Frequently Asked Question
Are hashed Primary Account Numbers (PAN) considered cardholder data that must be protected in accordance with PCI DSS?
One-way hashing meets the intent of rendering the PAN unreadable in storage; however the hashing process and results, as well as the system(s) that perform the hashing, would still be in scope to assure that the PAN cannot be recovered. If the hashing result is transferred and stored within a separate environment, the hashed data in that separate environment would no longer be considered cardholder data and the system(s) storing the hashed data would be out of scope of PCI DSS. If however, the system hashes and stores the data on the same system, that system is considered to be storing cardholder data and is within PCI DSS scope. The difference lies in where the data is hashed and then stored. More on hashing: A hash is intended to be irreversible by taking a variable-length input and producing a fixed-length string of cipher text. As the PAN has been 'replaced', it should most often be considered out of scope in the same manner receipt of truncated PANs are out of scope. However, PCI DSS Requirement 3.4 also states that the hash must be strong and one-way. This implies that the algorithm must use strong cryptography (e.g. collisions would not occur frequently) and the hash cannot be recovered or easily determined during an attack. It is also a recommended practice, but not specified requirement, that a salt be included. Since the intent of hashing is that the merchant or service provider will never need to recover the PAN again, a recommended practice is to simply remove the PAN rather than allowing the possibility of a compromise cracking the hash and revealing the original PAN. If the merchant or service provider intends to recover and use the PAN, then hashing is not an option and they should evaluate a strong encryption method.
April 2012
Article Number: 1089
