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1.4.4 System components that store cardholder data are not directly accessible from untrusted networks.

Original requirement from PCI DSS v4.0.1

Defined Approach Requirements

1.4.4 System components that store cardholder data are not directly accessible from untrusted networks.

Customized Approach Objective

Stored cardholder data cannot be accessed from untrusted networks.

Applicability Notes

This requirement is not intended to apply to storage of account data in volatile memory but does apply where memory is being treated as persistent storage (for example, RAM disk). Account data can only be stored in volatile memory during the time necessary to support the associated business process (for example, until completion of the related payment card transaction).

Defined Approach Testing Procedures

1.4.4.a Examine the data-flow diagram and network diagram to verify that it is documented that system components storing cardholder data are not directly accessible from the untrusted networks.

1.4.4.b Examine configurations of NSCs to verify that controls are implemented such that system components storing cardholder data are not directly accessible from untrusted networks.

Purpose

Cardholder data that is directly accessible from an untrusted network, for example, because it is stored on a system within the DMZ or in a cloud database service, is easier for an external attacker to access because there are fewer defensive layers to penetrate. Using NSCs to ensure that system components that store cardholder data (such as a database or a file) can only be directly accessed from trusted networks can prevent unauthorized network traffic from reaching the system component.

purpose

Protect stored cardholder data from direct external access.

whats required for compliance

  • No direct access from untrusted networks to CHD storage systems.
  • Enforced via NSCs and network design.

compliance strategies

  • Private VLANs
  • Application-layer gateways
  • Segmentation controls

typical policies procedures

  • Data Storage Zoning Policy
  • HSM Configuration

common pitfalls failures

  • Direct internet access to DBs

type

Technical Control

difficulty

High

key risks

  • Database breaches

product vendor recommendations

  • Use database encryption (Vormetric)

Eligible SAQ

  • SAQ-A-EP
  • SAQ-D MERCHANT
  • SAQ-D SERVICE PROVIDER

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