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Run: PCI DSS Telephone Payment Scope Review

Review the PCI DSS scope of telephone payment operations, from agent desktops and call recording to telephony integrations and cardholder data flows. Use it ...

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Inspection Scope and Environment

Review scope documented for all telephone payment channels critical (required)

Confirm the inspection explicitly covers inbound, outbound, transferred, and callback payment calls where card data may be spoken.

Yes No N/A

Business units and locations included in scope identified

List the departments, sites, queues, and remote work locations where agents handle spoken card payments.

Current payment flow diagram available and reviewed critical (required)

Verify a current data flow diagram exists showing where cardholder data enters, traverses, is paused, is recorded, or exits the environment.

PCI scope owner identified

Record the person or role responsible for maintaining telephone payment scope and coordinating remediation.

Agent Workstations and User Access

Agent desktops used for payment calls are identified and inventoried critical (required)

Confirm each workstation used during payment calls is listed with asset ID, location, and assigned user group.

Payment-call workstations are restricted to authorized users critical (required)

Verify access to in-scope desktops is limited to approved agents and support personnel with a business need.

Yes No N/A

Screen lock and session timeout configured on agent devices critical (required)

Confirm workstations lock after inactivity and require re-authentication before access is restored.

Yes No N/A

No local storage of cardholder data on agent endpoints critical (required)

Verify agents are not storing card numbers, CVV, or related payment data in notes, files, screenshots, clipboard tools, or browser caches.

Yes No N/A

Telephony, Headsets, and Call Recording

Headsets and softphone endpoints used for payment calls identified critical (required)

Confirm the specific headsets, softphones, desk phones, and related endpoints used during card payment calls are documented.

Call recording captures are paused or masked during card entry critical (required)

Verify the recording solution prevents storage of spoken card data through pause/resume, masking, DTMF suppression, or equivalent approved control.

Yes No N/A

Recording retention and access controls documented critical (required)

Confirm retention periods, access permissions, and review controls for recordings that may contain cardholder data are documented and enforced.

Yes No N/A

Telephony network segmentation reviewed critical (required)

Verify the voice environment is segmented from non-in-scope networks where required and that any shared services are documented with data flow impact.

Yes No N/A

Systems, Integrations, and Data Flows

All systems touching payment-call data identified critical (required)

List CRM, ticketing, IVR, payment gateway, recording, analytics, remote support, and workforce tools that may interact with card data or payment metadata.

Note (optional)

Cardholder data flow path documented end to end critical (required)

Describe where card data originates, where it is spoken, whether it is transcribed, where it is transmitted, and where it is stored or discarded.

No unnecessary systems receive cardholder data critical (required)

Verify only approved systems are in the payment path and that logging, transcription, screen capture, and support tools do not receive card data unless explicitly required and controlled.

Yes No N/A

Third-party processors and service providers identified

Record any external vendors, hosted services, or telecom providers that may be in PCI scope due to their role in the payment call flow.

Controls, Exceptions, and Closeout

Open deficiencies or non-conformances documented

Record any gaps found during the review, including missing segmentation, uncontrolled recordings, or unidentified in-scope assets.

Remediation owner and due date assigned for each finding

Confirm each deficiency has an accountable owner, target completion date, and follow-up plan.

Qualified Security Assessor consultation required if scope is unclear

Confirm whether the organization will consult a Qualified Security Assessor or equivalent PCI specialist for ambiguous scope boundaries or control design questions.

Yes No N/A

Note (optional)

Inspector sign-off completed critical (required)

Inspector confirms the review was completed based on observed evidence and available documentation.

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