12.4: 1. Additional requirement for service providers only: Responsibility is established by executive management for the protection of cardholder data and a PCI DSS compliance program to include: (a) Overall accountability for maintaining PCI DSS compliance, (b) Defining a charter for a PCI DSS compliance program and communication to executive management.
  • Additional testing procedure for service provider assessments only: Examine documentation to verify that executive management has established responsibility for the protection of cardholder data and a PCI DSS compliance program in accordance with all elements specified in this requirement.

Description

Purpose

Executive management assignment of PCI DSS compliance responsibilities ensures executive- level visibility into the PCI DSS compliance program and allows for the opportunity to ask appropriate questions to determine the effectiveness of the program and influence strategic priorities.

12.4: 2. Additional requirement for service providers only: Reviews are performed at least once every three months to confirm that personnel are performing their tasks in accordance with all security policies and operational procedures. Reviews are performed by personnel other than those responsible for performing the given task and include, but are not limited to, the following tasks: (a) Daily log reviews, (b) Configuration reviews for network security controls, (c) Applying configuration standards to new systems, (d) Responding to security alerts, (e) Change-management processes.
  • Additional testing procedure for service provider assessments only: Examine policies and procedures to verify that processes are defined for conducting reviews to confirm that personnel are performing their tasks in accordance with all security policies and all operational procedures, including but not limited to the tasks specified in this requirement.
  • Additional testing procedure for service provider assessments only: Interview responsible personnel and examine records of reviews to verify that reviews are performed:
  • • At least once every three months.
  • • By personnel other than those responsible for performing the given task.

Description

Purpose

Regularly confirming that security policies and procedures are being followed provides assurance that the expected controls are active and working as intended. This requirement is distinct from other requirements that specify a task to be performed. The objective of these reviews is not to reperform other PCI DSS requirements, but to confirm that security activities are being performed on an ongoing basis.

Good Practice

These reviews can also be used to verify that appropriate evidence is being maintained—for example, audit logs, vulnerability scan reports, reviews of network security control rulesets—to assist in the entity’s preparation for its next PCI DSS assessment.

Examples

Looking at Requirement 1.2.7 as one example, Requirement 12.4.2 is met by confirming, at least once every three months, that reviews of configurations of network security controls have occurred at the required frequency. On the other hand, Requirement 1.2.7 is met by reviewing those configurations as specified in the requirement.

12.4: 2.1. Additional requirement for service providers only: Reviews conducted in accordance with Requirement 12.4.2 are documented to include: (a) Results of the reviews, (b) Documented remediation actions taken for any tasks that were found to not be performed at Requirement 12.4.2, (c) Review and sign-off of results by personnel assigned responsibility for the PCI DSS compliance program.
  • Additional testing procedure for service provider assessments only: Examine documentation from the reviews conducted in accordance with PCI DSS Requirement 12.4.2 to verify the documentation includes all elements specified in this requirement.

Description

Purpose

The intent of these independent checks is to confirm whether security activities are being performed on an ongoing basis. These reviews can also be used to verify that appropriate evidence is being maintained—for example, audit logs, vulnerability scan reports, reviews of network security control rulesets—to assist in the entity’s preparation for its next PCI DSS assessment.