PCI DSS Call Recording: Compliance Guide

TL;DR

Recording calls that handle cardholder data can cause PCI DSS compliance issues if not managed correctly. This guide explains how to secure your call recordings and meet the requirements.

1. Understand the Risks

Call recordings store sensitive information, making them a target for attackers. PCI DSS requires you to protect this data throughout its lifecycle – from capture to storage and disposal. Key risks include:

• Unauthorized Access: Anyone with access to the recordings could potentially steal cardholder data.
• Data Breaches: Recordings stored insecurely are vulnerable to hacking and theft.
• Non-Compliance Fines: Failing to protect call recordings can result in significant penalties.

2. Identify Scope

Not all call recordings fall under PCI DSS scope. Determine which calls handle cardholder data (e.g., full card number, expiry date, CVV). Recordings of general customer service that don’t involve payment information are typically out of scope.

3. Secure Your Recording System

1. Encryption: Encrypt recordings both in transit and at rest. Use strong encryption algorithms (e.g., AES-256).
2. Access Control: Implement strict access controls to limit who can view, download, or modify recordings. Role-based access is best practice.
3. Authentication: Require strong authentication for all users accessing the recording system (e.g., multi-factor authentication).
4. Audit Logging: Enable detailed audit logging to track all access and changes to recordings. Review logs regularly.

Example of setting up basic user permissions in a hypothetical call recording platform:

user1 (analyst): read-only access to specific queues
user2 (supervisor): read/write access to all queues, limited deletion rights
user3 (admin): full access

4. Storage Considerations

1. Secure Servers: Store recordings on secure servers with appropriate firewalls and intrusion detection systems.
2. Data Masking/Tokenization: Consider masking or tokenizing cardholder data within the recordings if possible. This reduces the risk if a breach occurs.
3. Regular Backups: Implement regular backups of recordings, stored securely in a separate location.

5. Retention and Disposal

1. Retention Policy: Define a clear retention policy for call recordings based on legal and business requirements. Don’t store recordings longer than necessary.
2. Secure Deletion: When recordings are no longer needed, securely delete them to prevent recovery. Overwriting data multiple times is recommended.

Example command (Linux) for secure deletion using shred:

shred -u -z -v filename.wav

(This overwrites the file three times before deleting it.)

6. Vendor Management

If you use a third-party call recording provider, ensure they are PCI DSS compliant and have a Service Provider Attestation of Compliance (SOC) report. Review their security practices carefully.

7. Regular Testing & Monitoring

1. Vulnerability Scanning: Regularly scan your recording system for vulnerabilities.
2. Penetration Testing: Conduct periodic penetration testing to identify weaknesses in your security controls.
3. Security Audits: Perform regular security audits of your call recording processes and systems.

8. cyber security Awareness Training

Train all employees who handle or access call recordings on PCI DSS requirements and best practices for protecting cardholder data.