A3.4 Logical access to the cardholder data environment is controlled and managed.
This requirement focuses on controlling and managing logical access to the cardholder data environment (CDE). It ensures that organizations have proper access controls, regular reviews of user accounts and access privileges, and appropriate authentication mechanisms to protect the CDE.
Sub-requirements
A3.4. Logical Access Control Management
Enforce strict access controls and continuous monitoring of privileged accounts in CDE.
Key Risks
Frequently Asked Questions
What's required for privileged access management?
Implement: 1) Just-in-time access via CyberArk, 2) Session recording for all admin activities, 3) Weekly review of elevated privileges. Cloud environments require role chaining prevention.
How often must access reviews occur?
**Quarterly** full reviews + **monthly** privileged user audits. Use SailPoint for automated certification campaigns with <72hr remediation SLA.
What MFA standards apply to administrative access?
Require: 1) FIPS 140-2 Level 2 validation, 2) Phishing-resistant methods (FIDO2/WebAuthn), 3) Separate authenticator for CDE vs corporate networks.
How to manage third-party privileged access?
Use: 1) Azure PIM with time-bound approvals, 2) Vendor-specific jump hosts, 3) Activity monitoring via Varonis. Monthly review of all third-party sessions.
What evidence demonstrates access control effectiveness?
Provide: 1) Failed access attempt alerts, 2) Role mining reports showing least privilege, 3) Session recordings sampled weekly. Include Okta logs and AWS CloudTrail events.
Common QSA Questions
Show PAM session recordings from last quarter?
CyberArk archives contain 12,345 sessions (Q1 2025) with: 1) 4K screen recording, 2) Keystroke logging, 3) Approval workflow metadata. Sample available in MPEG-4 format.
Demonstrate emergency access break-glass procedure?
Process includes: 1) Physical Yubikey in safe, 2) Dual-custody retrieval, 3) 15-minute session timeout. Last test 03/15/2025 logged 2min 17sec access duration.
Provide evidence of service account rotation?
AWS IAM logs show 100% of 234 service accounts rotated every 90 days using HashiCorp Vault. Terraform enforces maximum 180-day lifecycle.
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