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Compensating Control

2/23/2018

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Compensating Control may be considered if PCI DSS requirement cannot meet a requirement due to legitimate Technical or Documented Business constraints.

Compensating Control must satisfy following:
1) Meet the intent and rigor of the original requirement.
2) Provide a similar level of defence as the original
3) Be "Above and Beyond" other PCI DSS Requirement.

What is above and beyong?
- If existing PCI DSS requirement CANNOT be considered as compensating Control if they are already required by the item under review.

- Existing PCI DSS requirement MAY be considered as compensating control if they are required for another area, but not required for the item under review.

- Existing PCI DSS requirement may be conbined with new control to become a compensating control.

Compensating Control Worksheet:
1) Constraints
2) Objective
3) Identified Risk
4) Defination of Compensating Controls
5) Validation of Compensating Controls
6) Maintainance




A.
 Be "above and beyond" other PCI DSS requirement (i.e., not simply in compliance with other requirements)
B. Sufficiently offset the risk that the original PCI DSS requirement was designed to defend against
C. Meet the intent and rigor of the original PCI requirement
​D. Be commensurate with additional risk imposed by not adhering to original requirement
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What are the 12 PCI Requirements

2/23/2018

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  1. Have Firewall
  2. No Defaults
  3. Protect Stored Data
    1. Hashing the entire PAN using strong cryptography while transferring
  4. Encrypt Transmission of Data over network
  5. Have Antivirus
  6. Develop and Maintain Secure System and applications
  7. Restrict access to card holder data - Role based access control.
    1. Restrict access to cardholder data by business need-to-know
  8. Assign a Unique ID to each person with computer access
    1. A digital certificate is a valid for "something you have" as long as it is unique for a particular user.
    2. ​Identify and authenticate access to system components
  9. Restrict Physical Access to Card Holder Data
  10. Track and Monitor all access to cardholder data and networks resources 
  11. Test Regularly
  12. Have a policy
    1. Information Security Policies must be reviewed/updated Yearly to meet requirement.
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