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Its fair to risky in IMHO but they need to get them some how or another.
I want to hear everyone else's ideas.
Keeping in mind that they are currently PCI compliant, the new version has to be PCI compliant.
More specifically, take a look at this file for CISP payment application best practices guide [usa.visa.com] (the link points to a .doc file). This document will outline what data can be stored, what cannot, and restrictions for both.
I just had to do PCI compliance for a web application. The biggest issue I faced wasn't technological either. It was the users behavior.
This particular application was ecommerce order processing where all the users had access to multiple machines in an order processing facility under 1 single user account. Well, in walks PCI compliance which says that all users must have their own accounts and the system must log when anyone of these users looks at a credit card number.
This meant the users couldn't bounce around from machine to machine to work on something at any available workstation w/o always logging off and back on. They didn't like this 'at all' and it has to constantly be reinforced or they'll be subject to a PCI Audit failure which I believe comes with a fine.
If you DONT store the CC in your own database and it gets housed in the payment gateway, i.e VERISIGN then there are some issues involving this. Firstly, Verisign or similar gateways will return a reference transaction associated with the credit card. (number, exp, type, etc). Depending on the card issuing bank, there IS an expiration associated to this reference transaction. Meaning, if you need to charge the card again in 3 months and the most recent transaction on record for the customer ID is 3 months ago---you cant. I've experienced some card #'s lasting for up to 6 months, but since I have customers purchasing once a year. I HAD to store it in our own database, with proper encryption of course.
The other issue is, if you decide to go from storing the CCS elsewhere to your own servers--you MUST ask how much would it cost to attain the necessary CC infos from prior customers using the stored CC (in payment gateway). They DO charge you based on volume.
If your application requires an immediate charge to the card and would never have to reference it in the future. Then I would not store the CC's in your own database due to liability issues.
Hope this helps