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.