The unexpected CHD could become problematic in many ways. In fact, unexpected CHD can be a breach risk, and while processes should ensure unexpected CHD is impossible to create, staffers can sometimes create ad-hoc processes to overcome limitations of the sanctioned ones. Since Requirement 3.1.b asks for proof of a quarterly process to ensure that all legitimate CHD is identified and removed when its retention limit expires, it follows that the scans for unexpected CHD should be subject to at least the same periodicity. The scan they miss is the one that answers the question “how did you prove there is no cardholder data (CHD) outside the Cardholder Data Environment (CDE)”. (Requirement 3.1 is in Section 6 of the ROC). Many entities miss four of the required quarterly scans since they are not explicitly defined in the Standard but are referenced in Section (not Requirement) 3.1 of the Report on Compliance, which asks about the environment and methodology used to confirm the scope of the CDE. However, if a vulnerability takes a long time to fix, documentation of following the process and mitigating arrangements (such as additional firewall or IDS/IPS configurations) will need to be shown instead. A client may not wait for the next month’s scan to prove remediation. Remedial or correction scans must be provided as soon as practicable to prove that the CDE was vulnerable for the shortest practical period. PCI is VERY unforgiving if ASV scans do not occur within a 90-92 day cadence. Please refer to separate guidance on what constitutes a “significant change”. Some of the scans prescribed by the standard must be completed quarterly, others annually, and all have the caveat: “and repeated after a significant change”, this accounts for the qualifier “minimum” adjacent to the initial scan counts above. Each period thus derived should then be documented in the Entity’s Policy, Procedure, compliance calendar, or internal standards documentation set as appropriate. As a result, QSAs look to clients to use their risk assessments to define and justify periodicity for the various contexts in which the DSS grants discretion to the assessed entity. Some of the standard’s requirements must be performed “periodically” which is in quotes because the standard does not define the period covered by that term. New entities going through compliance for the first time can provide just the most recent quarter’s worth of each of the applicable scans (and rescans, if necessary) as long as they are “clean”, i.e., they passed all the required elements with no critical or serious findings. The fourth blog on API testing for compliance is here.Īs a risk-based response to the continuous, and varied assaults on our systems by criminals, the PCI DSS standard requires a minimum of 20 technical scans per full year for merchants, and 21 for third-party service providers (TPSPs) The table below lists them. The third blog on network and data flow diagrams for PCI DSS compliance is here. See the second blog on PCI DSS reporting details to ensure when contracting quarterly CDE tests here. See the first blog relating to IAM and PCI DSS here. This is the fifth blog in the series focused on PCI DSS, written by an AT&T Cybersecurity consultant.
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