3.4.2 Technical controls prevent unauthorized PAN copy
When using remote-access technologies, technical controls prevent copy and relocation of PAN for all personnel except those with documented, explicit authorization.
5
artefacts
1
held by a system
1
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
- VDI or jump host configuration disabling clipboard and storage · Cloud console / configuration management
periodic reviewEvidence produced at each review
- Quarterly review of permitted users · Data governance / DLP tooling
governing documentDocuments that govern the control
- DLP policy blocking PAN egress · Policy repository / GRC workspace
- Authorisation register · Policy repository / GRC workspace
- Sample test of copy prevention · Policy repository / GRC workspace
First move
Mostly documents and reviews. Pull the 1 system-held artefact from your Cloud console / configuration management on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.
Common gaps auditors find
- Clipboard not disabled on remote sessions
- DLP not tuned for PAN
- No authorisation register
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 sheet3.4.1 PAN is masked when displayed (the BIN and last four digits are the maximum number of digits to be displayed), such that only personnel with a legitimate business need can · 3.5.1 PAN rendered unreadable wherever stored