7.2.1 Access control model defined
The entity must define an access control model that governs how access is granted. The model must provide: access that fits what the entity needs for its business and for access; access to data resources and system components based on each user's job classification and functions; and only the least privileges (for example user versus administrator) needed to carry out a job function. The guidance describes typical model elements (the resources to protect, the job functions needing access to them, and the activities each function performs, such as read, write or query), names role-based and attribute-based models as options, and suggests separation of duties as a design consideration. Objective under the customized approach: access requirements are set by job function following the principles of need to know and least privilege.
Source: PCI DSS v4.0.1, 7.2.1. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open PCI DSS v4.0.1 in the compliance library.
Version 4.0.1 is the active version; 4.0 has been retired. Appendix A1 applies only to multi-tenant service providers, A2 only to card-present POS POI terminals that still use SSL or early TLS, and A3 only when a payment brand or acquirer requires it. Which requirements apply to you follows your validation type.
These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.
system holds itEvidence a system already holds
- Configuration export from the IAM or directory platform showing implemented roles and groups · Identity provider / directory
periodic reviewEvidence produced at each review
none for this control
governing documentDocuments that govern the control
- Documented access control model (RBAC or ABAC) mapping job functions to resources and permitted activities · Policy repository / GRC workspace
- Role catalogue with privilege level (user, administrator) for each role · Policy repository / GRC workspace
- Separation-of-duties matrix identifying conflicting role combinations · Policy repository / GRC workspace
First move
Common gaps auditors find
- Roles are defined only for applications and not for infrastructure or database components
- Model grants broad default roles that exceed what most job functions need
- Documented model and the roles configured in the directory have drifted apart
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 sheet7.1.2 Requirement 7 roles and responsibilities assigned · 7.2.2 User access assigned by job function and least privilege