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GDPR vs PCI, how do the scopes overlap?

They overlap in 3 places and diverge in the rest:

Overlap (both frameworks require these):

  • Encryption at rest: PCI mandates it for cardholder data; GDPR mandates it for any "special category" personal data, both effectively require database-at-rest encryption.
  • Access logging: PCI requires admin-access logs for ~12 months; GDPR requires audit trails for processing of personal data. One SIEM serves both.
  • Breach notification: PCI doesn’t mandate customer notification but card brands do (typically 30 days); GDPR mandates regulator notification within 72 hours of awareness.

PCI-only (not GDPR):

  • Specific cryptography requirements (e.g. TLS 1.2+ mandate).
  • Quarterly external vulnerability scans by an ASV.
  • Annual penetration testing for SAQ A-EP and higher.
  • Specific compensating controls + scoping rules.

GDPR-only (not PCI):

  • Right to data export (subject access request, 30-day SLA).
  • Right to be forgotten (data deletion, 30-day SLA).
  • Lawful basis documentation for every processing activity.
  • DPIA (Data Protection Impact Assessment) for high-risk processing.
  • Privacy by design + by default.

The audit’s q14 specifically checks for the GDPR-only data-export endpoint, because PCI doesn’t cover that and stores often miss it. If you sell to EU/UK customers, GDPR applies regardless of where your servers live.

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