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Appendix C Compensating Controls Worksheet

The entity must use this worksheet to define compensating controls for any requirement where compensating controls are used to meet a PCI DSS requirement. Note that compensating controls should also be documented in accordance with instructions in the Report on Compliance in the corresponding PCI DSS requirement section.

Note: Only entities that have legitimate and documented technological or business constraints can consider the use of compensating controls to achieve compliance.

Requirement Number and Definition:

Information Required Explanation
1. Constraints Document the legitimate technical or business constraints precluding compliance with the original requirement.
2. Definition of Compensating Controls Define the compensating controls: explain how they address the objectives of the original control and the increased risk, if any.
3. Objective Define the objective of the original control (for example, the Customized Approach Objective).

Identify the objective met by the compensating control (note: this can be, but is not required to be, the stated Customized Approach Objective for the PCI DSS requirement).
4. Identified Risk Identify any additional risk posed by the lack of the original control.
5. Validation of Compensating Controls Define how the compensating controls were validated and tested.
6. Maintenance Define process(es) and controls in place to maintain compensating controls.

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