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A1.1.4 The effectiveness of logical separation controls used to separate customer environments is confirmed at least once every six months via penetration testing.

Original requirement from PCI DSS v4.0.1

Defined Approach Requirements

A1.1.4 The effectiveness of logical separation controls used to separate customer environments is confirmed at least once every six months via penetration testing.

Customized Approach Objective

Segmentation of customer environments from other environments is periodically validated to be effective.

Applicability Notes

The testing of adequate separation between customers in a multi-tenant service provider environment is in addition to the penetration tests specified in Requirement 11.4.6.

This requirement is a best practice until 31 March 2025, after which it will be required and must be fully considered during a PCI DSS assessment.

Defined Approach Testing Procedures

A1.1.4 Examine the results from the most recent penetration test to verify that testing confirmed the effectiveness of logical separation controls used to separate customer environments.

Purpose

Multi-tenant services providers are responsible for managing the segmentation between their customers.

Without technical assurance that segmentation controls are effective, it is possible that changes to the service provider's technology would inadvertently create a vulnerability that could be exploited across all the service provider's customers.

Good Practice

Effectiveness of separation techniques can be confirmed by using service-provider-created temporary (mock-up) environments that represent customer environments and attempting to 1) access one temporary environment from another environment, and 2) access a temporary environment from the Internet.

purpose

Ensure that each tenant can only access their own data, systems, and resources.

compliance strategies

  • Access controls
  • Role-based access management

typical policies

  • Tenant Access Policy

common pitfalls

  • Excessive access rights
  • No periodic access review

type

Technical/Process Control

difficulty

Moderate

key risks

  • Unauthorized access to other tenants' data

recommendations

  • Automate access reviews and enforce least privilege

Eligible SAQ

  • SAQ-D SERVICE PROVIDER

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