12.5.3 Impact analysis on org structure changes (SP)
Additional requirement for service providers: significant changes to organizational structure result in a documented review of the impact on PCI DSS scope and applicability of controls.
5
artefacts
0
held by a system
2
at each review
hard
to go live
Policy repository / GRC workspace
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- Sign-off by PCI program owner · Document repository
- Communication records · Policy repository / GRC workspace
governing documentDocuments that govern the control
- Procedure for triggering scope review on org changes · Policy repository / GRC workspace
- Sample impact analyses from past M&A or reorg · Document repository
- Updated scope documentation post-change · Policy repository / GRC workspace
First move
This control is evidenced by people and documents, not systems. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date. Do not try to automate it.
Common gaps auditors find
- No procedure
- Org changes not flagged
- No impact analyses on file
Do this for your whole sheet
Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.
Build my evidence sheet12.5.2.1 Service provider scope confirmed every 6 months · 12.6.1 Formal security awareness program implemented