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Winslow Compliance Partners
Our position, stated first. Winslow is not a Qualified Security Assessor, so we do not assess, sign Reports on Compliance or certify anybody. We prepare you and also introduce independent QSA firms.

Guide

PCI DSS IVR and phone payments: keeping agents out of scope

PCI DSS IVR questions come up whenever customers pay by phone. If agents hear card numbers or calls are recorded, a large part of your operation falls into scope, so the design choice matters.

  • Not a QSA, stated first
  • Introductions to independent QSAs
  • Written answers, no call
Pci dss ivr: map the call, mask the digits and check recordings

Why PCI DSS IVR design matters for phone payments

Card numbers spoken aloud reach agents, headsets, desktops and recording systems. Therefore each of those can enter scope. Also, security codes must never be stored after authorisation, which includes recordings. The standard is in the PCI SSC document library.

Options for PCI DSS IVR and call centres

Several designs reduce scope. However, they differ in cost and customer experience.

ApproachEffect on scope
Agent hears and types numbersAgents, desktops and recordings in scope.
Pause and resume recordingHelps, but relies on agents every time.
Keypad entry with tone maskingAgents never hear numbers, so scope shrinks.
Transfer to a hosted IVRCard entry handled by the provider.

PCI DSS IVR check

Tick each statement that is true.

Your result appears here as you tick, so you can see what is still open.

PCI DSS IVR and call recordings

Search existing recordings and transcripts for card data. For example, a call where a customer read out the security code is stored sensitive data. So include recordings in your data discovery.

  • Call recordings and backups
  • Speech-to-text transcripts
  • Quality monitoring tools
  • Ticket notes written during calls

Choosing a PCI DSS IVR design

Weigh call volume, cost and agent workflow. For example, a small team taking few phone payments may manage with careful procedures, while a busy call centre usually benefits from keypad masking.

Whatever the choice, document it. Assessors want to see how card data moves through the call, and a clear diagram answers most of their questions.

Where we help

We map the call flow, find stored data and compare scope-reduction options. However, we are not a QSA, and we do not sell telephony products.

Also train agents on what to do when a customer starts reading out a card number at the wrong moment, because procedures fail most often in those unexpected moments.

PCI DSS IVR questions

Does PCI DSS IVR guidance allow call recording?

Yes, but recordings must not keep security codes, and card data must be protected.

Is pause and resume enough for PCI DSS IVR?

It helps, but it relies on people, so mistakes happen.

What is keypad masking?

Customers type digits on their phone, and tones are hidden from the agent.

Do you sell phone systems?

No. We stay independent.

Related guides

Map your phone payment flow

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