9.4: 1. All media with cardholder data is physically secured.
  • 9.4.1. Examine documentation to verify that the procedures defined for protecting cardholder data include controls for physically securing all media.

Description

Purpose

Controls for physically securing media are intended to prevent unauthorized persons from gaining access to cardholder data on any media. Cardholder data is susceptible to unauthorized viewing, copying, or scanning if it is unprotected while it is on removable or portable media, printed out, or left on someone’s desk.

9.4: 1.1. Offline media backups with cardholder data are stored in a secure location.
  • Examine documentation to verify that procedures are defined for physically securing offline media backups with cardholder data in a secure location.
  • Examine logs or other documentation and interview responsible personnel at the storage location to verify that offline media backups are stored in a secure location.

Description

Purpose

If stored in a non-secured facility, backups containing cardholder data may easily be lost, stolen, or copied for malicious intent.

Good Practice

For secure storage of backup media, a good practice is to store media in an off-site facility, such as an alternate or backup site or commercial storage facility.

9.4: 1.2. The security of the offline media backup location(s) with cardholder data is reviewed at least once every 12 months.
  • Examine documentation to verify that procedures are defined for reviewing the security of the offline media backup location(s) with cardholder data at least once every 12 months.
  • Examine documented procedures, logs, or other documentation, and interview responsible personnel at the storage location(s) to verify that the storage location’s security is reviewed at least once every 12 months.

Description

Purpose

Conducting regular reviews of the storage facility enables the organization to address identified security issues promptly, minimizing the potential risk. It is important for the entity to be aware of the security of the area where media is being stored.

9.4: 2. All media with cardholder data is classified in accordance with the sensitivity of the data.
  • Examine documentation to verify that procedures are defined for classifying media with cardholder data in accordance with the sensitivity of the data.
  • Examine media logs or other documentation to verify that all media is classified in accordance with the sensitivity of the data.

Description

Purpose

Media not identified as confidential may not be adequately protected or may be lost or stolen.

Good Practice

It is important that media be identified such that its classification status is apparent. This does not mean however that the media needs to have a “confidential” label.

9.4: 3. Media with cardholder data sent outside the facility is secured as follows: (a) Media sent outside the facility is logged, (b) Media is sent by secured courier or other delivery method that can be accurately tracked, (c) Offsite tracking logs include details about media location.
  • Examine documentation to verify that procedures are defined for securing media sent outside the facility in accordance with all elements specified in this requirement.
  • Interview personnel and examine records to verify that all media sent outside the facility is logged and sent via secured courier or other delivery method that can be tracked.
  • Examine offsite tracking logs for all media to verify tracking details are documented.

Description

Purpose

Media may be lost or stolen if sent via a non- trackable method such as regular postal mail. The use of secure couriers to deliver any media that contains cardholder data allows organizations to use their tracking systems to maintain inventory and location of shipments.

9.4: 4. Management approves all media with cardholder data that is moved outside the facility (including when media is distributed to individuals).
  • Examine documentation to verify that procedures are defined to ensure that media moved outside the facility is approved by management.
  • Examine offsite media tracking logs and interview responsible personnel to verify that proper management authorization is obtained for all media moved outside the facility (including media distributed to individuals).

Description

Purpose

Without a firm process for ensuring that all media movements are approved before the media is removed from secure areas, the media would not be tracked or appropriately protected, and its location would be unknown, leading to lost or stolen media.

9.4: 5. Inventory logs of all electronic media with cardholder data are maintained.
  • Examine documentation to verify that procedures are defined to maintain electronic media inventory logs.
  • Examine electronic media inventory logs and interview responsible personnel to verify that logs are maintained.

Description

Purpose

Without careful inventory methods and storage controls, stolen or missing electronic media could go unnoticed for an indefinite amount of time.

9.4: 5.1. Inventories of electronic media with cardholder data are conducted at least once every 12 months.
  • Examine documentation to verify that procedures are defined to conduct inventories of electronic media with cardholder data at least once every 12 months.
  • Examine electronic media inventory logs and interview personnel to verify that electronic media inventories are performed at least once every 12 months.

Description

Purpose

Without careful inventory methods and storage controls, stolen or missing electronic media could go unnoticed for an indefinite amount of time.

9.4: 6. Hard-copy materials with cardholder data are destroyed when no longer needed for business or legal reasons, as follows: (a) Materials are cross-cut shredded, incinerated, or pulped so that cardholder data cannot be reconstructed, (b) Materials are stored in secure storage containers prior to destruction.
  • Examine the media destruction policy to verify that procedures are defined to destroy hard- copy media with cardholder data when no longer needed for business or legal reasons in accordance with all elements specified in this requirement.
  • Observe processes and interview personnel to verify that hard-copy materials are cross-cut shredded, incinerated, or pulped such that cardholder data cannot be reconstructed.
  • Observe storage containers used for materials that contain information to be destroyed to verify that the containers are secure.

Description

Purpose

If steps are not taken to destroy information contained on hard-copy media before disposal, malicious individuals may retrieve information from the disposed media, leading to a data compromise. For example, malicious individuals may use a technique known as “dumpster diving,” where they search through trashcans and recycle bins looking for hard-copy materials with information they can use to launch an attack.

Securing storage containers used for materials that are going to be destroyed prevents sensitive information from being captured while the materials are being collected.

Good Practice

Consider “to-be-shredded” containers with a lock that prevents access to its contents or that physically prevent access to the inside of the container.

Further Information

See NIST Special Publication 800-88, Revision 1: Guidelines for Media Sanitization .

9.4: 7. Electronic media with cardholder data is destroyed when no longer needed for business or legal reasons via one of the following: (a) The electronic media is destroyed, (b) The cardholder data is rendered unrecoverable so that it cannot be reconstructed.
  • Examine the media destruction policy to verify that procedures are defined to destroy electronic media when no longer needed for business or legal reasons in accordance with all elements specified in this requirement.
  • Observe the media destruction process and interview responsible personnel to verify that electronic media with cardholder data is destroyed via one of the methods specified in this requirement.

Description

Purpose

If steps are not taken to destroy information contained on electronic media when no longer needed, malicious individuals may retrieve information from the disposed media, leading to a data compromise. For example, malicious individuals may use a technique known as “dumpster diving,” where they search through trashcans and recycle bins looking for information they can use to launch an attack.

Good Practice

The deletion function in most operating systems allows deleted data to be recovered, so instead, a dedicated secure deletion function or application should be used to make data unrecoverable.

Examples

Methods for securely destroying electronic media include secure wiping in accordance with industry-accepted standards for secure deletion, degaussing, or physical destruction (such as grinding or shredding hard disks).

Further Information

See NIST Special Publication 800-88, Revision 1: Guidelines for Media Sanitization