like to hear your thoughts and experiences with tokenization. Either leave a comment—whether a trick or a treat—or E-mail me at

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