You are selecting controls for a system that must comply with both NIST SP 800-53 and the Payment Card Industry Data Security Standard (PCI DSS). The system processes credit card transactions. You have identified overlapping controls, but some PCI DSS requirements are more prescriptive than the NIST controls. What is the most effective approach to reconcile these differences during control selection?
Using NIST as the primary baseline and adding PCI DSS-specific controls as an overlay allows you to leverage the comprehensive NIST framework while addressing PCI DSS's more prescriptive requirements. This approach avoids duplication and ensures compliance with both. Overlays are designed for such scenarios, enabling the addition of controls to meet specific mandates.
Why this answer
The most effective approach is to use NIST SP 800-53 as the primary baseline and add PCI DSS-specific controls as an overlay. This leverages the comprehensive NIST framework and addresses PCI DSS's stricter requirements without duplication. It ensures compliance with both standards and maintains a structured, defensible control set.
Exam trap
The trap here is assuming that one standard completely covers the other, rather than recognizing the need to augment the baseline with an overlay for stricter requirements.