A3.2.3 Changes to organizational structure result in a formal (documented) review of the impact to PCI DSS scope and applicability of controls.
Defined Approach Requirements
A3.2.3 Changes to organizational structure result in a formal (documented) review of the impact to PCI DSS scope and applicability of controls.
PCI DSS Reference: Requirement 12
Customized Approach Objective
This requirement is not eligible for the customized approach.
Defined Approach Testing Procedures
A3.2.3 Examine policies and procedures to verify that a change to organizational structure results in a formal review of the impact on PCI DSS scope and applicability of controls.
Purpose
An organization's structure and management define the requirements and protocol for effective and secure operations. Changes to this structure could have negative effects to existing controls and frameworks by reallocating or removing resources that once supported PCI DSS controls or inheriting new responsibilities that may not have established controls in place. Therefore, it is important to revisit PCI DSS scope and controls when there are changes to an organization's structure and management to ensure controls are in place and active.
Examples
Changes to organizational structure include, but are not limited to, company mergers or acquisitions, and significant changes or reassignments of personnel with responsibility for security control.
purpose
Designated Entities must maintain documentation of PCI DSS scope confirmation activities.
compliance strategies
- Scope review logs
- Documentation retention
typical policies
- Scope Review Documentation Policy
common pitfalls
- No evidence of scope confirmation
type
Documentation Control
difficulty
Low
key risks
- Inability to demonstrate compliance
recommendations
- Centralize scope documentation
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