Key Takeaways:
- Clarify Scope and Current State Early: Begin by reviewing existing documentation like the ROC or SAQ, network diagrams, and gap assessments to understand where cardholder data resides and who owns each system. This foundational clarity shapes your entire PCI compliance strategy.
- Establish Ownership and Year-Round Accountability: Build an internal matrix mapping each PCI DSS requirement to a responsible owner, track evidence, and maintain visibility year-round — not just during audit season. Even a basic Excel tracker can support this process.
- Treat Your QSA as a Strategic Partner: Manage assessments like projects with structured timelines and clear communication. Collaborate with your QSA to proactively address control gaps and strengthen security, not just to “pass” an audit.
A QSA’s Guide for New GRC Professionals
Stepping into a GRC role responsible for PCI DSS compliance can be both exciting and daunting. Many organizations experience turnover in this function; a prior compliance manager moves on, and suddenly a new person inherits the PCI program. Sometimes that person has deep PCI experience; other times, they’re learning the framework from scratch.
What we often see is that documentation is scattered, key processes live in the heads of a few people, and there’s no centralized GRC or compliance tool in place. In these situations, the organization may rely heavily on its assessor’s tools and workflow — convenient in the short term, but risky in the long term. If personnel or assessors change, critical institutional knowledge can disappear overnight.
Having worked as a Qualified Security Assessor (QSA) across hundreds of PCI DSS assessments, I’ve seen how quickly a PCI program can drift and how strong leadership and structure from the GRC function can turn it around. Here’s how to effectively manage a PCI program when you’re the new face in the compliance seat.
Step 1: Understand Your PCI DSS Scope and Current State of Compliance
Your first task is to get clear on PCI DSS scope and the current state of your compliance program. Request copies of the latest Report on Compliance (ROC) or Self-Assessment Questionnaire (SAQ), network diagrams, and any gap assessments or scope validation reports.
Map out:
- Where cardholder data is stored, processed, or transmitted
- What segmentation controls isolate that environment
- Which vendors and third parties handle cardholder data
- Who owns each system and process
This foundational understanding will guide every PCI activity you manage. If you need help getting started, LBMC’s PCI Flash or Gap Assessment service helps new GRC leaders rapidly identify gaps and build a roadmap to compliance.
Step 2: Build Ownership and Accountability for PCI Requirements
Even if your QSA provides a robust evidence management platform, your organization needs its own internal PCI tracking process. You should be able to answer, at any time:
- Who owns each PCI DSS requirement?
- When was it last tested or reviewed?
- Where is the supporting evidence stored?
- What was last year’s QSA feedback?
Create a living matrix mapping each requirement to internal owners — IT, Security, DevOps, Finance, or Compliance. Track status, due dates, and evidence collection cycles.
Even without a GRC tool, a simple Excel-based tracker can work. The key is maintaining visibility and accountability throughout the year — not just during audit season.
Step 3: Manage the PCI DSS Assessment Like a Project (and a Partnership)
Most PCI DSS assessments follow a structured process:
- Collect core scoping evidence (network diagrams, system inventories, segmentation documentation, third-party lists).
- Conduct working sessions to observe controls and interview control owners.
- Review documentation and validate results.
- >Generate reports.
Your role as the GRC professional is to project manage this process from your organization’s side — scheduling sessions, coordinating evidence, and maintaining communication between your QSA and internal teams.
But here’s the real challenge: control owners are busy. PCI might not be their top priority. Your job is to make participation as easy as possible, provide clear instructions, send calendar holds for working audit sessions, and explain >why their evidence matters.
If engagement becomes difficult, escalate for executive support. Leadership reinforcement that “PCI is a business priority” can make all the difference.
Pro tips:
- Brief control owners before each session to clarify topics and expectations.
- Capture action items and deadlines after every discussion.
- Communicate proactively with your QSA about scheduling, readiness, and constraints.
This keeps the assessment efficient, minimizes rework, and establishes a professional rhythm with your assessor — one that strengthens each year.
Step 4: Maintain Continuous PCI Compliance Year-Round
Under PCI DSS v4.0, organizations must demonstrate continuous compliance, not just point-in-time certification. That means recurring activities — such as scans, training, and reviews — must be executed consistently and well-documented.
A mature PCI program operates on a compliance calendar that tracks:
- Quarterly internal and external vulnerability scans
- Wireless access point scans
- User account and access reviews
- Incident response tests
- Firewall rule reviews
- Annual policy and training updates and more!
LBMC’s PCI Continuous Compliance Program helps organizations operationalize this approach with quarterly QSA reviews and ongoing advisory support. Even if managed internally, make it a habit to review your PCI compliance status every quarter — not just before audit time.
Step 5: Collaborate with Your QSA to Strengthen Security
When audit week arrives, remember: it’s not a test to “pass” — it’s a process to validate and improve controls.
A strong QSA partnership is built on transparency and collaboration. Be upfront about control gaps or exceptions; address them early to avoid last-minute issues. Encourage your teams to ask questions — these sessions often surface valuable security improvements beyond compliance itself.
With PCI DSS v4.0, you can also leverage customized approaches that provide flexibility while maintaining compliance. If you go this route, engage your assessor early to define success criteria and required evidence.
LBMC provides comprehensive advisory and compliance support. Connect with a local expert today. With offices in Chattanooga, Memphis, Louisville, Nashville, Knoxville, and Charlotte, plus remote support, the firm supports clients across the Southeast.
Key Takeaways for New GRC Professionals Managing PCI DSS
- Start with clarity: Understand PCI DSS scope, data flows, and system ownership early.
- Own your matrix: Map every PCI requirement to internal stakeholders and evidence owners.
- Stay proactive: Build a quarterly compliance calendar to avoid last-minute fire drills.
- Educate and engage: Help control owners understand their PCI responsibilities.
- Partner with your QSA: Treat the assessor relationship as a collaboration, not an audit test.
Building a Sustainable PCI DSS Compliance Program
Taking over a PCI program is no small task, but it’s also a great opportunity to modernize documentation, strengthen collaboration, and establish sustainable PCI DSS compliance processes.
Start with clear scoping, build internal ownership, manage the assessment like a project, and engage leadership along the way. When PCI becomes part of your organization’s operational DNA, the annual assessment transforms from a stressful event into a simple, repeatable validation.
And if you’re looking for a partner to guide you through it, LBMC can help. Our experienced QSAs provide hands-on PCI compliance guidance, quarterly reviews, and structured programs designed to make compliance manageable and repeatable.
Visit our website or contact Stewart Fey to learn how LBMC can help you build and sustain a successful PCI compliance program.
New to PCI compliance? Learn how to manage your organization’s PCI DSS program, build accountability, and work effectively with your QSA. Get practical steps from LBMC’s experienced PCI assessors.
Content provided by Stewart Fey, Shareholder, LBMC Cybersecurity. Contact him at stewart.fey@lbmc.com.
Take the next step toward a more resilient and efficient compliance function. Talk with LBMC’s advisors for tailored support.
Frequently Asked Questions
What is the first step when taking over a PCI compliance program?
Start by reviewing your most recent ROC or SAQ, along with network diagrams and gap assessments. Understanding scope and current compliance posture sets the foundation for everything else.
How can I keep my PCI DSS compliance program on track year-round?
Establish a recurring PCI compliance calendar that includes quarterly scans, user access reviews, and incident response exercises. Continuous visibility helps maintain readiness between audits.
What if my organization doesn’t have a GRC tool?
That’s okay. Start with a structured Excel tracker that assigns PCI requirements to owners, due dates, and evidence locations. You can scale to tools later for automation and reporting.
How can I make PCI assessments easier for control owners?
Prepare them in advance, communicate expectations clearly, and schedule meetings efficiently. Remind them that PCI compliance supports the business by protecting customer data and reducing risk.