Do I Store Card Data? A Complete Beginner’s Guide to Understanding Cardholder Data Storage

Introduction

If you accept credit or debit cards at your business, you’ve likely wondered: “Do I store card data?” It’s one of the most important questions in PCI DSS compliance, yet many business owners aren’t sure how to answer it. You might think you don’t store cardholder data, but you could be storing it without even realizing it.

What You’ll Learn

In this guide, you’ll discover how to determine whether your business stores cardholder data, understand the different ways data can be stored, and learn what this means for your PCI compliance requirements. We’ll walk you through everything in simple, non-technical terms.

Why This Matters

Knowing whether you store card data directly impacts your PCI compliance requirements, security obligations, and potential liability. Businesses that store cardholder data face stricter compliance requirements and higher security standards than those that don’t.

Who This Guide Is For

This guide is perfect for small to medium business owners, managers, and anyone responsible for payment processing who needs to understand their PCI compliance obligations without getting lost in technical jargon.

The Basics

what is cardholder data?

Before we determine if you store it, let’s understand what cardholder data actually includes:

Primary Account Number (PAN): The 13-19 digit number on the front of a credit or debit card. This is the most critical piece of data.

Cardholder Name: The name printed on the card.

Expiration Date: When the card expires.

Service Code: The 3-digit code that specifies acceptance requirements (though this is less common in most business contexts).

What Does “Storing” Mean?

In PCI terms, storing cardholder data means keeping it in any form after the payment transaction is complete. This includes:

Electronic storage: In databases, files, spreadsheets, or any digital format
Physical storage: On paper receipts, written records, or printed documents
Temporary storage: Even if you plan to delete it later

Key Terminology Made Simple

PCI DSS: Payment Card Industry Data Security Standard – the security rules all businesses must follow when handling card data.

SAQ (Self-Assessment Questionnaire): A form you complete to validate your PCI compliance based on how you process and store card data.

Cardholder Data Environment (CDE): Any system, network, or area where cardholder data is stored, processed, or transmitted.

Why It Matters

Business Implications

Whether you store cardholder data determines:

Which PCI compliance requirements apply to you
How complex your security measures need to be
What type of assessment you need to complete
Your potential liability in case of a data breach

Risk of Non-Compliance

If you store How to without proper security:

Fines: Payment processors can impose significant penalties
Increased processing fees: You might face higher transaction costs
Legal liability: You could be held responsible for fraudulent card use
Reputation damage: data breaches can severely impact customer trust
Business disruption: You might lose the ability to accept card payments

Benefits of Compliance

When you properly handle cardholder data storage:

Reduced liability: Lower risk of being held responsible for fraud
Customer trust: Customers feel confident sharing their payment information
Competitive advantage: Compliance can be a selling point
Peace of mind: You know you’re following industry best practices

Step-by-Step Guide to Determine If You Store Card Data

Step 1: Examine Your Payment Process

Start by mapping out exactly how payments flow through your business:

1. Point of sale: How do customers provide their card information?
2. Processing: What happens to the card data during the transaction?
3. After the sale: Where does transaction information go?
4. Record keeping: What payment-related information do you keep?

Step 2: Check Your Digital Systems

Look for cardholder data in these common locations:

Point-of-sale systems: Check if your POS system stores complete card numbers after transactions.

Customer databases: Review any customer records to see if full card numbers are saved.

Email systems: Search for emails containing card information from phone orders.

Backup systems: Don’t forget to check backup files and archived data.

Spreadsheets and documents: Look for any files where staff might have recorded card information.

Step 3: Review Physical Storage

Don’t overlook physical storage of cardholder data:

Receipts: Check if you keep copies of receipts showing full card numbers.

Order forms: Review any paper forms customers fill out with card information.

Notebooks: Look for handwritten records of card information.

Filing systems: Check any physical files containing payment information.

Step 4: Interview Your Staff

Ask employees who handle payments:

Do you ever write down card numbers?
Are card numbers saved in any system for recurring payments?
Do customers email or text their card information?
Are there any “workaround” processes that might involve storing card data?

Timeline Expectations

This assessment typically takes:

Small businesses: 2-4 hours
Medium businesses: 1-2 days
Complex operations: Several days to weeks

Common Questions Beginners Have

“I Only Keep the Last Four Digits – Is That Storing Card Data?”

No, keeping only the last four digits is not considered storing cardholder data for PCI purposes. This is actually a recommended practice for receipts and records.

“My Payment Processor Handles Everything – Do I Still Need to Worry?”

Even if your processor handles the transaction, you might still store cardholder data in other ways. You’re responsible for any card data in your environment, regardless of who processes payments.

“I Delete Card Information After Each Transaction – Am I Safe?”

If you truly delete all cardholder data immediately after processing, you’re not storing it. However, make sure it’s completely removed from all systems, including backups and temporary files.

“What About Recurring Payments – Doesn’t That Require Storage?”

Not necessarily. Many payment processors offer tokenization services that let you process recurring payments without storing actual card data. The processor stores the real card information and gives you a token to use instead.

“I’m Too Small to Be a Target – Why Should I Care?”

Cybercriminals often target smaller businesses because they typically have weaker security measures. Plus, PCI compliance is required regardless of business size.

Mistakes to Avoid

Common Beginner Errors

Assuming you don’t store data without checking thoroughly: Many businesses discover they’re storing card data in unexpected places.

Focusing only on electronic storage: Physical storage of card data is just as important and regulated.

Ignoring email and communication systems: Card data in emails or messages still counts as storage.

Forgetting about backup and archived data: Old backups might contain cardholder data you forgot about.

Not involving all staff in the assessment: Employees might have created their own processes that involve storing card data.

How to Prevent These Mistakes

Conduct a thorough assessment of all systems and processes
Include both digital and physical storage in your review
Interview all staff who handle payments
Document your findings and create policies to prevent future storage
Regularly review and update your assessment

What to Do If You Make These Mistakes

If you discover you’ve been storing cardholder data:

1. Don’t panic: Many businesses discover this during their first PCI assessment
2. Secure the data immediately: Ensure it’s properly protected while you address the situation
3. Develop a plan: Decide whether to continue storing data with proper security or eliminate storage
4. Implement appropriate controls: If you continue storing data, ensure you meet all PCI requirements
5. Update your compliance approach: Choose the correct SAQ based on your actual data handling

Getting Help

When to DIY vs. Seek Professional Help

You can likely handle it yourself if:

You have a simple payment setup
You’re confident you don’t store cardholder data
You have time to learn and implement requirements

Consider professional help if:

You discover you do store cardholder data
You have complex payment systems
You’re unsure about technical security requirements
You want ongoing support and monitoring

Types of Services Available

Assessment services: Professionals who can help determine your storage practices and compliance requirements.

Implementation services: Experts who can help you achieve and maintain compliance.

Ongoing monitoring: Services that continuously check your compliance status.

Training and education: Programs to help your staff understand and maintain compliance.

How to Evaluate Service Providers

Look for providers who:

Have specific PCI DSS expertise and certifications
Understand businesses similar to yours
Offer clear pricing and service descriptions
Provide ongoing support, not just one-time assessments
Have good references and testimonials

Trust Elements: PCICompliance.com helps thousands of businesses achieve and maintain PCI DSS compliance with affordable tools, expert guidance, and ongoing support.

Next Steps

Immediate Actions

1. Complete your assessment: Use the steps in this guide to determine if you store cardholder data
2. Document your findings: Create a record of what you discovered
3. Identify your compliance requirements: Based on whether you store data, determine which PCI requirements apply
4. Create an action plan: Outline the steps you need to take for compliance

Resources for Deeper Learning

PCI Security Standards Council official documentation
Industry-specific compliance guides
Security best practices for small businesses
Regular compliance training and updates

Frequently Asked Questions

1. What if I’m not sure whether something counts as storing cardholder data?

When in doubt, err on the side of caution and assume you do store cardholder data. It’s better to follow stricter security requirements than to miss something important. Consider consulting with a PCI expert if you’re unsure about specific situations.

2. Can I store cardholder data if I follow the right security measures?

Yes, you can store cardholder data legally and in compliance with PCI DSS, but you must implement comprehensive security controls. This includes encryption, access controls, network security, and regular monitoring. However, many businesses find it easier and safer to avoid storing cardholder data altogether.

3. How often should I reassess whether I store cardholder data?

You should reassess at least annually or whenever you make changes to your payment processes, systems, or business operations. New software, different payment methods, or changes in staff procedures could all affect whether you store cardholder data.

4. What’s the difference between storing and processing cardholder data?

Processing means handling cardholder data during a transaction (like when a customer swipes their card). Storing means keeping that data after the transaction is complete. You might process cardholder data without storing it if the data is immediately sent to your payment processor and then deleted from your systems.

5. If my payment processor gets breached, am I liable?

Your liability depends on what data you store and how well you’ve protected it. If you don’t store cardholder data and your processor gets breached, your liability is typically much lower. However, if you store cardholder data and don’t follow PCI requirements, you could still face penalties and liability.

6. What happens if I discover I’ve been storing cardholder data incorrectly?

First, don’t panic – this is a common discovery. Immediately secure any stored data, then decide whether to implement proper security controls to continue storing data or eliminate storage altogether. You may need to update your PCI compliance approach and complete a different type of assessment. Consider getting professional help to ensure you address everything properly.

Conclusion

Understanding whether you store cardholder data is the foundation of PCI compliance. It affects everything from your security requirements to your potential liability. By following the steps in this guide, you can accurately assess your data storage practices and ensure you’re meeting the appropriate compliance requirements.

Remember, whether you store cardholder data or not, you still need to maintain PCI compliance. The key is understanding exactly what your obligations are based on your specific situation.

Ready to take the next step in your PCI compliance journey? Use our free PCI SAQ Wizard tool at PCICompliance.com to determine which Self-Assessment Questionnaire you need based on your business practices. Our tool takes the guesswork out of compliance and helps you get started on the right path. With expert guidance and ongoing support, we make PCI compliance manageable for businesses of all sizes.