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With over 50 million credit card customers around the world, the company was subject to the Payment Card Industry Data Security Standards (PCI-DSS). The standards require that sensitive credit card information be encrypted at rest, and that access to the information is controlled.

The latter requirement can be complicated. Credit card information includes the account holder’s name, address, social security number, and Primary Account Number (PAN). Most of the bank’s employees should be blocked from viewing any of this sensitive data. However, some employees required access to social security numbers, others only needed access to PANs. Still others needed access to both.

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