12.9.2
Defined Approach Requirements:
Additional requirement for service providers only: TPSPs support their customers’ requests for information to meet Requirements 12.8.4 and 12.8.5 by providing the following upon customer request:
- PCI DSS compliance status information for any service the TPSP performs on behalf of customers (Requirement 12.8.4).
- Information about which PCI DSS requirements are the responsibility of the TPSP and which are the responsibility of the customer, including any shared responsibilities (Requirement 12.8.5).
Customized Approach Objective:
TPSPs provide information as needed to support their customers’ PCI DSS compliance efforts.
Applicability Notes:
This requirement applies only when the entity being assessed is a service provider.
Defined Approach Testing Procedures:
- 12.9.2 Additional testing procedure for service provider assessments only: Examine policies and procedures to verify processes are defined for the TPSPs to support customers’ request for information to meet Requirements 12.8.4 and 12.8.5 in accordance with all elements specified in this requirement.
Purpose:
If a TPSP does not provide the necessary information to enable its customers to meet their security and compliance requirements, the customers will not be able to protect cardholder data nor meet their own contractual obligations.
Good Practice:
If a TPSP has a PCI DSS Attestation of Compliance (AOC), the expectation is that the TPSP should provide that to customers upon request to demonstrate their PCI DSS compliance status.
If the TPSP did not undergo a PCI DSS assessment, they may be able to provide other sufficient evidence to demonstrate that it has met the applicable requirements without undergoing a formal compliance validation. For example, the TPSP can provide specific evidence to the entity’s assessor so the assessor can confirm applicable requirements are met. Alternatively, the TPSP can elect to undergo multiple on-demand assessments by each of its customers’ assessors, with each assessment targeted to confirm that applicable requirements are met.
TPSPs should provide sufficient evidence to their customers to verify that the scope of the TPSP’s PCI DSS assessment covered the services applicable to the customer and that the relevant PCI DSS requirements were examined and determined to be in place.
TPSPs may define their PCI DSS responsibilities to be the same for all their customers; otherwise, this responsibility should be agreed upon by both the customer and TPSP. It is important that the customer understands which PCI DSS requirements and sub-requirements its TPSPs have agreed to meet, which requirements are shared between the TPSP and the customer, and for those that are shared, specifics about how the requirements are shared and which entity is responsible for meeting each sub-requirement. An example of a way to document these responsibilities is via a matrix that identifies all applicable PCI DSS requirements and indicates whether the customer or TPSP is responsible for meeting that requirement or whether it is a shared responsibility.
Further Information:
For further guidance, refer to:
- PCI DSS section: Use of Third-Party Service Providers.
- Information Supplement: Third-Party Security Assurance (includes a sample responsibility matrix template).