EvidenceSheet
PCI DSS v4.0.1 · Req 7: Restrict Access by Need to Know

7.2.3 Privileges approved by authorized personnel

Every privilege a user needs must be approved by personnel authorized to do so. The testing procedures check that documented approval exists for assigned privileges, that it came from authorized personnel, and that the privileges are consistent with the roles the individual holds. The guidance explains that documented approval (in writing or electronically) shows management knows who holds which access and that the access is necessary for the job. Customized approach objective: no user can receive access privileges without appropriate, documented authorization.

Source: PCI DSS v4.0.1, 7.2.3. 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.

4
artefacts
1
held by a system
1
at each review
moderate
to go live
Identity provider / directory
where the evidence lives
teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

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

  • Access request tickets or workflow records showing approver identity and date · Identity provider / directory

periodic reviewEvidence produced at each review

  • Sample reconciliation of current user privileges against approval records · Identity provider / directory

governing documentDocuments that govern the control

  • List of personnel authorized to approve access, by system or data set · Policy repository / GRC workspace
  • Procedure describing the approval process for standard and privileged access · Policy repository / GRC workspace

First move

Start with the 1 of 4 artefacts that already live in a system (Identity provider / directory); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

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 sheet

7.2.2 User access assigned by job function and least privilege · 7.2.4 User accounts and privileges reviewed every six months