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22-U: Call Centers

This section evaluates how your organization manages call center operations that handle customer information or support services.

The questions focus on whether call center staff are properly vetted and trained, how scripts and procedures address confidentiality and authentication, and what controls exist around call recording, screen viewing, and data entry. They also address physical and logical security in call center environments, quality monitoring, and supervision.

Overall, this section confirms that call center activities do not introduce undue risk to sensitive information, systems, or customers.

Explanation: Network separation ensures that sensitive client data in the call center is isolated from broader corporate networks, reducing the risk of unauthorized access or data breaches.

Risks of Incorrect Answer: Increased exposure of sensitive client data to network attacks.

Non-compliance with data protection regulations requiring segregation.

Vulnerability to lateral movement by attackers.

Applicable Frameworks: NIST CSF (PR.AC-5): Ensures access control by segregating networks.

ISO 27001 (A.13.1.1): Requires network security controls.

PCI DSS (Requirement 1.2): Requires segmentation of networks handling cardholder data

Explanation: Logical and physical separation minimizes unauthorized access and protects client data. Logical controls include VLANs and firewalls, while physical controls include restricted access areas.

Risks of Incorrect Answer: Unauthorized personnel accessing sensitive systems or data.

Breaches stemming from insufficient controls over access points.

Applicable Frameworks: ISO 27001 (A.11.1.1): Physical access controls.

HIPAA (164.310(a)): Safeguards for physical access.

NIST CSF (PR.AC-4): Logical access control implementation.

Explanation: Strong controls, such as disabling USB ports, implementing policies against mobile phones in work areas, and monitoring access logs, prevent data exfiltration.

Risks of Incorrect Answer: Loss or theft of sensitive customer data.

Potential regulatory violations and reputational harm.

Applicable Frameworks: NIST CSF (PR.DS-5): Protecting data in transit and at endpoints.

GDPR (Article 32): Ensures safeguards to prevent unauthorized data access.

PCI DSS (Requirement 12.3): Restricts unauthorized physical or logical access.

Explanation: Understanding the format of call recordings is critical for determining security requirements, such as encryption and storage access controls.

Risks of Incorrect Answer: Loss of unencrypted or poorly secured recordings.

Compliance failures with data storage and retention standards.

Applicable Frameworks: PCI DSS (Requirement 3.4): Encryption of sensitive data.

NIST CSF (PR.DS-1): Protecting stored data.

ISO 27001 (A.12.4.1): Logging and monitoring requirements.

Explanation: Proper storage, encryption, and access controls for recordings protect sensitive information and ensure compliance with data privacy standards.

Risks of Incorrect Answer: Breaches exposing sensitive conversations.

Loss of client trust due to non-compliance with security requirements.

Applicable Frameworks: NIST CSF (PR.DS-1): Encrypting stored recordings.

GDPR (Article 32): Data protection and access control measures.

HIPAA (164.310(d)(2)(iv)): Data storage security

Explanation: Quality assurance ensures compliance with service and data handling policies. It also helps identify potential security or operational issues.

Risks of Incorrect Answer: Lack of oversight may lead to poor data handling practices.

Undetected issues could result in regulatory fines or breaches.

Applicable Frameworks: ISO 27001 (A.12.7.1): Monitoring and quality assurance.

NIST CSF (DE.DP-5): Continuous monitoring and auditing.

Explanation: Retention and disposal policies ensure that call recordings are stored only as long as necessary and securely destroyed when no longer needed.

Risks of Incorrect Answer: Over-retention increases the attack surface for data breaches.

Non-compliance with data retention laws can result in penalties.

Applicable Frameworks: NIST CSF (PR.IP-6): Retention and disposal policies.

GDPR (Article 5.1(e)): Data minimization and retention principles.

HIPAA (164.310(d)(2)(i)): Disposal of sensitive data.

Explanation: Restricting access reduces the risk of malware infections or accidental data leaks from unsecured browsing.

Risks of Incorrect Answer: Exposure of client data to phishing attacks or malware.

Breaches through compromised employee devices.

Applicable Frameworks: NIST CSF (PR.PT-4): Safeguards against unauthorized software and usage.

ISO 27001 (A.12.6.2): Restrictions on software and browsing.

Explanation: Monitoring access to sensitive financial data ensures compliance with PCI DSS and other financial data security standards.

Risks of Incorrect Answer: Mishandling of sensitive billing information could lead to fraud or breaches.

Violations of PCI DSS requirements result in fines and loss of payment processing privileges.

Applicable Frameworks: PCI DSS (Requirement 3): Secure storage and handling of cardholder data.

NIST CSF (PR.AC-4): Role-based access control for sensitive data.

GDPR (Article 5.1(f)): Safeguarding personal data.

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Some or all of the services described in this engagement may not be available to certain clients, including those who have affiliations or relationships with audit firms or related entities.

The information provided herein is of a general nature and is not intended to address the specific circumstances of any individual or entity. While we strive to offer accurate and up-to-date information, we cannot guarantee its accuracy at the time it is received or in the future. No action should be taken based solely on this information without seeking appropriate professional advice tailored to your particular situation. CRISP does not provide legal or tax advice.

This information is not intended to constitute “written advice concerning one or more Federal tax matters” as defined by section 10.37(a)(2) of Treasury Department Circular 230.

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