WithPCI Logo
WithPCI.com

3.2.2 For PAN storage, the business justification is documented.

Original requirement from PCI DSS v4.0.1

Defined Approach Requirements

3.2.2 For PAN storage, the business justification is documented.

Customized Approach Objective

The business need for storing PAN is documented.

Defined Approach Testing Procedures

3.2.2 Interview personnel and examine documentation to verify that the business justification for PAN storage is documented.

Purpose

Without a documented business need and retention policy, PANs could be stored without a defined retention period, which could lead to unnecessarily storing PANs, which increases the risk in case of a compromise.

Good Practice

The business justification for PAN storage should be documented as part of the data retention policy.

purpose

Do not store sensitive authentication data after authorization (even if encrypted).

compliance strategies

  • Data discovery scans
  • Automated deletion routines

typical policies

  • Sensitive Data Handling Policy

common pitfalls

  • SAD stored post-authorization
  • No automated deletion

type

Technical/Process Control

difficulty

High

key risks

  • Regulatory fines, increased breach risk

recommendations

  • Automate SAD deletion and monitor storage

Eligible SAQ

  • SAQ-D MERCHANT
  • SAQ-D SERVICE PROVIDER

Your perspective on this PCI DSS requirement matters! Share your implementation experiences, challenges, or questions below. Your insights help other organizations improve their compliance journey and build a stronger security community.Comment Policy