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A3.2.1 PCI DSS scope is documented and confirmed for accuracy at least once every three months and upon significant changes to the in-scope environment. At a minimum, the scoping validation includes:

Original requirement from PCI DSS v4.0.1

Defined Approach Requirements

A3.2.1 PCI DSS scope is documented and confirmed for accuracy at least once every three months and upon significant changes to the in-scope environment. At a minimum, the scoping validation includes:

  • Identifying all data flows for the various payment stages (for example, authorization, capture, settlement, chargebacks, and refunds) and acceptance channels (for example, card-present, card-not-present, and e-commerce).
  • Updating all data-flow diagrams per Requirement 1.2.4.
  • Identifying all locations where account data is stored, processed, and transmitted, including but not limited to 1) any locations outside of the currently defined CDE, 2) applications that process CHD, 3) transmissions between systems and networks, and 4) file backups.
  • For any account data found outside of the currently defined CDE, either 1) securely delete it, 2) migrate it into the currently defined CDE, or 3) expand the currently defined CDE to include it.
  • Identifying all system components in the CDE, connected to the CDE, or that could impact security of the CDE.
  • Identifying all segmentation controls in use and the environment(s) from which the CDE is segmented, including justification for environments being out of scope
  • Identifying all connections to third-party entities and to the CDE.
  • Confirming that all identified data flows, account data, system components, segmentation controls, and connections from third parties with access to the CDE are included in scope.

PCI DSS Reference: Scope of PCI DSS Requirements, Requirement 12.

Customized Approach Objective

This requirement is not eligible for the customized approach.

Defined Approach Testing Procedures

A3.2.1.a Examine documented results of scope reviews and interview personnel to verify that the reviews are performed:

  • At least once every three months.
  • After significant changes to the in-scope environment.

A3.2.1.b Examine documented results of scope reviews occurring at least once every three months to verify that scoping validation includes all elements specified in this requirement.

Purpose

Frequent validation of PCI DSS scope helps to ensure PCI DSS scope remains up to date and aligned with changing business objectives, and therefore that security controls are protecting all appropriate system components.

Good Practice

Accurate scoping involves critically evaluating the CDE and all connected system components to determine the necessary coverage for PCI DSS requirements. Scoping activities, including careful analysis and ongoing monitoring, help to ensure that in-scope systems are appropriately secured.

When documenting account data locations, the entity can consider creating a table or spreadsheet that includes the following information:

  • Data stores (databases, files, cloud, etc.), including purpose of data storage and the retention period.
  • Which CHD elements are stored (PAN, expiry date, cardholder name, and/or any elements of SAD prior to completion of authorization).
  • How data is secured (type of encryption and strength, hashing algorithm and strength, truncation, tokenization).
  • How access to data stores is logged, including a description of logging mechanism(s) in use (enterprise solution, application level, operating system level, etc.).

In addition to internal systems and networks, all connections from third-party entities—for example, business partners, entities providing remote support services, and other service providers—need to be identified to determine inclusion for PCI DSS scope. Once the in-scope connections have been identified, the applicable PCI DSS controls can be implemented to reduce the risk of a third-party connection being used to compromise an entity's CDE.

A data discovery tool or methodology can be used to facilitate identifying all sources and locations of PAN, and to look for PAN that resides on systems and networks outside the currently defined CDE or in unexpected places within the defined CDE—for example, in an error log or memory dump file. This approach can help ensure that previously unknown locations of PAN are detected and that the PAN is either eliminated or properly secured.

Further Information

Refer to Information Supplement: Guidance for PCI DSS Scoping and Network Segmentation for additional guidance.

purpose

Designated Entities must maintain a current list of all PCI DSS requirements and responsible personnel.

compliance strategies

  • Responsibility matrix
  • Annual review

typical policies

  • PCI DSS Responsibility Matrix

common pitfalls

  • Outdated matrix
  • Unassigned requirements

type

Governance

difficulty

Low

key risks

  • Gaps in compliance coverage

recommendations

  • Review matrix during annual assessments

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