15.1 Cash-Handling Protocols, Point-of-Sale (POS) & Separation of Duties
Key Takeaways
- Internal fiscal controls safeguard public assets and maintain public trust through the strict Segregation of Duties, ensuring that no single employee has end-to-end control over cash collection, cash drawer balancing, bank deposit preparation, and general ledger reconciliation.
- Point-of-Sale (POS) systems require unique, individual cashier credentials, zero shared cash drawers, mandatory immediate receipt generation for all transactions, and dual-custody supervisory overrides for voids, cancellations, and customer refunds.
- The daily cash-handling lifecycle enforces opening float verifications, mid-shift handoffs, end-of-day blind counts, dual-custody drops into drop-safes, and daily or 24-hour armored/police-escorted bank deposits.
- Petty cash operations must utilize a fixed imprest fund system with strict per-transaction dollar limits, mandatory original itemized receipts, periodic replenishment equal to substantiated expenditures, and unannounced surprise spot audits.
- Payment Card Industry Data Security Standards (PCI-DSS) mandate that municipal recreation facilities never store CVV/PIN data, use point-to-point encrypted (P2PE) payment terminals, segment payment networks from public Wi-Fi, and restrict cardholder data access.
Cash-Handling Protocols, Point-of-Sale (POS) & Separation of Duties
Public park and recreation agencies operate diverse revenue-generating facilities and services, including municipal aquatic centers, golf courses, community recreation centers, ice arenas, concession stands, marina boat launches, and special event ticketing gates. These operations handle significant volumes of currency, checks, and electronic payments daily. Because municipal agencies operate as stewards of public tax dollars and participant user fees, establishing rigorous internal fiscal controls is mandatory to prevent fraud, deter theft, eliminate accounting discrepancies, and protect employees from unfounded allegations of financial impropriety.
For the Certified Park and Recreation Professional (CPRP), understanding the architecture of internal cash controls is essential for operational management and national certification. This section provides an in-depth analysis of the fundamental Segregation of Duties, Point-of-Sale (POS) operational controls, the complete Daily Cash Handling Lifecycle, Imprest Petty Cash management, and PCI-DSS (Payment Card Industry Data Security Standards) compliance across recreation facilities.
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| INTERNAL FISCAL CONTROL FRAMEWORK IN RECREATION |
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| 1. SEPARATION OF DUTIES | 2. POS OPERATIONAL CONTROLS | 3. PHYSICAL SAFEGUARDS |
| * Custody != Accounting | * Unique Individual Logins | * Tamper-Evident Bags |
| * Authorization != Custody | * Zero Shared Cash Drawers | * Dual-Key Drop Safes |
| * Reconciliation != Custody | * Mandatory Print Receipts | * Timely Bank Deposits |
| * Independent Spot Audits | * Supervisory Void Overrides| * Armored/Police Escort |
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1. Internal Fiscal Controls & Segregation of Duties
Internal controls are systematic operational policies, procedures, organizational structures, and physical safeguards designed to achieve three primary objectives:
- Safeguard public agency assets against waste, theft, loss, and unauthorized use.
- Ensure the absolute accuracy, completeness, and reliability of financial accounting records.
- Ensure operational compliance with municipal financial policies, state statutes, and governmental accounting standards (GASB).
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| THE FOUR PILLARS OF SEGREGATION OF DUTIES |
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| CUSTODY OF ASSETS | AUTHORIZATION OF TRANSACTIONS |
| Collecting cash at the desk, | Approving refunds, discounts, fee waivers, |
| holding petty cash, making | voids, purchase orders, and expenditure vouchers. |
| physical safe drops. | |
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| RECORDKEEPING & ACCOUNTING | RECONCILIATION & AUDIT |
| Entering ledger transactions, | Comparing bank statements to general ledgers, |
| posting journal entries, | conducting surprise physical cash drawer audits, |
| updating registration files. | auditing POS electronic audit logs. |
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| RULE: No single employee may perform more than one of these four core functions! |
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The Fundamental Principle: Segregation of Duties
The single most critical internal control in revenue operations is the Segregation (or Separation) of Duties. Under this principle, the operational workflow is divided among different staff members such that no single individual has complete end-to-end control over any financial transaction. If one person collects funds, records the transaction, prepares the bank deposit, and reconciles the account, the agency has created an inherent vulnerability for undetected error or intentional misappropriation (such as skimming or deposit lapping).
To establish an effective segregation of duties in recreation operations, four core functions must remain strictly isolated across separate personnel:
- Custody of Assets: The physical handling, collection, and storage of currency, coins, and checks (e.g., frontline Cashier, Front Desk Attendant, Concession Worker).
- Authorization of Transactions: The formal administrative approval of non-standard transactions, such as program fee waivers, scholarship adjustments, transaction voids, and payment refunds (e.g., Recreation Supervisor, Facility Manager).
- Recording / Accounting: The formal entry of transactions into the municipal enterprise financial system or general ledger (e.g., Finance Department Bookkeeper, Departmental Accountant).
- Reconciliation & Auditing: The independent verification of financial data, including monthly bank statement reconciliations, variance audits, and unannounced cash counts (e.g., Internal Auditor, Municipal Finance Director).
Core CPRP Examination Rule: The employee who collects cash from patrons must never balance the register, prepare the bank deposit bag, or reconcile the monthly bank statements.
Managing Small-Staff Facility Limitations
In smaller park agencies or satellite facilities (such as a remote community tennis center or seasonal boat launch) where staffing levels may not permit four distinct individuals on duty, management must implement compensating controls:
- Mandatory Dual-Custody: Two employees must co-verify and sign off on cash counts, end-of-day register totals, and safe deposits.
- Direct Supervisory Review: The facility manager must review daily electronic POS transaction summary logs and cross-reference them against actual bank deposit receipts.
- Independent Centralized Auditing: Central municipal accounting personnel perform regular unannounced surprise spot audits of register banks and physical cash safes.
2. Point-of-Sale (POS) Operational & Electronic Controls
Modern park and recreation agencies utilize specialized Point-of-Sale (POS) and recreation management software (e.g., RecTrac, ActiveNet, CivicRec, PerfectMind, EZFacility) to manage program registrations, membership admissions, facility rentals, retail merchandise sales, and daily concessions. A properly configured POS system serves as a powerful automated internal control.
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| MANDATORY POS OPERATIONAL PROTOCOLS |
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| 1. UNIQUE CASHIER CREDENTIALS | Unique user ID & password; zero shared logins |
| 2. DEDICATED CASH DRAWERS | Strictly one cashier per physical cash drawer |
| 3. MANDATORY RECEIPTS | Immediate itemized receipt generated for all sales|
| 4. DUAL-AUTH OVERRIDES | Supervisor credential required for refunds/voids |
| 5. IMMUTABLE AUDIT TRAILS | System timestamps every keystroke, open, & drawer |
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Core POS Control Standards:
- Individual Cashier Credentials & Accountability:
- Every staff member operating a POS terminal must log in with a unique, individual username, password, biometric scan, or secure magnetic swipe card.
- Generic, shared logins (e.g.,
frontdesk1orcashier) are strictly prohibited. Shared logins destroy individual accountability and prevent the agency from establishing chain of custody during audit investigations.
- Zero Shared Cash Drawers (One Cashier, One Drawer):
- A physical cash drawer must be assigned to exactly one cashier at any given time.
- If a cashier takes a scheduled lunch break, steps away from the desk, or ends their shift, their drawer must be locked, removed, or counted out. A relief cashier must insert their own separate, verified cash drawer into the terminal.
- Sharing a cash drawer between multiple workers makes it impossible to determine which individual is responsible for cash shortages or overages.
- Mandatory Immediate Receipt Generation:
- The POS terminal must automatically generate an immediate, sequential, itemized printed or electronic receipt for every transaction (including cash, credit, debit, or gift certificate).
- Cashiers must offer the receipt to the patron. Prominently displayed signage at all customer service counters must state: "Please retain your official receipt. If you are not offered a receipt, please ask to speak with the Recreation Supervisor." This public-facing policy deters off-the-books transactions (skimming cash without ringing up the sale).
- Supervisory Overrides for Non-Standard Transactions:
- Frontline cashiers must not have system permissions to execute transaction cancellations, post-sale voids, price overrides, tax exemptions, or cash refunds.
- Any refund, return, or transaction void must require an electronic or keycard supervisory override by a designated supervisor or facility manager, accompanied by a documented, written justification and the customer's original receipt.
- Automated POS Audit Logs & Drawer-Open Tracking:
- Modern POS software maintains an immutable electronic audit trail that records every transaction, keystroke, drawer-kick (opening the cash drawer without a sale), price override, and supervisor authorization with exact timestamps and user IDs.
- Supervisors must review POS "No-Sale Drawer-Open" reports daily to identify suspicious patterns of unrecorded drawer access.
3. The Daily Cash Handling Lifecycle
From the moment a recreation facility unlocks its doors in the morning until revenue is credited to the municipal bank account, cash must follow a standardized, secure, and documented lifecycle.
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| THE DAILY RECREATION CASH HANDLING LIFECYCLE |
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| [ 1. Opening Float Verification ] |
| Cashier verifies & signs for static starting change bank (e.g., $150.00) |
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| [ 2. Daily Transaction Processing ] |
| Individual POS login; immediate receipts; supervisor overrides for voids |
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| [ 3. End-of-Shift / End-of-Day Blind Count ] |
| Cashier counts cash/checks without knowing system total; completes Tally Form|
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| [ 4. Supervisor Dual-Custody Reconciliation ] |
| Supervisor runs POS 'Z-Report'; matches count to report; notes Over/Short |
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| [ 5. Secure Tamper-Evident Bag & Safe Drop ] |
| Funds sealed in serialized bag; dual-signed drop into dual-custody drop safe |
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| [ 6. Armored Transit & Bank Deposit (< 24 Hours) ] |
| Funds transported to bank; bank-validated deposit slip returned to Finance |
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Step 1: Opening Cash Float (Change Bank) Verification
- Each cashier is issued a standardized, predetermined starting cash float (e.g., $100.00 or $200.00 in specific bill and coin denominations) to make change for patrons.
- The cashier must count the starting float in a secure, non-public area before opening the register and sign the Cash Float Issuance Log, verifying that the starting balance is exactly correct.
Step 2: Shift Changes and Mid-Day Handoffs
- When cashiers rotate during peak operational periods (such as a municipal pool shift change), the outgoing cashier must perform a full count and reconciliation of their drawer before the incoming cashier begins transactions.
- Mid-day cash drops (skimming excess $50 and $100 bills from the active drawer to minimize on-counter cash exposure during high-volume special events) must be documented on a numbered cash drop form, co-signed by the cashier and supervisor, and placed immediately into the drop safe.
Step 3: End-of-Shift / End-of-Day Blind Count
- At the conclusion of the operating shift or business day, the cashier locks the POS terminal and conducts an independent Blind Cash Count in a secure back office.
- Blind Count Principle: The cashier counts all currency, coins, and checks and records the exact totals on a standardized Daily Cash Tally Sheet without first looking at the POS system's daily sales summary total (commonly referred to as the POS 'Z-Report' or End-of-Day Total). This prevents cashiers from manipulating physical counts or pocketing unrecorded overages to match the computer report.
Step 4: Dual-Custody Reconciliation & Over/Short Variance Tracking
- Once the cashier completes and signs the Blind Cash Tally Sheet, the on-duty supervisor accesses the POS administrative module and generates the official End-of-Day POS Sales Report.
- The supervisor and cashier jointly compare the physical cash count against the POS system expected revenue:
- Over/Short Procedures:
- An exact match ($0.00 variance) is ideal. Minor rounding discrepancies (+/- $1.00 to $3.00) are recorded in the general ledger Over/Short account.
- Discrepancies exceeding a predetermined agency threshold (e.g., any variance $\ge $5.00$ or $\ge $10.00$) require an immediate physical recount of the drawer and float, a line-by-line audit of POS transaction receipts, and a mandatory written Cash Variance Incident Report submitted to the Department Finance Director.
- Agencies must maintain employee cash variance logs to detect recurring patterns of shortages or intentional manipulation by specific workers.
Step 5: Dual-Custody Safe Drops & Physical Security
- After reconciliation, the starting cash float is returned to the facility's locked overnight cash safe for the next business day.
- The net daily revenue (cash, checks, credit card summary slips, and reconciliation paperwork) is placed into a heavy-duty, serialized tamper-evident deposit bag.
- The cashier and supervisor both sign across the seal of the tamper-evident bag and record the bag's unique serial number, date, time, and dollar amount in the permanent Safe Drop Log.
- The sealed bag is immediately dropped through the one-way hopper slot of a dual-control depository drop safe. Depository drop safes are engineered so that once a deposit is dropped, it cannot be retrieved through the hopper slot, and the main safe chamber requires two separate keys or dual digital combinations (e.g., one held by the Facility Manager and one by the Municipal Treasury/Armored Courier) to open.
Step 6: Timely Bank Deposits & Armored Transport
- State statutes and municipal fiscal policies generally dictate that all collected public funds must be deposited into the agency's designated depository bank daily or within 24 hours of receipt.
- Holding accumulated cash over weekends or multiple days creates severe burglary risks and violates public finance laws.
- Deposit Transport:
- High-volume facilities (aquatics centers, golf courses, large recreation complexes) must utilize bonded, licensed armored car transport services for direct bank delivery.
- Lower-volume facilities without armored pickup must transport deposits to the municipal treasury or bank night depository using strict security protocols: dual-staff transport, varying transit routes and departure times, concealed bank bags, and/or police escorts.
- The bank-validated deposit receipt must be matched against the initial POS daily reconciliation report and forwarded to the Central Finance Department for general ledger posting.
4. Petty Cash Funds & The Imprest System
Park and recreation departments frequently require immediate, low-dollar purchasing capability for minor, incidental operational emergencies—such as buying emergency hardware screws to repair a broken community center door latch, purchasing ice for a first-aid station during a youth soccer tournament, or paying minor municipal parking fees. Using formal purchase orders or corporate credit cards for small, unpredictable $5.00 to $20.00 transactions is administratively inefficient. To accommodate these needs while preserving strict financial accountability, agencies utilize an Imprest Petty Cash Fund.
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| THE IMPREST PETTY CASH ACCOUNTING CYCLE |
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| 1. ESTABLISH FUND | Council/Board authorizes fixed balance (e.g. $200)|
| 2. CUSTODIAL ASSIGNMENT | Single designated Petty Cash Custodian is liable |
| 3. AUTHORIZED DISBURSEMENTS | Minor emergency costs (<$25); original receipts |
| 4. CONSTANT FUND BALANCE RULE | [ Physical Cash Remaining ] + [ Receipts ] = $200 |
| 5. REPLENISHMENT VOUCHER | Submit receipts; check drawn to restore cash bank |
| 6. SURPRISE AUDITS | Unannounced spot counts by internal audit staff |
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Rules for Compliant Imprest Petty Cash Management:
- Fixed Imprest Balance: The petty cash fund is established with a fixed, static dollar limit authorized by the governing board or finance director (typically $100.00 to $300.00 depending on facility size).
- Sole Custodianship: A single, named employee (e.g., Facility Administrative Assistant) is formally designated as the Petty Cash Custodian and is held personally accountable for the physical security and balance of the fund. The cash box must be locked inside a secure safe when not in use.
- Strict Transaction Limits: Agency policy establishes a strict maximum cap per disbursement (typically $25.00 to $50.00). Transactions exceeding this limit must be processed through standard municipal procurement channels (P-Card or Purchase Order).
- Mandatory Itemized Documentation:
- Cash may never be disbursed without a signed Petty Cash Voucher accompanied by an original, detailed itemized store receipt or invoice proving the purchase.
- Vouchers must document: date, exact amount, business purpose, municipal budget account code, recipient signature, and custodian approval signature.
- Absolute Prohibitions:
- Petty cash funds may never be used to cash personal employee checks, provide employee IOUs or travel salary advances, pay contractor labor wages, purchase alcohol, or bypass competitive bidding thresholds.
- The Imprest Formula (Constant Value): At any given second in time, the sum of physical cash remaining in the lockbox plus the total dollar value of unreplenished original receipts must exactly equal the authorized imprest fund balance:
- Replenishment Procedure: When the cash in the box reaches a minimum operational threshold (e.g., 25% to 30% remaining), the custodian submits all original receipts and vouchers to Finance. Finance verifies the receipts, charges the appropriate departmental line-item budget accounts, and issues a check payable to the Custodian (or direct cash transfer) for the exact total of the receipts, restoring the cash box to its full original authorized balance.
- Surprise Audits: Internal audit or finance supervisors must conduct periodic, unannounced spot audits of the petty cash box to verify the physical cash-and-receipts balance.
5. PCI-DSS Compliance & Electronic Payment Security
In modern recreation operations, over 80% of customer transactions occur via credit and debit cards—both online through cloud registration software and in person at facility customer service counters. To process payment cards legally, public agencies must comply with the Payment Card Industry Data Security Standards (PCI-DSS), a mandatory set of global technical and operational requirements established by major card brands (Visa, MasterCard, American Express, Discover) to protect cardholder data and prevent cyber theft.
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| PCI-DSS COMPLIANCE PILLARS IN RECREATION |
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| 1. CARDHOLDER DATA RETENTION | NEVER store sensitive authentication data (CVV/PIN)|
| 2. P2PE PAYMENT TERMINALS | Use EMV Point-to-Point Encrypted hardware |
| 3. NETWORK SEGREGATION | Separate POS network from public park Wi-Fi |
| 4. ACCESS CONTROLS | Restrict card data access strictly by job role |
| 5. PHYSICAL DEVICE AUDITS | Inspect payment terminals daily for skimming bugs |
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Essential PCI-DSS Compliance Guidelines for Park & Recreation Staff:
- Zero Storage of Sensitive Authentication Data (SAD):
- Recreation staff are strictly prohibited from writing down, recording, scanning, or electronically storing Card Verification Values (CVV/CVC 3-digit/4-digit codes), full magnetic stripe track data, or debit card PIN numbers.
- Phone registrations: If a customer provides credit card details over the phone, the staff member must enter the data directly into the secure payment gateway in real time. Writing credit card numbers on paper sticky notes or registration forms is a severe PCI-DSS violation and a critical data security breach.
- Point-to-Point Encryption (P2PE) & EMV Chip Hardware:
- Facilities must utilize certified P2PE payment card terminals (tap, chip, and swipe readers) that encrypt card data immediately upon physical contact. The decrypted card data is never accessible to the municipal computer network or local POS software.
- Strict Network Segmentation:
- POS terminals, payment gateways, and registration computers must operate on a dedicated, secure, firewall-isolated Virtual Local Area Network (VLAN).
- Payment networks must be completely segmented and isolated from public park guest Wi-Fi networks and general administrative municipal networks to prevent hackers on public Wi-Fi from intercepting transaction data.
- Daily Physical Terminal Inspections (Anti-Skimming):
- Frontline staff must conduct daily physical inspections of all card readers and payment terminals to detect tampering, illegal overlay skimming devices, or unauthorized cable attachments.
6. Cash Handling Controls Comparison Matrix
The following matrix summarizes the core internal control mechanisms, their operational applications in park and recreation operations, associated risks, and monitoring methods:
| Control Mechanism | Primary Operational Rule | Threat / Fraud Risk Mitigated | Responsible Role | Verification & Audit Method | |:---|:---|:---|:---|:---|:---| | Segregation of Duties | Isolate asset custody, transaction approval, ledger entry, and bank reconciliation across separate staff. | Skimming, deposit lapping, unrecorded theft, accounting concealment. | Facility Manager, Cashier, Finance Director. | Annual external audit; monthly independent bank reconciliation. | | Individual POS Logins | Zero shared user accounts; unique password/PIN per cashier; automatic timeout. | Lack of individual accountability; untraceable drawer shortages. | Front Desk Staff, Lifeguards, Cashiers. | POS user activity logs; keystroke audit reports. | | Dedicated Cash Drawers | Exactly one cashier assigned per physical drawer; drawer locked during breaks. | Passing shortages between shift workers; finger-pointing during loss. | Cashiers, Shift Leads. | Daily drawer issuance and check-in logs. | | Supervisory Overrides | Frontline staff cannot void or refund; manager credentials required with receipt. | Unauthorized cash extraction disguised as fake refunds or voids. | Recreation Supervisor, Facility Manager. | Daily POS exception reports; void/refund ratio audits. | | Blind Cash Counts | Cashier counts physical cash/checks without viewing POS system sales totals. | Fudging physical cash counts to match system totals; stealing overages. | Cashier, Closing Lead. | Completed Blind Tally Sheet compared to POS Z-Report. | | Dual-Custody Safe Drops | Two staff verify count, seal in numbered tamper bag, and drop into hopper safe. | Single-staff safe theft, bag tampering, safe-opening discrepancies. | Cashier & On-Duty Supervisor. | Co-signed safe drop log; verified tamper-evident bag serials. | | 24-Hour Bank Deposits | All revenue deposited daily/within 24 hours via armored car or police escort. | Overnight burglary, armed robbery in transit, municipal policy violation. | Armored Courier, Facility Manager, Police. | Bank-validated deposit slips matched to daily POS ledgers. | | Imprest Petty Cash | Static authorized balance; $ Receipts + $ Cash = Fund Total; strict $25–$50 cap. | Unsubstantiated expenditures, personal IOUs, budget evasion. | Petty Cash Custodian. | Unannounced surprise spot counts; finance replenishment audit. | | PCI-DSS Compliance | Never write down/store CVV or card data; use P2PE terminals; segment POS network. | Credit card data breach, identity theft, massive card brand fines. | All Customer Service Staff, IT Specialist. | Annual SAQ (Self-Assessment Questionnaire); daily terminal skimmer check. |
A community recreation center operates a busy customer service desk. To streamline operations during the busy summer registration rush, the facility manager allows front desk attendants to collect program registration cash, generate daily POS summary reports, count and balance their own cash drawers, prepare the bank deposit bag, and drop it in the bank night depository. Which fundamental internal control principle is being violated in this operational workflow?
A park agency establishes an authorized Imprest Petty Cash Fund of $250.00 for minor emergency maintenance supplies at a municipal golf clubhouse. At the end of the month, the lockbox contains $72.00 in physical cash and original itemized store receipts totaling $178.00 ($45.00 for irrigation pipe fittings, $38.00 for emergency flagstick hardware, and $95.00 for mower spark plugs). How should the petty cash custodian and finance department handle fund replenishment?
A parent calls the recreation department to register their child for a youth gymnastics camp. The customer service representative enters the parent's credit card number into the secure registration portal. The parent also asks the representative to write down their 3-digit CVV security code and credit card expiration date on a paper camp registration form so the department can automatically charge next month's session. How should the representative handle this request under PCI-DSS compliance standards?