12.8.1 A list of all third-party service providers (TPSPs) with which account data is shared or that could affect the security of account data is maintained
Defined Approach Requirements
12.8.1 A list of all third-party service providers (TPSPs) with which account data is shared or that could affect the security of account data is maintained, including a description for each of the services provided.
Customized Approach Objective
Records are maintained of TPSPs and the services provided.
Applicability Notes
The use of a PCI DSS compliant TPSP does not make an entity PCI DSS compliant, nor does it remove the entity's responsibility for its own PCI DSS compliance.
Defined Approach Testing Procedures
12.8.1.a Examine policies and procedures to verify that processes are defined to maintain a list of TPSPs, including a description for each of the services provided, for all TPSPs with whom account data is shared or that could affect the security of account data.
12.8.1.b Examine documentation to verify that a list of all TPSPs is maintained that includes a description of the services provided.
Purpose
Maintaining a list of all TPSPs identifies where potential risk extends outside the organization and defines the organization's extended attack surface.
Examples
Different types of TPSPs include those that:
Store, process, or transmit account data on the entity's behalf (such as payment gateways, payment processors, payment service providers (PSPs), and off-site storage providers).
Manage system components included in the entity's PCI DSS assessment (such as providers of network security control services, anti-malware services, and security incident and event management (SIEM); contact and call centers; web-hosting companies; and IaaS, PaaS, SaaS, and FaaS cloud providers).
Could impact the security of the entity's cardholder data and/or sensitive authentication data (such as vendors providing support via remote access, and bespoke software developers).
purpose
Maintain a list of all third-party service providers (TPSPs) with access to cardholder data or CDE.
compliance strategies
- Vendor inventory management
- Annual review of TPSP list
typical policies
- TPSP Management Policy
common pitfalls
- Outdated TPSP list
- Missed new vendors
type
Process Control
difficulty
Moderate
key risks
- Unmonitored third-party risk
recommendations
- Automate vendor tracking
Eligible SAQ
- SAQ-A
- SAQ-A-EP
- SAQ-B
- SAQ-B-IP
- SAQ-C
- SAQ-C-VT
- SAQ-D MERCHANT
- SAQ-D SERVICE PROVIDER
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