PCXProgram controls
Controls should follow data and decisions from Shopify intake through eligibility, provider coordination, customer communication, support, reporting, change, and closure.
Define the minimum data each participant needs, approved transfer paths, access boundaries, retention periods, monitoring, and incident ownership. Card-sensitive processes remain with appropriately controlled systems and providers.
Automated decisions need versioned policies, reliable inputs, safe retry behavior, and observable failures. Manual decisions need limited authority, reason records, escalation, and periodic review.
Provider diligence should confirm legal roles, program authority, network and issuer context, security responsibilities, service ownership, reporting, incident response, subcontractors, and exit provisions.