>Yes Maureen - I know this. What "we" are asking is - What if the customer
>DOESN'T WANT TO USE THOSE - What if they want you to store the credit card
>anyway... regardless of compliance. (Compliance isn't law...)  What if that
>is your option?

Actually, there *are* states that have made compliance a law. Only a few so 
far, but we can expect more to follow. Also, by getting a merchant account, you 
are basically entering a contract with the merchant bank and agreeing to follow 
their rules. So if you are breached, you can be liable for severe fines which 
would easily hold up in court, just as any contract would. You really want to 
be careful as a developer agreeing to do something for a client that could lead 
to serious financial harm for them. 


>Matt's original question wasn't what are other methods - but what is the
>best choice for encrypting the data. (And what is required for compliance.)

One of the primary things you have to do if you plan to store credit card data, 
is to be up on the requirements for encryption. You not only have to encrypt 
the data, you have to use a multi-level encryption (key encryption key) which 
has to be stored separately from the rest of the data. It's not something you 
can handle at the ColdFusion or database level alone, and it's pretty darned 
expensive as well. You have to have a dedicated web sever, and a separate 
server for the database. There's over 200 requirements that you have to fulfill 
to meet the PCI compliance regulations for storing card data, that cover all 
kinds of things from your building and computer access to wireless security, 
etc. It's really well beyond the scope of any small merchant to deal with, and 
really silly to even consider as a way to save money versus paying for a 
gateway. 


--- Mary Jo



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