PCI DSS 9.3.1: Authorize and Manage Personnel Physical Access to the CDE
Controlling who enters your cardholder data environment is fundamental to PCI DSS compliance. Control 9.3.1 requires documented procedures for authorizing and managing physical access to your CDE. Without proper access controls, you expose sensitive card data to unauthorized personnel and internal threats.
What this means
This control requires organizations to establish and maintain formal procedures that define how personnel are authorized to physically access the cardholder data environment. It encompasses the entire access lifecycle: request, approval, granting access, and ongoing management. Organizations must document who is permitted to access which areas of the CDE, based on business need and role, and ensure these authorizations are reviewed and updated regularly.
How to comply
- 1.Document access authorization procedures that specify roles, responsibilities, and approval workflows for CDE access requests
- 2.Define physical access requirements by job function and document the business justification for each approval
- 3.Implement a formal authorization process requiring management approval before granting or modifying CDE access
- 4.Maintain an up-to-date list of authorized personnel with their access privileges and approval dates
- 5.Establish a periodic review schedule (at minimum quarterly) to verify access authorizations remain valid and necessary
- 6.Revoke or modify access promptly when personnel change roles, transfer departments, or separate from the organization
- 7.Document all access authorization decisions and maintain records for audit purposes
Evidence auditors look for
- Physical access authorization policy document with defined procedures and approval workflows
- Access request forms signed by requestor and authorized manager with business justification
- Current list of authorized CDE personnel with job titles, access types, and authorization dates
- Access approval records showing management sign-off before access is granted
- Quarterly access review documentation with sign-offs confirming authorization validity
- Access modification or revocation records with effective dates and approval documentation
- Building access logs or badge swipe records correlating to authorized personnel
Frequently asked questions
When will FAQs be available?
The FAQ for this control is currently being prepared.
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