12.6: 1. A formal security awareness program is implemented to make all personnel aware of the entity’s information security policy and procedures, and their role in protecting the cardholder data.
  • Examine the security awareness program to verify it provides awareness to all personnel about the entity’s information security policy and procedures, and personnel’s role in protecting the cardholder data.

Description

Purpose

If personnel are not educated about their company’s information security policies and procedures and their own security responsibilities, security safeguards and processes that have been implemented may become ineffective through unintentional errors or intentional actions.

12.6: 2. The security awareness program is: (a) Reviewed at least once every 12 months, and, (b) Updated as needed to address any new threats and vulnerabilities that may impact the security of the entity’s cardholder data and/or sensitive authentication data, or the information provided to personnel about their role in protecting cardholder data.
  • Examine security awareness program content, evidence of reviews, and interview personnel to verify that the security awareness program is in accordance with all elements specified in this requirement.

Description

Purpose

The threat environment and an entity’s defenses are not static. As such, the security awareness program materials must be updated as frequently as needed to ensure that the education received by personnel is up to date and represents the current threat environment.

12.6: 3. Personnel receive security awareness training as follows: (a) Upon hire and at least once every 12 months, (b) Multiple methods of communication are used, (c) Personnel acknowledge at least once every 12 months that they have read and understood the information security policy and procedures.
  • Examine security awareness program records to verify that personnel attend security awareness training upon hire and at least once every 12 months.
  • Examine security awareness program materials to verify the program includes multiple methods of communicating awareness and educating personnel.
  • Interview personnel to verify they have completed awareness training and are aware of their role in protecting cardholder data.
  • Examine security awareness program materials and personnel acknowledgments to verify that personnel acknowledge at least once every 12 months that they have read and understand the information security policy and procedures.

Description

Purpose

Training of personnel ensures they receive the information about the importance of information security and that they understand their role in protecting the organization.

Requiring an acknowledgment by personnel helps ensure that they have read and understood the security policies and procedures, and that they have made and will continue to make a commitment to comply with these policies.

Good Practice

Entities may incorporate new-hire training as part of the Human Resources onboarding process. Training should outline the security-related “dos” and “don’ts.” Periodic refresher training reinforces key security processes and procedures that may be forgotten or bypassed.

Entities should consider requiring security awareness training anytime personnel transfer into roles where they can impact the security of cardholder data and/or sensitive authentication data from roles where they did not have this impact.

Methods and training content can vary, depending on personnel roles.

Examples

Different methods that can be used to provide security awareness and education include posters, letters, web-based training, in-person training, team meetings, and incentives.

Personnel acknowledgments may be recorded in writing or electronically.

12.6: 3.1. Security awareness training includes awareness of threats and vulnerabilities that could impact the security of cardholder data and/or sensitive authentication data, including but not limited to: (a) Phishing and related attacks, (b) Social engineering.
  • Examine security awareness training content to verify it includes all elements specified in this requirement.

Description

Purpose

Educating personnel on how to detect, react to, and report potential phishing and related attacks and social engineering attempts is essential to minimizing the probability of successful attacks.

Good Practice

An effective security awareness program should include examples of phishing emails and periodic testing to determine the prevalence of personnel reporting such attacks. Training material an entity can consider for this topic include:

• How to identify phishing and other social engineering attacks.

• How to react to suspected phishing and social engineering.

• Where and how to report suspected phishing and social engineering activity.

An emphasis on reporting allows the organization to reward positive behavior, to optimize technical defenses (see Requirement 5.4.1), and to take immediate action to remove similar phishing emails that evaded technical defenses from recipient inboxes.

12.6: 3.2. Security awareness training includes awareness about the acceptable use of end-user technologies in accordance with Requirement 12.2.1.
  • Examine security awareness training content to verify it includes awareness about acceptable use of end-user technologies in accordance with Requirement 12.2.1.

Description

Purpose

By including the key points of the acceptable use policy in regular training and the related context, personnel will understand their responsibilities and how these impact the security of an organization’s systems.