Evan Schuman's StorefrontBacktalk

The reason they won’t meet the requirements is that these call centers mistakenly think Requirement 9.1.1 does not apply to them.

The reason behind that is they use Self-Assessment Questionnaire C, and SAQ C does not include Requirement 9.1.1—the one highlighted in the Council’s newsletter. Indeed, there is nothing in SAQ C for any of the Requirements 9.1 to 9.4, so merchants using SAQ C might be excused for thinking none of these requirements apply to them.

I will avoid the issue of whether or not SAQ C applies to a call center, especially when the devices share a LAN. A QSA might or might not consider that LAN to violate the requirement that the workstations are “not connected to any other systems in your environment,” and QSAs might or might not agree that SAQ C is appropriate. I will only remind merchants with call centers to ask their QSA or their acquirer.

The reality is that many merchants with call centers use SAQ C. And many merchants design their operations to validate PCI compliance with a shortened self-assessment questionnaire. For example, because call center operators access the Internet to authorize transactions, merchants isolate the center from the rest of their environment and ensure it does not store any electronic cardholder data (including voice recordings) so they can, in their eyes, meet SAQ C eligibility requirements. Sometimes these moves can get extreme. The other week, I spoke with a call center manager who is about to reverse his technology investment by buying a bunch of POS devices and entering card transactions manually solely to qualify for a shortened SAQ.

One solution to this choice is to update SAQ C to include additional appropriate PCI requirements. Barring that unlikely event, the Council could reinforce its stance with merchants (perhaps in a future newsletter?) that they should use their self-assessment questionnaires as guidance. The SAQ is a compliance starting point and not the limit of a merchant’s PCI compliance effort. The PCI Council makes this clear in the instructions for each SAQ version. But it could do with some reinforcement, because it appears that not everybody reads all the instructions.

Validation with a shortened SAQ may look good in theory, but compliance has always meant meeting every requirement of PCI DSS. If a merchant suffers a data breach, a “but that requirement wasn’t in my SAQ” defense is not going to get the merchant very far.

The moral of this story is that merchants need to comply with all of PCI all of the time. It would help if the shortened SAQs reflected real merchant requirements more closely. Given there is wide variability across millions of individual merchants, though, this is not likely to happen anytime soon. The alternative of having every merchant use only SAQ D is equally unlikely.

The bottom line is that if you have a call center, consider it to be a sensitive area for PCI purposes and implement access control measures and other security measures defined in Requirement 9. Do this no matter what your SAQ says.

What do you think? I’d like to hear your thoughts. Either leave a comment or E-mail me at wconway@403labs.com.