ISC2 Certified Cloud Security Professional (CCSP) Practice Question
A retailer plans to migrate its card-holder database to an IaaS provider. To avoid rewriting decades-old billing programs that require a 16-digit numeric credit-card field, the architect proposes installing an on-premises tokenization server. The server will replace each primary account number (PAN) with a randomly generated 16-digit numeric token before the record is sent to the cloud, and the token vault will remain in the retailer's data center.
Which statement correctly describes the PCI DSS impact of this design?
Because the real PAN never leaves the premises, the cloud environment is automatically exempt from any PCI DSS requirements.
Tokenization works by applying irreversible salted hashing, so neither the retailer nor the cloud provider can ever map a token back to a PAN.
Moving the token vault to the cloud would simplify key management and remove the provider's infrastructure from PCI DSS scope.
Tokenization can remove the cardholder data from the cloud storage, so the cloud's PCI DSS scope is greatly reduced, but the cloud must still be evaluated if it can impact the on-premises CDE.
Because the cloud stores only random, format-preserving tokens that contain no exploitable PAN information, the cloud portion of the solution no longer handles cardholder data directly, significantly reducing its PCI DSS scope. However, PCI DSS still requires an assessment of any system- including the cloud environment-if it could influence the security of the on-premises cardholder data environment (CDE). The incorrect options either assume scope is eliminated entirely, misunderstand tokenization as hashing, or suggest moving the vault (which would keep the cloud fully in scope).
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What is tokenization in the context of PCI DSS?
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Why does a cloud provider environment still require PCI DSS assessment in this design?
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What is the difference between tokenization and hashing?
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ISC2 Certified Cloud Security Professional (CCSP)
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