Protecting Call Centers, The PCI Way

A 403 Labs QSA, PCI Columnist Walt Conway has worked in payments and technology for more than 30 years, 10 of them with Visa.

The PCI Council used its December 2011 newsletter to remind merchants and service providers to control physical access to their call centers with video cameras or other devices. This recommendation is both sound security and good advice, and I hope merchants everywhere will take it to heart. As a QSA, I wish the Council had done more than highlight just one particular sub-requirement. There is more to protecting sensitive areas than installing video cameras. The second, and possibly thornier, concern for small and midsize merchants is how effective the reminder is likely to be when many of them mistakenly think they won't need to follow the advice.

The Council's electronic newsletter to participating organizations (POs) is a great communication tool. I hope the PO contacts who receive the E-mails distribute them widely throughout their organizations. The PCI Council also notes in its December newsletter that call centers are to be considered "sensitive areas," just like data centers. That is, call centers "process, transmit and/or store cardholder data" and, therefore, merchants and service providers must protect them from unauthorized physical access.

The Council's reasoning is that "without physical access controls, unauthorized persons could potentially gain access to the CDE [cardholder data environment] and to sensitive information, or could alter system configurations, introduce vulnerabilities into the network or destroy or steal equipment."

PCI addresses physical access controls in Requirement 9. The particular sub-requirement highlighted in the newsletter (9.1.1) requires installing video cameras or other access control mechanisms to monitor individual access. The intent is to ensure that all entry/exit points to the call center are controlled and monitored and that you can identify all individuals who enter the call center.

As a QSA, I find myself wishing the PCI Council had gone a bit further. The Council reminded POs that their call centers are sensitive areas, but it stopped short of saying that call centers—just like server rooms—should be subject to all of Requirement 9.

Requirement 9 has two main parts. The first four sub-requirements (9.1–9.4) address restricting physical access to the facility and systems, while the last six sub-requirements (9.5–9.10) deal with protecting storage media, both paper and electronic.

Because the Council highlighted 9.1.1 in its "FAQ of the Month," I imagine it is getting a lot of questions about this particular requirement. However, I would prefer the Council had gone a bit further and highlighted the need for call centers to comply with all of 9.1 through 9.4, as appropriate, and not just the one sub-requirement. For example, it seems that if call centers are sensitive areas, managers and users must lock consoles to prevent unauthorized use (9.1), restrict wireless and handheld devices (9.1.3), implement a badging system (9.2) that identifies employees and visitors (9.3) and maintain a visitor log (9.4).

I feel confident that Level 1 merchant and service provider call centers likely meet all these requirements. Many other call centers, however, do not meet the access control requirements. Once more, they are unlikely to do so. 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 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 [email protected].