PCI DSS Requirement 10.7 mandates that audit trail history is retained for at least one year, with a minimum of three months of logs immediately available for analysis. A 30-day retention period is insufficient for investigating security incidents, tracking suspicious activity over time, or meeting compliance evidence requests.

PCI DSS Requirement 4 requires that cardholder data be encrypted during transmission over open, public networks. Relying on an automatic failover to an untrusted public network creates an uncontrolled and high-risk path for data transmission, making it vulnerable to eavesdropping and man-in-the-middle attacks, regardless of how infrequently it is used.

PCI DSS Requirement 2.1 is explicit: all default passwords must be changed, and unnecessary default accounts must be removed or disabled before a system is installed on the network. This includes vendor-supplied generic accounts, which are well-known to attackers. Vendor support should use uniquely named, monitored accounts created specifically for them.

PCI DSS Requirement 12.10 requires an incident response plan that includes notification of payment card brands and acquirers. Each card brand (Visa, Mastercard, etc.) has its own mandatory rules, timelines (often within 24-72 hours), and reporting channels for suspected compromises. Simply deferring to a legal department may not ensure these critical, time-sensitive notifications are made correctly.

A jump host or bastion host provides a single, fortified point of entry that enforces strong authentication, logs all access attempts and commands, and limits the pathways into the CDE. This aligns with the principle of least privilege and PCI DSS requirements for secure access (Req 8) and tracking all access (Req 10). Direct connections or permanent rules weaken segmentation and increase the attack surface.

The cornerstone of PCI scoping is the flow of cardholder data. With a redirect or iframe method, if the merchant’s website never touches the actual card data (the consumer is sent directly to the processor’s secure page), then the website may be largely out of scope. If the website accepts the data before passing it to the processor, even momentarily, the entire system that handles that data is in scope.

PCI DSS Requirement 11.2.2 requires that external vulnerability scans be performed quarterly and after any significant change. The requirement is to perform scans and address any vulnerabilities found. While risk ranking helps prioritize, all vulnerabilities must be addressed, typically by applying patches, implementing compensating controls, or documenting a legitimate business reason for acceptance. Re-scanning to verify remediation is a standard part of the process.

Least privilege (PCI DSS Req 7) is a fundamental security control. DBAs with excessive privileges could, intentionally or accidentally, view, modify, or delete sensitive cardholder data, bypass logging mechanisms, or alter database configurations in a way that compromises security. Restricting their access to the minimum necessary for their specific duties is a key defense layer in protecting the CDE.

PCI DSS Requirement 3.3 mandates that the PAN be masked when displayed (the first six and last four digits are the maximum allowed to be shown). Paper receipts are a form of display. Storing receipts with the full PAN violates this requirement and unnecessarily increases the risk of compromise. The data should be truncated on the receipt at the point of printing.

PCI DSS Requirement 10.7 mandates that audit trail history is retained for at least one year, with a minimum of three months of logs immediately available for analysis. A 30-day retention period is insufficient for investigating security incidents, tracking suspicious activity over time, or meeting compliance evidence requests.0