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PCI DSS and GDPR: Where Card Data Meets Personal Data

Where PCI DSS and GDPR overlap — CHD as personal data, dual compliance evidence, and breach duties.

Published: September 2026 Compliance · PCI DSS 8–12 min read

Cardholder data is often personal data under GDPR. Meeting PCI DSS does not automatically satisfy GDPR, and vice versa.

Run dual-tagged controls for encryption, access, retention, and incident response.

Retention clash: PCI minimises CHD storage; GDPR adds lawful basis and rights — design retention to satisfy both.

Overlap

Access control, encryption, logging, vendor diligence, and IR appear in both programmes.

Differences

Operating model

One evidence library with PCI requirement IDs and GDPR article tags.

How CyberSilo Helps

Talk to CyberSilo

Map evidence and operations with CyberSilo CSA and ThreatHawk.

Frequently Asked Questions

Is PAN personal data?

Typically yes when linked to an identifiable person — analyse with counsel.

DSAR for CHD?

Rights apply with security caveats — don't email raw PAN.

Processors?

Payment processors may be processors/controllers depending on facts.

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