New PCI Call Center Recording Advice: Make SAD Go Away

Written by Walter Conway
March 23rd, 2011

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’s latest statement on call center voice recordings includes nothing new in terms of the council’s position, but it does offer some interesting tactics for sharply reducing how much sensitive authentication data (SAD) remains in those recordings.

The council’s unchanged position is simply that if you have recordings with cardholder data, they are in your PCI scope. But because there are many call centers that need to retain those recordings after authorization due to regulatory or legal requirements, the council got creative with its advice. Its core position on retaining SAD is simple: Don’t do it. This is detailed in PCI Requirement 3.2. If your call center records phone calls and you ask customers for the security code from the back of their cards, you need to stop the practice and make sure your voice recording software cuts out and does not record the SAD. For many call centers that means upgrading or reprogramming their voice recording application or changing their process (for example, substituting address verification). Once you stop recording, the next step is to purge all SAD from the existing recordings.

The PCI Council reiterated its prohibition on recording SAD just about a year ago and the requirement to purge old recordings came out at about the same time. There are good reasons for this prohibition.

My colleagues and I have lived through horror stories, including the time we discovered call center staff using the functionality of the call recording software to export and then E-mail MP3 and WAV files containing SAD. This action led to a case of scope creep on steroids.

The council’s recent guidance recognizes that a call center (or a merchant) might be subject to legal or regulatory requirements that supersede PCI. Those requirements can mandate storing the SAD with the call. In those few cases where the SAD cannot be purged, the compliance test is that the call recordings cannot be queried. Specifically: “For data to be considered ‘non-queriable,’ it must not be feasible for general users of the system or malicious users who gain access to the system to retrieve or access the data.”

Encrypting the SAD is not acceptable. Call centers that can document the need to keep the recordings must, for example, store them offline in a secure location like a safe and with strict access restrictions described in the document. If a call center cannot guarantee that the recordings cannot be queried, they are not and cannot be PCI compliant.

The supplement includes other goodies that make it recommended reading for any call center manager. The PCI compliance decision tree for assessing controls, for example, is very clearly presented with straightforward yes or no answers. The report also includes a discussion of what constitutes non-queriable. In addition, it reinforces the requirement that any call center storing SAD must explicitly reflect that in its risk assessment process (PCI Requirement 12.1.2). Lastly, the report presents a summary of all PCI requirements that pertain to call centers with some recommended best practices.

The report is available to everyone on the PCI Council’s online document library.

Does the information supplement answer all of your call center PCI questions? I’d like to hear your thoughts. Either leave a comment or E-mail me at


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