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A3.1.2 A formal PCI DSS compliance program is in place that includes:

Original requirement from PCI DSS v4.0.1

Defined Approach Requirements

A3.1.2 A formal PCI DSS compliance program is in place that includes:

  • Definition of activities for maintaining and monitoring overall PCI DSS compliance, including business-as-usual activities.
  • Annual PCI DSS assessment processes.
  • Processes for the continuous validation of PCI DSS requirements (for example, daily, weekly, every three months, as applicable per the requirement).
  • A process for performing business-impact analysis to determine potential PCI DSS impacts for strategic business decisions.

PCI DSS Reference: Requirements 1-12

Customized Approach Objective

This requirement is not eligible for the customized approach.

Defined Approach Testing Procedures

A3.1.2.a Examine information security policies and procedures to verify that processes are defined for a formal PCI DSS compliance program that includes all elements specified in this requirement.

A3.1.2.b Interview personnel and observe compliance activities to verify that a formal PCI DSS compliance program is implemented in accordance with all elements specified in this requirement.

Purpose

A formal compliance program allows an organization to monitor the health of its security controls, be proactive if a control fails, and effectively communicate activities and compliance status throughout the organization.

Good Practice

The PCI DSS compliance program can be a dedicated program or part of overarching compliance and/or governance program, and should include a well-defined methodology that demonstrates consistent and effective evaluation.

Strategic business decisions that should be analyzed for potential PCI DSS impacts may include mergers and acquisitions, new technology purchases, or new payment-acceptance channels.

Definitions

Maintaining and monitoring an organization's overall PCI DSS compliance includes identifying activities to be performed daily, weekly, monthly, every three months, or annually, and ensuring these activities are being performed accordingly (for example, using a security self-assessment or PDCA methodology).

Examples

Methodologies that support the management of compliance programs include Plan-Do-Check-Act (PDCA), ISO 27001, COBIT, DMAIC, and Six Sigma.

purpose

Designated Entities must perform quarterly reviews of PCI DSS compliance status.

compliance strategies

  • Quarterly compliance meetings
  • Review documentation

typical policies

  • Compliance Review Policy

common pitfalls

  • Missed reviews
  • No documentation

type

Process Control

difficulty

Moderate

key risks

  • Compliance drift

recommendations

  • Automate review reminders and tracking

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