Clearly, one errant employee is something every chain has (for many, it's more like several thousand errant employees, but let's not go there). But this example brings up a too-often overlooked PCI fact: Compliance is an issue for every employee. That means training and quite a few new policies and procedures. Mobile payment, being a disruptive factor, will only make things worse, because it creates many more opportunities for payment-card data to be captured/retained against the rules.
The Fortnum & Mason situation, which—to the best of our knowledge—was first reported by Computerworld UK, started out with what undoubtedly seemed to be a reasonable customer service customer interaction.
The rep understood enough about PCI and payment-card procedures to know that such data cannot be preserved. The problem happened when the rep took the next step.
Fortnum & Mason "does not process direct crediting automatically due to encryption measures." So far, so good. "I understand you do not want to give out your details, however. We do not keep them on file due to security reasons." Again, everything is looking good.
The rep then said: "The only way I can refund you is if I do have them. We will instantly destroy your details as soon as you are refunded." And there we have the double-whammy of PCI boo-boos: The rep understood that such data can't be stored, but somehow didn't see how asking for it to be E-mailed would undo that.
Then there's the card data security coup de grâce: The rep's belief that the ability exists to "instantly destroy your details as soon as you are refunded." Setting aside the data backups for both the retailer and the customer, there's the issue of sending that information across multiple E-mail servers and the Internet in plain text. The rep even acknowledged "encryption measures," but didn't see how this request—which the customer had the good sense to refuse—contradicted it.
A Fortnum & Mason spokesperson, Sarah Street, issued a statement that fessed up. The retailer had initially denied that customer service had sought the payment-card data, but it then corrected that statement.
"We have now fully investigated the claim that a customer was asked for their credit card details via E-Mail and we can confirm that an error was inadvertently made in an effort to expedite a refund," the statement said. "We apologize for causing concern for this genuine human error, done with best intentions to aid the customer. It is against our procedures and we have taken action to ensure that this will not occur again."
It was a good, contrite statement and fully appropriate.It was a good, contrite statement and fully appropriate. But the next part of the statement is a bit more troubling: "Fortnum & Mason take the handling of customer personal information and data extremely seriously. We comply fully with the Payment Card Industry (PCI) Data Security Standard for both payment card and consumer financial data protection and have procedures in place to ensure these standards are met. We do not hold any customer credit card details."
On its own, those sentiments are fine. But when combined with the confession made a sentence or two earlier, it's disconcerting. The only reason this one customer service rep incident came to light was because someone went to the media with a copy of that E-mail. If there was one incident, what makes Fortnum & Mason so certain that there aren't many more out there? Indeed, until new training and other mechanisms are put in place, logic would suggest that there almost certainly are other similar situations happening, unless there was something unusual about this one rep. Otherwise, if all of the training and management is the same, wouldn't that suggest similar results?
And if that is happening, how can it be said that Fortnum & Mason does "comply fully with the Payment Card Industry (PCI) Data Security Standard for both payment card and consumer financial data protection" when such requests are clearly contrary to PCI rules?
The statement said that the retailer has "procedures in place to ensure these standards are met." Not so sure how this could be ensured. If a customer service rep makes the request and if the customer complies, you have a violation. Management can tell reps to not do that and calls can be periodically monitored, but this is not something that can ever be fully halted.
To be clear, this Fortnum & Mason situation is quite likely an isolated problem. But the certainty from corporate that this can't happen again is eerily similar to the associate's faith in his/her ability to permanently delete information. In short, all that card data rules can do is reduce the fraud probability, because it can never go away. The belief from any player that any mechanism can eliminate that risk, that's where the problems kick in.