Frequently Asked Question
Are audio/voice recordings permitted to contain sensitive authentication data?
PCI DSS Requirement 3.2 prohibits storage of sensitive authentication data (SAD), including card validation codes and values, after authorization even if the data is encrypted. Storage of card validation codes or values (referred to as CAV2, CVC2, CVV2 or CID) in any form of digital audio recording—for example, .wav or .mp3 files—after authorization is therefore a violation of this requirement.
Every possible effort should be made to eliminate sensitive authentication data from the entity’s environment. Where technology exists to prevent recording of these data elements, such technology should be enabled. If it is not possible to prevent SAD from being recorded, the data should be securely deleted immediately upon authorization of the transaction. If secure deletion is not possible due to a legitimate technical or business constraint, compensating controls should be implemented to mitigate the risk associated with storing the data. At a minimum, this should include performing a comprehensive risk assessment at least annually and upon significant changes to the environment, securing the SAD in accordance with applicable PCI DSS requirements, and implementing controls to ensure that SAD cannot be accessed and call recordings cannot be queried. The detailed justification, risk-assessment results, and documentation of controls in place to ensure SAD cannot be accessed and call recordings cannot be queried should be retained and validated as part of the entity’s annual PCI DSS assessment. All the resulting documentation should also be provided to and discussed with the entity’s acquiring bank and/or payment brands as applicable to confirm whether the entity has met their PCI DSS compliance obligations.
PCI DSS requirements do not supersede local or regional laws that may govern the retention of audio recordings.
The PCI SSC Information Supplement: Protecting Telephone Based Payment Card Data provides additional guidance.