1) Process
2) Store
3) Transmit
cardholder data you fall under PCI. All of PCI. It's not an ala carte menu that you get to pick and choose from. If you are a level 1 or 2 merchant, you're already behind. Way behind. The rest of you better get moving. And yes, if you take cardholder data on your web site you were supposed to have an application layer firewall in front of every web server. And NO, that doesn't mean you simply slap a cheap ASA firewall in front and call that an application layer firewall. If you don't know the difference, ask someone.

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