Frequently Asked Questions

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Are audio/voice recordings permitted to contain sensitive authentication data?

FAQ Response

PCI SSC FAQ’s are designed to provide merchants, assessors, acquirers and other Council stakeholders with clear and timely guidance on PCI standards. They are a critical two way communication channel from which the PCI SSC draws valuable market feedback and insight, and is able to share this with the industry. On January 22 2010, as part of the online FAQ feedback and submission process, the regular review of FAQ language, and inquiries from Participating Organizations the SSC sought to clarify its position on call center audio recordings.

The updates to the FAQ language were intended to eliminate any inconsistencies in implementations of audio recordings in call center environments by providing a higher level of specificity in FAQ guidance. The Council’s position remains that if you can digitally query sensitive authentication data (SAD) contained within audio recordings - if SAD is easily accessible - then it must not be stored. As a result of additional market feedback, on February 17, 2010 the SSC modified the new language to further clarify its position on audio recordings.

This response is intended to provide clarification for call centers that record cardholder data in audio recordings, and applies only to the storage of card validation codes and values (referred to as CAV2, CVC2, CVV2 or CID codes by the payment brands).

It is a violation of PCI DSS requirement 3.2 to store any sensitive authentication data, including card validation codes and values, after authorization even if encrypted.

It is therefore prohibited to use any form of digital audio recording (using formats such as wav, mp3 etc) for storing CAV2, CVC2, CVV2 or CID codes after authorization if that data can be queried; recognizing that multiple tools exist that potentially could query a variety of digital recordings.

Where technology exists to prevent recording of these data elements, such technology should be enabled.

If these recordings cannot be data mined, storage of CAV2, CVC2, CVV2 or CID codes after authorization may be permissible as long as appropriate validation has been performed. This includes the physical and logical protections defined in PCI DSS that must still be applied to these call recording formats.

This requirement does not supersede local or regional laws that may govern the retention of audio recordings.


October 2011
Article Number 1210