PAN never stored in call recordingsEnable DTMF masking or pause-and-resume recording around PAN entry.

Agents cannot key in PAN into their own screensReduce scope — direct PAN entry goes to a PCI-compliant payment app only.

DTMF tones masked end-to-endTones replaced or suppressed before entering any non-PCI system.

Screens blurred/redacted during CHD captureScreen recording and shoulder-surfing both mitigated.

Call recording retention policy documentedNo CHD in retained recordings — or retained only in PCI-scoped storage.

Segmented network for any CHD-touching systemSwitch/firewall segmentation is documented and tested.

Quarterly ASV scans on exposed CHD systemsExternal scan by an ASV passes quarterly.

Annual penetration test covers CC scopeCall-center-facing apps and IVRs included.

Role-based access controls on recordingsAccess to CHD-adjacent recordings is RBAC-enforced and audit-logged.

BAU audit trail of calls containing CHDYou can produce a list of recordings that touched PAN on demand.

Third-party processor BAAs/DPAs in placeAny vendor handling recordings or PAN has written contractual obligations.

Annual PCI AOC producedAttestation of Compliance refreshed.