PCI DSS 4.0 to HIPAA Security Rule crosswalk

28 control objectives in PCI DSS are mapped here to HIPAA Security Rule and Breach Notification Rule. 4 of them have no direct HIPAA Security Rule requirement, which is marked in the table. Each row is one shared objective, with the requirement ids on both sides.

Control objective	PCI DSS 4.0	HIPAA Security Rule
Security governance and policies	`12.1`A comprehensive information security policy is established, published, maintained and disseminated `12.4`PCI DSS compliance is managed	`164.308(a)(1)(i)`Security management process `164.316(a)`Policies and procedures
Security roles and accountability	`12.1.3`Security policy defines information security roles and responsibilities `12.4.1`Executive management responsibility for protection of cardholder data (service providers)	`164.308(a)(2)`Assigned security responsibility
Risk assessment and treatment	`12.3`Risks to the cardholder data environment are formally identified, evaluated and managed `12.3.1`Targeted risk analysis for requirements with flexible frequency	`164.308(a)(1)(ii)(A)`Risk analysis `164.308(a)(1)(ii)(B)`Risk management
Asset and system inventory	`12.5.1`Inventory of system components in scope for PCI DSS is maintained `12.5.2`PCI DSS scope is documented and confirmed at least every 12 months	`164.310(d)(2)(iii)`Accountability (record of hardware and media movements)
Data classification and handling	`12.5.2`PCI DSS scope is documented and confirmed (includes identifying all data flows)	`164.308(a)(1)(ii)(A)`Risk analysis (requires identifying where ePHI lives)
Access provisioning, review and removal	`7.2`Access to system components and data is appropriately defined and assigned (incl. 7.2.4 six-month review) `7.3`Access is managed via an access control system `8.2.5`Access for terminated users is immediately revoked	`164.308(a)(3)`Workforce security (authorization, supervision, termination) `164.308(a)(4)`Information access management
Least privilege and privileged access	`7.2.1`An access control model is defined `7.2.2`Access assigned based on job classification and least privileges	`164.312(a)(1)`Access control `164.308(a)(4)`Information access management
Authentication, unique IDs and multi-factor authentication	`8.2`User identification and related accounts are strictly managed `8.3`Strong authentication for users and administrators is established and managed `8.4`Multi-factor authentication is implemented `8.5`MFA systems are configured to prevent misuse	`164.312(d)`Person or entity authentication `164.312(a)(2)(i)`Unique user identification
Encryption at rest and key management	`3.5`Primary account number is secured wherever it is stored `3.6`Cryptographic keys used to protect stored account data are secured `3.7`Key management processes and procedures are defined and implemented	`164.312(a)(2)(iv)`Encryption and decryption (addressable)
Encryption in transit	`4.2`PAN is protected with strong cryptography during transmission `2.2.7`All non-console administrative access is encrypted	`164.312(e)(1)`Transmission security
Network security and segmentation	`1.2`Network security controls are configured and maintained `1.3`Network access to and from the cardholder data environment is restricted `1.4`Network connections between trusted and untrusted networks are controlled	no direct requirement
Secure configuration and hardening	`2.2`System components are configured and managed securely	no direct requirement
Vulnerability scanning and patching	`6.3`Security vulnerabilities are identified and addressed `11.3`External and internal vulnerabilities are regularly identified, prioritized and addressed	`164.308(a)(8)`Evaluation (periodic technical evaluation)
Penetration testing and independent assessment	`11.4`External and internal penetration testing is regularly performed	`164.308(a)(8)`Evaluation
Logging, log review and monitoring	`10.2`Audit logs are implemented to support detection of anomalies and suspicious activity `10.3`Audit logs are protected from destruction and unauthorized modification `10.4`Audit logs are reviewed to identify anomalies or suspicious activity `10.5`Audit log history is retained and available for analysis `10.6`Time-synchronization mechanisms support consistent time settings	`164.312(b)`Audit controls `164.308(a)(1)(ii)(D)`Information system activity review
Intrusion detection and integrity monitoring	`11.5`Network intrusions and unexpected file changes are detected and responded to `11.6`Unauthorized changes on payment pages are detected and responded to	`164.312(c)(1)`Integrity
Malware protection	`5.2`Malicious software is prevented, or detected and addressed `5.3`Anti-malware mechanisms and processes are active, maintained and monitored `5.4`Anti-phishing mechanisms protect users against phishing attacks	`164.308(a)(5)(ii)(B)`Protection from malicious software
Incident response and breach notification	`12.10`Suspected and confirmed security incidents that could impact the CDE are responded to immediately (12.10.1 IR plan, 12.10.2 annual review and test)	`164.308(a)(6)`Security incident procedures `164.404`Notification to individuals (Breach Notification Rule)
Change management	`6.5`Changes to all system components are managed securely (6.5.1 change control procedures)	no direct requirement
Secure software development	`6.2`Bespoke and custom software is developed securely `6.4`Public-facing web applications are protected against attacks	no direct requirement
Third-party and vendor risk management	`12.8`Risk to information assets associated with third-party service provider relationships is managed `12.9`Third-party service providers support their customers' PCI DSS compliance	`164.308(b)(1)`Business associate contracts and other arrangements `164.314(a)`Business associate contracts or other arrangements
Business continuity and disaster recovery	`12.10.1`Incident response plan includes business recovery and continuity procedures	`164.308(a)(7)`Contingency plan
Backup and redundancy	`12.10.1`Incident response plan includes data backup processes `9.4.1.1`Offline media backups with cardholder data are stored in a secure location	`164.308(a)(7)(ii)(A)`Data backup plan `164.308(a)(7)(ii)(B)`Disaster recovery plan
Security awareness and training	`12.6`Security awareness education is an ongoing activity (12.6.1 program, 12.6.2 annual review, 12.6.3 training at hire and annually)	`164.308(a)(5)`Security awareness and training
Personnel screening, terms and sanctions	`12.7`Personnel are screened to reduce risks from insider threats	`164.308(a)(3)(ii)(B)`Workforce clearance procedure `164.308(a)(3)(ii)(C)`Termination procedures `164.308(a)(1)(ii)(C)`Sanction policy
Physical access and facility security	`9.2`Physical access controls manage entry into facilities and systems containing cardholder data `9.3`Physical access for personnel and visitors is authorized and managed	`164.310(a)`Facility access controls
Data retention, media handling and secure disposal	`3.2`Storage of account data is kept to a minimum (3.2.1 retention and disposal) `9.4`Media with cardholder data is securely stored, accessed, distributed and destroyed	`164.310(d)(2)(i)`Disposal `164.310(d)(2)(ii)`Media re-use
Ongoing control monitoring and internal audit	`12.4.2`Reviews confirm personnel perform tasks per policy (service providers)	`164.308(a)(8)`Evaluation

Open a control objective for the evidence checklist.HIPAA Security Rule to PCI DSS 4.0 →

Scope: Mapped at requirement / sub-requirement level. Many PCI requirements only apply to the cardholder data environment (CDE) or to service providers. Citations are to 45 CFR 164. 'Addressable' vs 'required' implementation specifications are not distinguished here. Several themes have no direct HIPAA citation. A mapping means the requirements address the same objective. It does not mean satisfying one satisfies the other, because scope, frequency and evidence rules differ.

More from PCI DSS 4.0

PCI DSS 4.0 to SOC 2 PCI DSS 4.0 to NIST CSF 2.0 PCI DSS 4.0 to ISO 27001:2022 PCI DSS 4.0 to NIST 800-53 r5