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A3.4.1 User accounts and access privileges to in-scope system components are reviewed at least once every six months

Original requirement from PCI DSS v4.0.1

Defined Approach Requirements

A3.4.1 User accounts and access privileges to in-scope system components are reviewed at least once every six months to ensure user accounts and access privileges remain appropriate based on job function, and that all access is authorized.

PCI DSS Reference: Requirement 7

Customized Approach Objective

This requirement is not eligible for the customized approach.

Defined Approach Testing Procedures

A3.4.1 Interview responsible personnel and examine supporting documentation to verify that:

  • User accounts and access privileges are reviewed at least every six months.
  • Reviews confirm that access is appropriate based on job function and that all access is authorized.

Purpose

Regular review of access rights helps to detect excessive access rights remaining after user job responsibilities change, system functions change, or other modifications. If excessive user rights are not revoked in due time, they may be used by malicious users for unauthorized access.

This review provides another opportunity to ensure that accounts for all terminated users have been removed (if any were missed at the time of termination), as well as to ensure that any third parties that no longer need access have had their access terminated.

purpose

Designated Entities must review and update documentation of PCI DSS compliance program at least annually.

compliance strategies

  • Annual review schedule
  • Version control

typical policies

  • Compliance Program Review Policy

common pitfalls

  • Missed reviews
  • No update documentation

type

Process Control

difficulty

Low

key risks

  • Stale or ineffective compliance program

recommendations

  • Automate review reminders

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