Did you know data contained on credit cards and debit cards issued by schemes such as Visa and MasterCard are one of the easiest types of information for criminals to steal and convert to cash? Disposal of card information when it is no longer required for business purposes is the best way of protecting both your customers and your agency from this type of theft.
The Payment Card Industry Data Security Standard (PCI DSS) was developed to encourage and enhance cardholder data security, and it applies to all entities involved in payment card processing. The Standard has some quite specific requirements regarding the storage and disposal of credit card details which must be met.
We’ve been hearing that agencies are grappling with how they can meet these requirements and be recordkeeping compliant. To address this, QSA has released a new version of the Transitory Records and Short Term Retention and Disposal Schedule QDAN720. With guidance from Queensland Treasury who provided clarity on PCI DSS requirements, we’ve developed two new classes for card records. Check out the updated schedule.
Why the change?
The table below, taken from the Standard, illustrates commonly used elements of card data, which of these can be stored, and which need to be protected.
As you can see in the table, sensitive authentication data, such as those 3 digit numbers on the back of MasterCard and Visa cards, should never be stored.
It also says that a Primary Account Number (PAN) (the card number), needs to be rendered unreadable when it is stored. Can your system meet that requirement? If not, then you can’t store (capture) this record in your system.
The data that can be stored under the PCI DSS should only be retained if there is a valid legal, business or regulatory need for that data. That’s why under the Transitory Records and Short Term Retention and Disposal Schedule QDAN720, we’ve made the disposal action ‘retain until business use ceases’. This means your agency determines when the card data is no longer required and can destroy it if there is no valid business reason to retain it. For the sensitive authentication data, we’ve directed immediate destruction – as you must not store this data at all.
What about the existing record classes in the GRDS?
There are two existing classes in GRDSv7 specifically associated with card data (4.1.12 and 4.1.13) so we know it may appear we’re duplicating things here, however records covered under the Transitory Records and Short Term Retention and Disposal Schedule QDAN720 don’t have to be captured into an agency’s recordkeeping solution. By having the two new classes in that schedule, we want to make it clear that QSA doesn’t have a requirement for you to capture and store these records!
Of course, if you wish to continue to use the classes in the GRDSv7 for disposal until we release the revised schedule, you can. You just need to ensure you are storing the records in line with the Standard.
What if other information needs to be kept once a transaction is completed?
Where there is a need to keep other parts of the record for a certain period of time after the card transaction has occurred, for example to show payment has been received, orders sent etc., the cardholder data must be stored or redacted in some way, in accordance with the requirements of the PCI DSS.
If this is challenging for you and you’re looking to avoid such storage issues compounding for the future, you might wish to consider introducing new processes such that all new cardholder data received is not captured with other record data. This will mean you can easily dispose of the cardholder data once your business need is met, whilst retaining the other data for its required retention period, thereby being compliant with both the Standard and your recordkeeping obligations.
Irrespective, a documented process relating to the management and capture of records associated with credit card transactions is important to help make it crystal clear for all staff, both exactly what does need to be captured – in order to meet your recordkeeping responsibilities – and what can be disposed of. This will certainly require consultation with those staff who receive, handle and use cardholder data.
If you’ve successfully implemented the PCI DSS within your agency, do you have learnings or tips you’d like to share with your colleagues? If so, leave a comment below, or you can contact us at any time via email, telephone (07) 3037 6630, blog, Twitter, Facebook, Instagram or Flickr.
Anna Morris Karen Ryan
A/Manager, Agency Services Principal Appraisal Officer