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3.1: All security policies and operational procedures that are identified in Requirement 3 are: (a) Documented, (b) Kept up to date, (c) In use, (d) Known to all affected parties.
  • Examine documentation and interview personnel to verify that security policies and operational procedures identified in Requirement 3 are managed in accordance with all elements specified in this requirement.
Description

Requirement 3.1.1

Purpose

Requirement 3.1.1 is about effectively managing and maintaining the various policies and procedures specified throughout Requirement 3. While it is important to define the specific policies or procedures called out in Requirement 3, it is equally important to ensure they are properly documented, maintained, and disseminated.

Good Practice

It is important to update policies and procedures as needed to address changes in processes, technologies, and business objectives. For these reasons, consider updating these documents as soon as possible after a change occurs and not only on a periodic cycle.

Definitions

Security policies define the entity's security objectives and principles. Operational procedures describe how to perform activities, and define the controls, methods, and processes that are followed to achieve the desired result in a consistent manner and in accordance with policy objectives.

Requirement 3.1.2

Purpose

If roles and responsibilities are not formally assigned, personnel may not be aware of their day-to-day responsibilities and critical activities may not occur.

Good Practice

Roles and responsibilities may be documented within policies and procedures or maintained within separate documents. As part of communicating roles and responsibilities, entities can consider having personnel acknowledge their acceptance and understanding of their assigned roles and responsibilities.

Examples

A method to document roles and responsibilities is a responsibility assignment matrix that includes who is responsible, accountable, consulted, and informed (also called a RACI matrix).

3.1: Roles and responsibilities for performing activities in Requirement 3 are documented, assigned, and understood.
  • Examine documentation to verify that descriptions of roles and responsibilities performing activities in Requirement 3 are documented and assigned.
  • Interview personnel with responsibility for performing activities in Requirement 3 to verify that roles and responsibilities are assigned as documented and are understood.
Description

Requirement 3.1.1

Purpose

Requirement 3.1.1 is about effectively managing and maintaining the various policies and procedures specified throughout Requirement 3. While it is important to define the specific policies or procedures called out in Requirement 3, it is equally important to ensure they are properly documented, maintained, and disseminated.

Good Practice

It is important to update policies and procedures as needed to address changes in processes, technologies, and business objectives. For these reasons, consider updating these documents as soon as possible after a change occurs and not only on a periodic cycle.

Definitions

Security policies define the entity's security objectives and principles. Operational procedures describe how to perform activities, and define the controls, methods, and processes that are followed to achieve the desired result in a consistent manner and in accordance with policy objectives.

Requirement 3.1.2

Purpose

If roles and responsibilities are not formally assigned, personnel may not be aware of their day-to-day responsibilities and critical activities may not occur.

Good Practice

Roles and responsibilities may be documented within policies and procedures or maintained within separate documents. As part of communicating roles and responsibilities, entities can consider having personnel acknowledge their acceptance and understanding of their assigned roles and responsibilities.

Examples

A method to document roles and responsibilities is a responsibility assignment matrix that includes who is responsible, accountable, consulted, and informed (also called a RACI matrix).

3.2: Account data storage is kept to a minimum through implementation of data retention and disposal policies, procedures, and processes that include at least the following: (a) Coverage for all locations of stored account data, (b) Coverage for any sensitive authentication data (SAD) stored prior to completion of authorization. This bullet is a best practice until its effective date; refer to Applicability Notes below for details, (c) Limiting data storage amount and retention time to that which is required for legal or regulatory, and/or business requirements, (d) Specific retention requirements for stored account data that defines length of retention period and includes a documented business justification, (e) Processes for secure deletion or rendering account data unrecoverable when no longer needed per the retention policy, (f) A process for verifying, at least once every three months, that stored account data exceeding the defined retention period has been securely deleted or rendered unrecoverable.
  • Examine the data retention and disposal policies, procedures, and processes and interview personnel to verify processes are defined to include all elements specified in this requirement.
  • Examine files and system records on system components where account data is stored to verify that the data storage amount and retention time does not exceed the requirements defined in the data retention policy.
  • Observe the mechanisms used to render account data unrecoverable to verify data cannot be recovered.
Description

Requirement 3.2.1

Purpose

Storing account data beyond what is needed for business purposes creates unnecessary risk. The longer data is retained, the greater the potential exposure in the event of a data breach. Implementing data retention and disposal policies helps minimize the amount of data at risk.

Good Practice

Data retention policies should clearly define what data is stored, where it is stored, how long it is retained, and how it is securely disposed of when no longer needed. Automated processes should be used where possible to identify and securely delete stored account data that exceeds the defined retention period.

Definitions

A data retention and disposal policy defines the business requirements for retaining data, the specific data elements to be retained, and the timeframes and methods for secure disposal of data that is no longer needed.

3.3: SAD is not stored after authorization, even if encrypted. All sensitive authentication data received is rendered unrecoverable upon completion of the authorization process.
  • If SAD is received, examine documented policies, procedures, and system configurations to verify the data is not stored after authorization.
  • If SAD is received, examine the documented procedures and observe the secure data deletion processes to verify the data is rendered unrecoverable upon completion of the authorization process.
Description

Requirement 3.3.1

Purpose

Sensitive authentication data (SAD) is valuable to attackers because it can be used to generate counterfeit payment cards and create fraudulent transactions. If SAD is stored after authorization, it provides attackers with more data to steal. Ensuring SAD is not retained after authorization reduces the risk of fraud.

Good Practice

Processes should be in place to securely delete SAD immediately after the authorization process is complete. Automated tools can help ensure that SAD is not inadvertently retained in logs, temporary files, or other storage locations.

Definitions

Sensitive authentication data includes full track data, card verification codes/values (CAV2/CVC2/CVV2/CID), and PINs/PIN blocks. Authorization is the process by which a card issuer approves or declines a transaction.

Requirement 3.3.1.1

Purpose

Full track data from the magnetic stripe or chip contains all the information needed to create a counterfeit card. If this data is stored after authorization, it could be used by attackers to commit fraud.

Good Practice

Systems should be configured to not store full track data after authorization. Regular scans should be performed to verify that full track data is not being stored anywhere in the environment.

Requirement 3.3.1.2

Purpose

The card verification code (CAV2/CVC2/CVV2/CID) is used to verify that the person making a card-not-present transaction has physical possession of the card. If this value is stored after authorization, it could be used to make fraudulent transactions without the physical card.

Good Practice

Systems should be configured to not store card verification codes after authorization. Regular verification should confirm that these values are not retained in any storage location.

Requirement 3.3.1.3

Purpose

PINs and PIN blocks are used to authenticate cardholders during transactions. If this data is stored after authorization, it could be used to commit unauthorized transactions at ATMs or point-of-sale terminals.

Good Practice

Systems should be configured to never store PINs or PIN blocks after authorization, even in encrypted form. Regular checks should verify that this data is not being retained.

Requirement 3.3.2

Purpose

SAD stored prior to completion of authorization could be accessed by unauthorized individuals if the system is compromised. Encrypting SAD during the authorization process provides an additional layer of protection while the data is temporarily needed.

Good Practice

Strong cryptographic mechanisms should be used to protect SAD stored prior to authorization completion. The cryptographic keys used should be managed in accordance with Requirements 3.6 and 3.7.

Requirement 3.3.3

Purpose

Issuers and companies that support issuing services may have a legitimate business need to store SAD. However, additional protections are necessary when SAD is stored, even by issuers, to prevent unauthorized use.

Good Practice

Entities that store SAD for issuing purposes should ensure that the data is encrypted using strong cryptography and that access is strictly limited to personnel with a documented business need.

3.3: The full contents of any track are not stored upon completion of the authorization process.
  • Examine data sources to verify that the full contents of any track are not stored upon completion of the authorization process.
Description

Requirement 3.3.1

Purpose

Sensitive authentication data (SAD) is valuable to attackers because it can be used to generate counterfeit payment cards and create fraudulent transactions. If SAD is stored after authorization, it provides attackers with more data to steal. Ensuring SAD is not retained after authorization reduces the risk of fraud.

Good Practice

Processes should be in place to securely delete SAD immediately after the authorization process is complete. Automated tools can help ensure that SAD is not inadvertently retained in logs, temporary files, or other storage locations.

Definitions

Sensitive authentication data includes full track data, card verification codes/values (CAV2/CVC2/CVV2/CID), and PINs/PIN blocks. Authorization is the process by which a card issuer approves or declines a transaction.

Requirement 3.3.1.1

Purpose

Full track data from the magnetic stripe or chip contains all the information needed to create a counterfeit card. If this data is stored after authorization, it could be used by attackers to commit fraud.

Good Practice

Systems should be configured to not store full track data after authorization. Regular scans should be performed to verify that full track data is not being stored anywhere in the environment.

Requirement 3.3.1.2

Purpose

The card verification code (CAV2/CVC2/CVV2/CID) is used to verify that the person making a card-not-present transaction has physical possession of the card. If this value is stored after authorization, it could be used to make fraudulent transactions without the physical card.

Good Practice

Systems should be configured to not store card verification codes after authorization. Regular verification should confirm that these values are not retained in any storage location.

Requirement 3.3.1.3

Purpose

PINs and PIN blocks are used to authenticate cardholders during transactions. If this data is stored after authorization, it could be used to commit unauthorized transactions at ATMs or point-of-sale terminals.

Good Practice

Systems should be configured to never store PINs or PIN blocks after authorization, even in encrypted form. Regular checks should verify that this data is not being retained.

Requirement 3.3.2

Purpose

SAD stored prior to completion of authorization could be accessed by unauthorized individuals if the system is compromised. Encrypting SAD during the authorization process provides an additional layer of protection while the data is temporarily needed.

Good Practice

Strong cryptographic mechanisms should be used to protect SAD stored prior to authorization completion. The cryptographic keys used should be managed in accordance with Requirements 3.6 and 3.7.

Requirement 3.3.3

Purpose

Issuers and companies that support issuing services may have a legitimate business need to store SAD. However, additional protections are necessary when SAD is stored, even by issuers, to prevent unauthorized use.

Good Practice

Entities that store SAD for issuing purposes should ensure that the data is encrypted using strong cryptography and that access is strictly limited to personnel with a documented business need.

3.3: The card verification code is not stored upon completion of the authorization process.
  • Examine data sources, to verify that the card verification code is not stored upon completion of the authorization process.
Description

Requirement 3.3.1

Purpose

Sensitive authentication data (SAD) is valuable to attackers because it can be used to generate counterfeit payment cards and create fraudulent transactions. If SAD is stored after authorization, it provides attackers with more data to steal. Ensuring SAD is not retained after authorization reduces the risk of fraud.

Good Practice

Processes should be in place to securely delete SAD immediately after the authorization process is complete. Automated tools can help ensure that SAD is not inadvertently retained in logs, temporary files, or other storage locations.

Definitions

Sensitive authentication data includes full track data, card verification codes/values (CAV2/CVC2/CVV2/CID), and PINs/PIN blocks. Authorization is the process by which a card issuer approves or declines a transaction.

Requirement 3.3.1.1

Purpose

Full track data from the magnetic stripe or chip contains all the information needed to create a counterfeit card. If this data is stored after authorization, it could be used by attackers to commit fraud.

Good Practice

Systems should be configured to not store full track data after authorization. Regular scans should be performed to verify that full track data is not being stored anywhere in the environment.

Requirement 3.3.1.2

Purpose

The card verification code (CAV2/CVC2/CVV2/CID) is used to verify that the person making a card-not-present transaction has physical possession of the card. If this value is stored after authorization, it could be used to make fraudulent transactions without the physical card.

Good Practice

Systems should be configured to not store card verification codes after authorization. Regular verification should confirm that these values are not retained in any storage location.

Requirement 3.3.1.3

Purpose

PINs and PIN blocks are used to authenticate cardholders during transactions. If this data is stored after authorization, it could be used to commit unauthorized transactions at ATMs or point-of-sale terminals.

Good Practice

Systems should be configured to never store PINs or PIN blocks after authorization, even in encrypted form. Regular checks should verify that this data is not being retained.

Requirement 3.3.2

Purpose

SAD stored prior to completion of authorization could be accessed by unauthorized individuals if the system is compromised. Encrypting SAD during the authorization process provides an additional layer of protection while the data is temporarily needed.

Good Practice

Strong cryptographic mechanisms should be used to protect SAD stored prior to authorization completion. The cryptographic keys used should be managed in accordance with Requirements 3.6 and 3.7.

Requirement 3.3.3

Purpose

Issuers and companies that support issuing services may have a legitimate business need to store SAD. However, additional protections are necessary when SAD is stored, even by issuers, to prevent unauthorized use.

Good Practice

Entities that store SAD for issuing purposes should ensure that the data is encrypted using strong cryptography and that access is strictly limited to personnel with a documented business need.

3.3: The personal identification number (PIN) and the PIN block are not stored upon completion of the authorization process.
  • Examine data sources, to verify that PINs and PIN blocks are not stored upon completion of the authorization process.
Description

Requirement 3.3.1

Purpose

Sensitive authentication data (SAD) is valuable to attackers because it can be used to generate counterfeit payment cards and create fraudulent transactions. If SAD is stored after authorization, it provides attackers with more data to steal. Ensuring SAD is not retained after authorization reduces the risk of fraud.

Good Practice

Processes should be in place to securely delete SAD immediately after the authorization process is complete. Automated tools can help ensure that SAD is not inadvertently retained in logs, temporary files, or other storage locations.

Definitions

Sensitive authentication data includes full track data, card verification codes/values (CAV2/CVC2/CVV2/CID), and PINs/PIN blocks. Authorization is the process by which a card issuer approves or declines a transaction.

Requirement 3.3.1.1

Purpose

Full track data from the magnetic stripe or chip contains all the information needed to create a counterfeit card. If this data is stored after authorization, it could be used by attackers to commit fraud.

Good Practice

Systems should be configured to not store full track data after authorization. Regular scans should be performed to verify that full track data is not being stored anywhere in the environment.

Requirement 3.3.1.2

Purpose

The card verification code (CAV2/CVC2/CVV2/CID) is used to verify that the person making a card-not-present transaction has physical possession of the card. If this value is stored after authorization, it could be used to make fraudulent transactions without the physical card.

Good Practice

Systems should be configured to not store card verification codes after authorization. Regular verification should confirm that these values are not retained in any storage location.

Requirement 3.3.1.3

Purpose

PINs and PIN blocks are used to authenticate cardholders during transactions. If this data is stored after authorization, it could be used to commit unauthorized transactions at ATMs or point-of-sale terminals.

Good Practice

Systems should be configured to never store PINs or PIN blocks after authorization, even in encrypted form. Regular checks should verify that this data is not being retained.

Requirement 3.3.2

Purpose

SAD stored prior to completion of authorization could be accessed by unauthorized individuals if the system is compromised. Encrypting SAD during the authorization process provides an additional layer of protection while the data is temporarily needed.

Good Practice

Strong cryptographic mechanisms should be used to protect SAD stored prior to authorization completion. The cryptographic keys used should be managed in accordance with Requirements 3.6 and 3.7.

Requirement 3.3.3

Purpose

Issuers and companies that support issuing services may have a legitimate business need to store SAD. However, additional protections are necessary when SAD is stored, even by issuers, to prevent unauthorized use.

Good Practice

Entities that store SAD for issuing purposes should ensure that the data is encrypted using strong cryptography and that access is strictly limited to personnel with a documented business need.

3.3: SAD that is stored electronically prior to completion of authorization is encrypted using strong cryptography.
  • Examine data stores, system configurations, and/or vendor documentation to verify that all SAD that is stored electronically prior to completion of authorization is encrypted using strong cryptography.
Description

Requirement 3.3.1

Purpose

Sensitive authentication data (SAD) is valuable to attackers because it can be used to generate counterfeit payment cards and create fraudulent transactions. If SAD is stored after authorization, it provides attackers with more data to steal. Ensuring SAD is not retained after authorization reduces the risk of fraud.

Good Practice

Processes should be in place to securely delete SAD immediately after the authorization process is complete. Automated tools can help ensure that SAD is not inadvertently retained in logs, temporary files, or other storage locations.

Definitions

Sensitive authentication data includes full track data, card verification codes/values (CAV2/CVC2/CVV2/CID), and PINs/PIN blocks. Authorization is the process by which a card issuer approves or declines a transaction.

Requirement 3.3.1.1

Purpose

Full track data from the magnetic stripe or chip contains all the information needed to create a counterfeit card. If this data is stored after authorization, it could be used by attackers to commit fraud.

Good Practice

Systems should be configured to not store full track data after authorization. Regular scans should be performed to verify that full track data is not being stored anywhere in the environment.

Requirement 3.3.1.2

Purpose

The card verification code (CAV2/CVC2/CVV2/CID) is used to verify that the person making a card-not-present transaction has physical possession of the card. If this value is stored after authorization, it could be used to make fraudulent transactions without the physical card.

Good Practice

Systems should be configured to not store card verification codes after authorization. Regular verification should confirm that these values are not retained in any storage location.

Requirement 3.3.1.3

Purpose

PINs and PIN blocks are used to authenticate cardholders during transactions. If this data is stored after authorization, it could be used to commit unauthorized transactions at ATMs or point-of-sale terminals.

Good Practice

Systems should be configured to never store PINs or PIN blocks after authorization, even in encrypted form. Regular checks should verify that this data is not being retained.

Requirement 3.3.2

Purpose

SAD stored prior to completion of authorization could be accessed by unauthorized individuals if the system is compromised. Encrypting SAD during the authorization process provides an additional layer of protection while the data is temporarily needed.

Good Practice

Strong cryptographic mechanisms should be used to protect SAD stored prior to authorization completion. The cryptographic keys used should be managed in accordance with Requirements 3.6 and 3.7.

Requirement 3.3.3

Purpose

Issuers and companies that support issuing services may have a legitimate business need to store SAD. However, additional protections are necessary when SAD is stored, even by issuers, to prevent unauthorized use.

Good Practice

Entities that store SAD for issuing purposes should ensure that the data is encrypted using strong cryptography and that access is strictly limited to personnel with a documented business need.

3.3: Additional requirement for issuers and companies that support issuing services and store sensitive authentication data: Any storage of sensitive authentication data is: (a) Limited to that which is needed for a legitimate issuing business need and is secured, (b) Encrypted using strong cryptography. This bullet is a best practice until its effective date; refer to Applicability Notes below for details.
  • Additional testing procedure for issuers and companies that support issuing services and store sensitive authentication data: Examine documented policies and interview personnel to verify there is a documented business justification for the storage of sensitive authentication data.
  • Additional testing procedure for issuers and companies that support issuing services and store sensitive authentication data: Examine data stores and system configurations to verify that the sensitive authentication data is stored securely.
Description

Requirement 3.3.1

Purpose

Sensitive authentication data (SAD) is valuable to attackers because it can be used to generate counterfeit payment cards and create fraudulent transactions. If SAD is stored after authorization, it provides attackers with more data to steal. Ensuring SAD is not retained after authorization reduces the risk of fraud.

Good Practice

Processes should be in place to securely delete SAD immediately after the authorization process is complete. Automated tools can help ensure that SAD is not inadvertently retained in logs, temporary files, or other storage locations.

Definitions

Sensitive authentication data includes full track data, card verification codes/values (CAV2/CVC2/CVV2/CID), and PINs/PIN blocks. Authorization is the process by which a card issuer approves or declines a transaction.

Requirement 3.3.1.1

Purpose

Full track data from the magnetic stripe or chip contains all the information needed to create a counterfeit card. If this data is stored after authorization, it could be used by attackers to commit fraud.

Good Practice

Systems should be configured to not store full track data after authorization. Regular scans should be performed to verify that full track data is not being stored anywhere in the environment.

Requirement 3.3.1.2

Purpose

The card verification code (CAV2/CVC2/CVV2/CID) is used to verify that the person making a card-not-present transaction has physical possession of the card. If this value is stored after authorization, it could be used to make fraudulent transactions without the physical card.

Good Practice

Systems should be configured to not store card verification codes after authorization. Regular verification should confirm that these values are not retained in any storage location.

Requirement 3.3.1.3

Purpose

PINs and PIN blocks are used to authenticate cardholders during transactions. If this data is stored after authorization, it could be used to commit unauthorized transactions at ATMs or point-of-sale terminals.

Good Practice

Systems should be configured to never store PINs or PIN blocks after authorization, even in encrypted form. Regular checks should verify that this data is not being retained.

Requirement 3.3.2

Purpose

SAD stored prior to completion of authorization could be accessed by unauthorized individuals if the system is compromised. Encrypting SAD during the authorization process provides an additional layer of protection while the data is temporarily needed.

Good Practice

Strong cryptographic mechanisms should be used to protect SAD stored prior to authorization completion. The cryptographic keys used should be managed in accordance with Requirements 3.6 and 3.7.

Requirement 3.3.3

Purpose

Issuers and companies that support issuing services may have a legitimate business need to store SAD. However, additional protections are necessary when SAD is stored, even by issuers, to prevent unauthorized use.

Good Practice

Entities that store SAD for issuing purposes should ensure that the data is encrypted using strong cryptography and that access is strictly limited to personnel with a documented business need.

3.4: PAN is masked when displayed (the BIN and last four digits are the maximum number of digits to be displayed), such that only personnel with a legitimate business need can see more than the BIN and last four digits of the PAN.
  • Examine documented policies and procedures for masking the display of PANs to verify: • A list of roles that need access to more than the BIN and last four digits of the PAN (includes full PAN) is documented, together with a legitimate business need for each role to have such access. • PAN is masked when displayed such that only personnel with a legitimate business need can see more than the BIN and last four digits of the PAN. • All roles not specifically authorized to see the full PAN must only see masked PANs.
  • Examine system configurations to verify that full PAN is only displayed for roles with a documented business need, and that PAN is masked for all other requests.
  • Examine displays of PAN (for example, on screen, on paper receipts) to verify that PANs are masked when displayed, and that only those with a legitimate business need are able to see more than the BIN and/or last four digits of the PAN.
Description

Requirement 3.4.1

Purpose

Displaying the full PAN increases the risk that the number will be seen by unauthorized individuals and used for fraudulent purposes. Masking the PAN when displayed limits exposure of the full number to only those personnel who have a legitimate business need to see it.

Good Practice

The default display of PAN should show only the BIN (first six digits) and last four digits at most. Any display of more than these digits should require explicit authorization and should be logged. Role-based access controls should determine which personnel can view the full PAN.

Definitions

PAN masking refers to the practice of hiding a portion of the PAN when displayed, typically showing only the first six and/or last four digits. This is different from truncation, which permanently removes digits from stored data.

Requirement 3.4.2

Purpose

When PAN is accessible via remote-access technologies, there is a risk that the PAN could be copied, stored, or transmitted insecurely on the remote device or through the remote connection. Preventing the ability to copy or relocate PAN when using remote access helps reduce this risk.

Good Practice

Technical controls should prevent PAN from being copied, moved, or stored on local hard drives or removable media when accessed remotely. Technologies such as disabling clipboard functionality, preventing screen captures, and restricting file downloads can help protect PAN during remote access sessions.

3.4: When using remote-access technologies, technical controls prevent copy and/or relocation of PAN for all personnel, except for those with documented, explicit authorization and a legitimate, defined business need.
  • Examine documented policies and procedures and documented evidence for technical controls that prevent copy and/or relocation of PAN when using remote-access technologies onto local hard drives or removable electronic media to verify the following: • Technical controls prevent all personnel not specifically authorized from copying and/or relocating PAN. • A list of personnel with permission to copy and/or relocate PAN is maintained, together with the documented, explicit authorization and legitimate, defined business need.
  • Examine configurations for remote-access technologies to verify that technical controls to prevent copy and/or relocation of PAN for all personnel, unless explicitly authorized. Storing or relocating PAN onto local hard drives, removable electronic media, and other storage devices brings these devices into scope for PCI DSS. This requirement is a best practice until 31 March 2025, after which it will be required and must be fully considered during a PCI DSS assessment.
  • Observe processes and interview personnel to verify that only personnel with documented, explicit authorization and a legitimate, defined business need have permission to copy and/or relocate PAN when using remote- access technologies.
Description

Requirement 3.4.1

Purpose

Displaying the full PAN increases the risk that the number will be seen by unauthorized individuals and used for fraudulent purposes. Masking the PAN when displayed limits exposure of the full number to only those personnel who have a legitimate business need to see it.

Good Practice

The default display of PAN should show only the BIN (first six digits) and last four digits at most. Any display of more than these digits should require explicit authorization and should be logged. Role-based access controls should determine which personnel can view the full PAN.

Definitions

PAN masking refers to the practice of hiding a portion of the PAN when displayed, typically showing only the first six and/or last four digits. This is different from truncation, which permanently removes digits from stored data.

Requirement 3.4.2

Purpose

When PAN is accessible via remote-access technologies, there is a risk that the PAN could be copied, stored, or transmitted insecurely on the remote device or through the remote connection. Preventing the ability to copy or relocate PAN when using remote access helps reduce this risk.

Good Practice

Technical controls should prevent PAN from being copied, moved, or stored on local hard drives or removable media when accessed remotely. Technologies such as disabling clipboard functionality, preventing screen captures, and restricting file downloads can help protect PAN during remote access sessions.

3.5: PAN is rendered unreadable anywhere it is stored by using any of the following approaches: (a) One-way hashes based on strong cryptography of the entire PAN, (b) Truncation (hashing cannot be used to replace the truncated segment of PAN). – If hashed and truncated versions of the same PAN, or different truncation formats of the same PAN, are present in an environment, additional controls are in place such that the different versions cannot be correlated to reconstruct the original PAN, (c) Index tokens, (d) Strong cryptography with associated key- management processes and procedures.
  • Examine documentation about the system used to render PAN unreadable, including the vendor, type of system/process, and the encryption algorithms (if applicable) to verify that the PAN is rendered unreadable using any of the methods specified in this requirement.
  • Examine data repositories and audit logs, including payment application logs, to verify the PAN is rendered unreadable using any of the methods specified in this requirement.
  • If hashed and truncated versions of the same PAN are present in the environment, examine implemented controls to verify that the hashed and truncated versions cannot be correlated to reconstruct the original PAN.
Description

Requirement 3.5.1

Purpose

Rendering PAN unreadable wherever it is stored protects it from being used by unauthorized individuals who may gain access to stored data. Using strong cryptographic methods ensures that even if the storage media is compromised, the PAN cannot be easily recovered.

Good Practice

The approach used to render PAN unreadable should be appropriate for the storage environment and the data lifecycle. Organizations should select an approach based on their specific risk profile and operational requirements.

Definitions

Approaches for rendering PAN unreadable include one-way hashes based on strong cryptography, truncation, index tokens and pads, and strong cryptography with associated key-management processes and procedures.

Requirement 3.5.1.1

Purpose

Hashing PAN using strong cryptography provides a one-way transformation that prevents the original PAN from being recovered. However, if the hash can be correlated with the original PAN through lookup tables or other means, the protection is undermined.

Good Practice

Keyed cryptographic hashes (such as HMAC) should be used rather than simple hashes. The cryptographic keys used for hashing should be managed in accordance with Requirements 3.6 and 3.7. If truncated versions of the same PAN are stored alongside hashed versions, additional controls should prevent correlation.

Requirement 3.5.1.2

Purpose

If disk-level or partition-level encryption is used to render PAN unreadable, additional controls are needed because the data is automatically decrypted when the system is running, making it accessible to anyone with logical access to the system.

Good Practice

Disk-level encryption should only be used on removable electronic media. For non-removable media, use a different approach to render PAN unreadable. If disk-level encryption must be used, logical access must be managed independently and separately from native operating system access control mechanisms.

Requirement 3.5.1.3

Purpose

If index tokens are used to replace PAN, the original PAN and the tokens must be stored in separate, secure locations. If an attacker gains access to both the tokens and the mapping to the original PANs, the protection is defeated.

Good Practice

The mapping between index tokens and original PANs should be stored in a secure environment with strong access controls. The process for generating tokens should be cryptographically secure to prevent an attacker from predicting or reverse-engineering the tokens.

3.5: Hashes used to render PAN unreadable (per the first bullet of Requirement 3.5.1) are keyed cryptographic hashes of the entire PAN, with associated key- management processes and procedures in accordance with Requirements 3.6 and 3.7.
  • Examine documentation about the hashing method used to render PAN unreadable, including the vendor, type of system/process, and the encryption algorithms (as applicable) to verify that the hashing method results in keyed cryptographic hashes of the entire PAN, with associated key management processes and procedures.
  • Examine documentation about the key management procedures and processes associated with the keyed cryptographic hashes to verify keys are managed in accordance with Requirements 3.6 and 3.7.
  • Examine data repositories to verify the PAN is rendered unreadable.
  • Examine audit logs, including payment application logs, to verify the PAN is rendered unreadable.
Description

Requirement 3.5.1

Purpose

Rendering PAN unreadable wherever it is stored protects it from being used by unauthorized individuals who may gain access to stored data. Using strong cryptographic methods ensures that even if the storage media is compromised, the PAN cannot be easily recovered.

Good Practice

The approach used to render PAN unreadable should be appropriate for the storage environment and the data lifecycle. Organizations should select an approach based on their specific risk profile and operational requirements.

Definitions

Approaches for rendering PAN unreadable include one-way hashes based on strong cryptography, truncation, index tokens and pads, and strong cryptography with associated key-management processes and procedures.

Requirement 3.5.1.1

Purpose

Hashing PAN using strong cryptography provides a one-way transformation that prevents the original PAN from being recovered. However, if the hash can be correlated with the original PAN through lookup tables or other means, the protection is undermined.

Good Practice

Keyed cryptographic hashes (such as HMAC) should be used rather than simple hashes. The cryptographic keys used for hashing should be managed in accordance with Requirements 3.6 and 3.7. If truncated versions of the same PAN are stored alongside hashed versions, additional controls should prevent correlation.

Requirement 3.5.1.2

Purpose

If disk-level or partition-level encryption is used to render PAN unreadable, additional controls are needed because the data is automatically decrypted when the system is running, making it accessible to anyone with logical access to the system.

Good Practice

Disk-level encryption should only be used on removable electronic media. For non-removable media, use a different approach to render PAN unreadable. If disk-level encryption must be used, logical access must be managed independently and separately from native operating system access control mechanisms.

Requirement 3.5.1.3

Purpose

If index tokens are used to replace PAN, the original PAN and the tokens must be stored in separate, secure locations. If an attacker gains access to both the tokens and the mapping to the original PANs, the protection is defeated.

Good Practice

The mapping between index tokens and original PANs should be stored in a secure environment with strong access controls. The process for generating tokens should be cryptographically secure to prevent an attacker from predicting or reverse-engineering the tokens.

3.5: If disk-level or partition-level encryption (rather than file-, column-, or field-level database encryption) is used to render PAN unreadable, it is implemented only as follows: (a) On removable electronic media OR, (b) If used for non-removable electronic media, PAN is also rendered unreadable via another mechanism that meets Requirement 3.5.1.
  • Examine encryption processes to verify that, if disk-level or partition-level encryption is used to render PAN unreadable, it is implemented only as follows: • On removable electronic media, OR • If used for non-removable electronic media, examine encryption processes used to verify that PAN is also rendered unreadable via another method that meets Requirement 3.5.1.
  • Examine configurations and/or vendor documentation and observe encryption processes to verify the system is configured according to vendor documentation the result is that the disk or the partition is rendered unreadable.
Description

Requirement 3.5.1

Purpose

Rendering PAN unreadable wherever it is stored protects it from being used by unauthorized individuals who may gain access to stored data. Using strong cryptographic methods ensures that even if the storage media is compromised, the PAN cannot be easily recovered.

Good Practice

The approach used to render PAN unreadable should be appropriate for the storage environment and the data lifecycle. Organizations should select an approach based on their specific risk profile and operational requirements.

Definitions

Approaches for rendering PAN unreadable include one-way hashes based on strong cryptography, truncation, index tokens and pads, and strong cryptography with associated key-management processes and procedures.

Requirement 3.5.1.1

Purpose

Hashing PAN using strong cryptography provides a one-way transformation that prevents the original PAN from being recovered. However, if the hash can be correlated with the original PAN through lookup tables or other means, the protection is undermined.

Good Practice

Keyed cryptographic hashes (such as HMAC) should be used rather than simple hashes. The cryptographic keys used for hashing should be managed in accordance with Requirements 3.6 and 3.7. If truncated versions of the same PAN are stored alongside hashed versions, additional controls should prevent correlation.

Requirement 3.5.1.2

Purpose

If disk-level or partition-level encryption is used to render PAN unreadable, additional controls are needed because the data is automatically decrypted when the system is running, making it accessible to anyone with logical access to the system.

Good Practice

Disk-level encryption should only be used on removable electronic media. For non-removable media, use a different approach to render PAN unreadable. If disk-level encryption must be used, logical access must be managed independently and separately from native operating system access control mechanisms.

Requirement 3.5.1.3

Purpose

If index tokens are used to replace PAN, the original PAN and the tokens must be stored in separate, secure locations. If an attacker gains access to both the tokens and the mapping to the original PANs, the protection is defeated.

Good Practice

The mapping between index tokens and original PANs should be stored in a secure environment with strong access controls. The process for generating tokens should be cryptographically secure to prevent an attacker from predicting or reverse-engineering the tokens.

3.5: If disk-level or partition-level encryption is used (rather than file-, column-, or field-level database encryption) to render PAN unreadable, it is managed as follows: (a) Logical access is managed separately and independently of native operating system authentication and access control mechanisms, (b) Decryption keys are not associated with user accounts, (c) Authentication factors (passwords, passphrases, or cryptographic keys) that allow access to unencrypted data are stored securely.
  • If disk-level or partition-level encryption is used to render PAN unreadable, examine the system configuration and observe the authentication process to verify that logical access is implemented in accordance with all elements specified in this requirement.
  • Examine files containing authentication factors (passwords, passphrases, or cryptographic keys) and interview personnel to verify that authentication factors that allow access to unencrypted data are stored securely and are independent from the native operating system’s authentication and access control methods.
Description

Requirement 3.5.1

Purpose

Rendering PAN unreadable wherever it is stored protects it from being used by unauthorized individuals who may gain access to stored data. Using strong cryptographic methods ensures that even if the storage media is compromised, the PAN cannot be easily recovered.

Good Practice

The approach used to render PAN unreadable should be appropriate for the storage environment and the data lifecycle. Organizations should select an approach based on their specific risk profile and operational requirements.

Definitions

Approaches for rendering PAN unreadable include one-way hashes based on strong cryptography, truncation, index tokens and pads, and strong cryptography with associated key-management processes and procedures.

Requirement 3.5.1.1

Purpose

Hashing PAN using strong cryptography provides a one-way transformation that prevents the original PAN from being recovered. However, if the hash can be correlated with the original PAN through lookup tables or other means, the protection is undermined.

Good Practice

Keyed cryptographic hashes (such as HMAC) should be used rather than simple hashes. The cryptographic keys used for hashing should be managed in accordance with Requirements 3.6 and 3.7. If truncated versions of the same PAN are stored alongside hashed versions, additional controls should prevent correlation.

Requirement 3.5.1.2

Purpose

If disk-level or partition-level encryption is used to render PAN unreadable, additional controls are needed because the data is automatically decrypted when the system is running, making it accessible to anyone with logical access to the system.

Good Practice

Disk-level encryption should only be used on removable electronic media. For non-removable media, use a different approach to render PAN unreadable. If disk-level encryption must be used, logical access must be managed independently and separately from native operating system access control mechanisms.

Requirement 3.5.1.3

Purpose

If index tokens are used to replace PAN, the original PAN and the tokens must be stored in separate, secure locations. If an attacker gains access to both the tokens and the mapping to the original PANs, the protection is defeated.

Good Practice

The mapping between index tokens and original PANs should be stored in a secure environment with strong access controls. The process for generating tokens should be cryptographically secure to prevent an attacker from predicting or reverse-engineering the tokens.

3.6: Procedures are defined and implemented to protect cryptographic keys used to protect stored account data against disclosure and misuse that include: (a) Access to keys is restricted to the fewest number of custodians necessary, (b) Key-encrypting keys are at least as strong as the data-encrypting keys they protect, (c) Key-encrypting keys are stored separately from data-encrypting keys, (d) Keys are stored securely in the fewest possible locations and forms.
  • Examine documented key-management policies and procedures to verify that processes to protect cryptographic keys used to protect stored account data against disclosure and misuse are defined to include all elements specified in this requirement.
Description

Requirement 3.6.1

Purpose

Cryptographic key management is essential for the ongoing security of encryption. If keys are not properly managed, the encryption protecting stored account data can be undermined, potentially exposing cardholder data.

Good Practice

Key management procedures should be documented and followed consistently. Procedures should address all aspects of key lifecycle management, including generation, distribution, storage, changes, retirement, and destruction.

Requirement 3.6.1.1

Purpose

Restricting access to cryptographic keys to the fewest number of custodians necessary reduces the risk of unauthorized access to or misuse of the keys. If too many people have access to cryptographic keys, the risk of compromise increases.

Good Practice

Access to cryptographic keys should be limited to only those personnel whose job function requires it. A formal process should be in place for granting and revoking access to cryptographic keys.

Requirement 3.6.1.2

Purpose

If cryptographic keys are not stored securely, they could be accessed by unauthorized individuals and used to decrypt protected data. Secure key storage helps maintain the confidentiality of encrypted data.

Good Practice

Cryptographic keys should be stored in a secure manner that limits access to authorized custodians only. Key-encrypting keys should be at least as strong as the data-encrypting keys they protect. Key-encrypting keys should be stored separately from data-encrypting keys.

Requirement 3.6.1.3

Purpose

Storing cryptographic keys in the fewest possible locations reduces the risk of unauthorized access and simplifies key management. The more locations where keys are stored, the greater the risk of compromise.

Good Practice

Keys should be stored in as few locations as possible, with each location having appropriate security controls. Inventory of key storage locations should be maintained and reviewed periodically.

Requirement 3.6.1.4

Purpose

Cryptographic keys have a limited effective lifetime. Using keys beyond their defined crypto period increases the risk that the encryption can be compromised. Regular key rotation helps maintain the strength of the encryption.

Good Practice

Crypto periods should be defined based on industry best practices and the sensitivity of the data being protected. When a key reaches the end of its crypto period, it should be retired and replaced with a new key. Data encrypted with the old key should be re-encrypted with the new key where feasible.

Definitions

A crypto period is the time span during which a specific cryptographic key is authorized for use. Crypto periods are defined based on factors such as key strength, the volume of data encrypted, and the sensitivity of the data.

3.6: Additional requirement for service providers only: A documented description of the cryptographic architecture is maintained that includes: (a) Details of all algorithms, protocols, and keys used for the protection of stored account data, including key strength and expiry date, (b) Preventing the use of the same cryptographic keys in production and test environments. This bullet is a best practice until its effective date; refer to Applicability Notes below for details, (c) Description of the key usage for each key, (d) Inventory of any hardware security modules (HSMs), key management systems (KMS), and other secure cryptographic devices (SCDs) used for key management, including type and location of devices, to support meeting Requirement 12.3.4.
  • Additional testing procedure for service provider assessments only: Interview responsible personnel and examine documentation to verify that a document exists to describe the cryptographic architecture that includes all elements specified in this requirement.
Description

Requirement 3.6.1

Purpose

Cryptographic key management is essential for the ongoing security of encryption. If keys are not properly managed, the encryption protecting stored account data can be undermined, potentially exposing cardholder data.

Good Practice

Key management procedures should be documented and followed consistently. Procedures should address all aspects of key lifecycle management, including generation, distribution, storage, changes, retirement, and destruction.

Requirement 3.6.1.1

Purpose

Restricting access to cryptographic keys to the fewest number of custodians necessary reduces the risk of unauthorized access to or misuse of the keys. If too many people have access to cryptographic keys, the risk of compromise increases.

Good Practice

Access to cryptographic keys should be limited to only those personnel whose job function requires it. A formal process should be in place for granting and revoking access to cryptographic keys.

Requirement 3.6.1.2

Purpose

If cryptographic keys are not stored securely, they could be accessed by unauthorized individuals and used to decrypt protected data. Secure key storage helps maintain the confidentiality of encrypted data.

Good Practice

Cryptographic keys should be stored in a secure manner that limits access to authorized custodians only. Key-encrypting keys should be at least as strong as the data-encrypting keys they protect. Key-encrypting keys should be stored separately from data-encrypting keys.

Requirement 3.6.1.3

Purpose

Storing cryptographic keys in the fewest possible locations reduces the risk of unauthorized access and simplifies key management. The more locations where keys are stored, the greater the risk of compromise.

Good Practice

Keys should be stored in as few locations as possible, with each location having appropriate security controls. Inventory of key storage locations should be maintained and reviewed periodically.

Requirement 3.6.1.4

Purpose

Cryptographic keys have a limited effective lifetime. Using keys beyond their defined crypto period increases the risk that the encryption can be compromised. Regular key rotation helps maintain the strength of the encryption.

Good Practice

Crypto periods should be defined based on industry best practices and the sensitivity of the data being protected. When a key reaches the end of its crypto period, it should be retired and replaced with a new key. Data encrypted with the old key should be re-encrypted with the new key where feasible.

Definitions

A crypto period is the time span during which a specific cryptographic key is authorized for use. Crypto periods are defined based on factors such as key strength, the volume of data encrypted, and the sensitivity of the data.

3.6: Secret and private keys used to protect stored account data are stored in one (or more) of the following forms at all times: (a) Encrypted with a key-encrypting key that is at least as strong as the data-encrypting key, and that is stored separately from the data- encrypting key, (b) Within a secure cryptographic device (SCD), such as a hardware security module (HSM) or PTS-approved point-of-interaction device, (c) As at least two full-length key components or key shares, in accordance with an industry- accepted method.
  • Examine documented procedures to verify it is defined that cryptographic keys used to encrypt/decrypt stored account data must exist only in one (or more) of the forms specified in this requirement.
  • Examine system configurations and key storage locations to verify that cryptographic keys used to encrypt/decrypt stored account data exist in one (or more) of the forms specified in this requirement.
  • Wherever key-encrypting keys are used, examine system configurations and key storage locations to verify: • Key-encrypting keys are at least as strong as the data-encrypting keys they protect. • Key-encrypting keys are stored separately from data-encrypting keys.
Description

Requirement 3.6.1

Purpose

Cryptographic key management is essential for the ongoing security of encryption. If keys are not properly managed, the encryption protecting stored account data can be undermined, potentially exposing cardholder data.

Good Practice

Key management procedures should be documented and followed consistently. Procedures should address all aspects of key lifecycle management, including generation, distribution, storage, changes, retirement, and destruction.

Requirement 3.6.1.1

Purpose

Restricting access to cryptographic keys to the fewest number of custodians necessary reduces the risk of unauthorized access to or misuse of the keys. If too many people have access to cryptographic keys, the risk of compromise increases.

Good Practice

Access to cryptographic keys should be limited to only those personnel whose job function requires it. A formal process should be in place for granting and revoking access to cryptographic keys.

Requirement 3.6.1.2

Purpose

If cryptographic keys are not stored securely, they could be accessed by unauthorized individuals and used to decrypt protected data. Secure key storage helps maintain the confidentiality of encrypted data.

Good Practice

Cryptographic keys should be stored in a secure manner that limits access to authorized custodians only. Key-encrypting keys should be at least as strong as the data-encrypting keys they protect. Key-encrypting keys should be stored separately from data-encrypting keys.

Requirement 3.6.1.3

Purpose

Storing cryptographic keys in the fewest possible locations reduces the risk of unauthorized access and simplifies key management. The more locations where keys are stored, the greater the risk of compromise.

Good Practice

Keys should be stored in as few locations as possible, with each location having appropriate security controls. Inventory of key storage locations should be maintained and reviewed periodically.

Requirement 3.6.1.4

Purpose

Cryptographic keys have a limited effective lifetime. Using keys beyond their defined crypto period increases the risk that the encryption can be compromised. Regular key rotation helps maintain the strength of the encryption.

Good Practice

Crypto periods should be defined based on industry best practices and the sensitivity of the data being protected. When a key reaches the end of its crypto period, it should be retired and replaced with a new key. Data encrypted with the old key should be re-encrypted with the new key where feasible.

Definitions

A crypto period is the time span during which a specific cryptographic key is authorized for use. Crypto periods are defined based on factors such as key strength, the volume of data encrypted, and the sensitivity of the data.

3.6: Access to cleartext cryptographic key components is restricted to the fewest number of custodians necessary.
  • Examine user access lists to verify that access to cleartext cryptographic key components is restricted to the fewest number of custodians necessary.
Description

Requirement 3.6.1

Purpose

Cryptographic key management is essential for the ongoing security of encryption. If keys are not properly managed, the encryption protecting stored account data can be undermined, potentially exposing cardholder data.

Good Practice

Key management procedures should be documented and followed consistently. Procedures should address all aspects of key lifecycle management, including generation, distribution, storage, changes, retirement, and destruction.

Requirement 3.6.1.1

Purpose

Restricting access to cryptographic keys to the fewest number of custodians necessary reduces the risk of unauthorized access to or misuse of the keys. If too many people have access to cryptographic keys, the risk of compromise increases.

Good Practice

Access to cryptographic keys should be limited to only those personnel whose job function requires it. A formal process should be in place for granting and revoking access to cryptographic keys.

Requirement 3.6.1.2

Purpose

If cryptographic keys are not stored securely, they could be accessed by unauthorized individuals and used to decrypt protected data. Secure key storage helps maintain the confidentiality of encrypted data.

Good Practice

Cryptographic keys should be stored in a secure manner that limits access to authorized custodians only. Key-encrypting keys should be at least as strong as the data-encrypting keys they protect. Key-encrypting keys should be stored separately from data-encrypting keys.

Requirement 3.6.1.3

Purpose

Storing cryptographic keys in the fewest possible locations reduces the risk of unauthorized access and simplifies key management. The more locations where keys are stored, the greater the risk of compromise.

Good Practice

Keys should be stored in as few locations as possible, with each location having appropriate security controls. Inventory of key storage locations should be maintained and reviewed periodically.

Requirement 3.6.1.4

Purpose

Cryptographic keys have a limited effective lifetime. Using keys beyond their defined crypto period increases the risk that the encryption can be compromised. Regular key rotation helps maintain the strength of the encryption.

Good Practice

Crypto periods should be defined based on industry best practices and the sensitivity of the data being protected. When a key reaches the end of its crypto period, it should be retired and replaced with a new key. Data encrypted with the old key should be re-encrypted with the new key where feasible.

Definitions

A crypto period is the time span during which a specific cryptographic key is authorized for use. Crypto periods are defined based on factors such as key strength, the volume of data encrypted, and the sensitivity of the data.

3.6: Cryptographic keys are stored in the fewest possible locations.
  • Examine key storage locations and observe processes to verify that keys are stored in the fewest possible locations.
Description

Requirement 3.6.1

Purpose

Cryptographic key management is essential for the ongoing security of encryption. If keys are not properly managed, the encryption protecting stored account data can be undermined, potentially exposing cardholder data.

Good Practice

Key management procedures should be documented and followed consistently. Procedures should address all aspects of key lifecycle management, including generation, distribution, storage, changes, retirement, and destruction.

Requirement 3.6.1.1

Purpose

Restricting access to cryptographic keys to the fewest number of custodians necessary reduces the risk of unauthorized access to or misuse of the keys. If too many people have access to cryptographic keys, the risk of compromise increases.

Good Practice

Access to cryptographic keys should be limited to only those personnel whose job function requires it. A formal process should be in place for granting and revoking access to cryptographic keys.

Requirement 3.6.1.2

Purpose

If cryptographic keys are not stored securely, they could be accessed by unauthorized individuals and used to decrypt protected data. Secure key storage helps maintain the confidentiality of encrypted data.

Good Practice

Cryptographic keys should be stored in a secure manner that limits access to authorized custodians only. Key-encrypting keys should be at least as strong as the data-encrypting keys they protect. Key-encrypting keys should be stored separately from data-encrypting keys.

Requirement 3.6.1.3

Purpose

Storing cryptographic keys in the fewest possible locations reduces the risk of unauthorized access and simplifies key management. The more locations where keys are stored, the greater the risk of compromise.

Good Practice

Keys should be stored in as few locations as possible, with each location having appropriate security controls. Inventory of key storage locations should be maintained and reviewed periodically.

Requirement 3.6.1.4

Purpose

Cryptographic keys have a limited effective lifetime. Using keys beyond their defined crypto period increases the risk that the encryption can be compromised. Regular key rotation helps maintain the strength of the encryption.

Good Practice

Crypto periods should be defined based on industry best practices and the sensitivity of the data being protected. When a key reaches the end of its crypto period, it should be retired and replaced with a new key. Data encrypted with the old key should be re-encrypted with the new key where feasible.

Definitions

A crypto period is the time span during which a specific cryptographic key is authorized for use. Crypto periods are defined based on factors such as key strength, the volume of data encrypted, and the sensitivity of the data.

3.7: Key-management policies and procedures are implemented to include generation of strong cryptographic keys used to protect stored account data.
  • Examine the documented key-management policies and procedures for keys used for protection of stored account data to verify that they define generation of strong cryptographic keys.
  • Observe the method for generating keys to verify that strong keys are generated.
Description

Requirement 3.7.1

Purpose

The strength of the encryption depends on the strength of the cryptographic keys. If keys are not generated using strong methods, the encryption they provide may be weak and vulnerable to attack.

Good Practice

Key generation should use industry-accepted algorithms and random number generators. The key generation process should be documented and auditable.

Definitions

Strong cryptographic key generation uses algorithms and key lengths that are recognized as being resistant to current and anticipated future attacks, as defined by industry standards such as NIST SP 800-57.

Requirement 3.7.2

Purpose

If cryptographic keys are not distributed securely, they could be intercepted and used by unauthorized individuals to decrypt protected data. Secure distribution methods help ensure that only authorized parties receive the keys.

Good Practice

Keys should be distributed using secure methods such as key-wrapping with a key-encrypting key, loading keys directly into secure cryptographic devices, or using secure key exchange protocols. Keys should never be distributed in cleartext.

Requirement 3.7.3

Purpose

If cryptographic keys are not stored securely, they could be accessed by unauthorized individuals and used to decrypt protected data. Secure storage methods help maintain the confidentiality of encrypted account data.

Good Practice

Keys should be stored in a secure form, such as encrypted with a key-encrypting key. If stored on disk, they should be protected with strong access controls. Hardware security modules (HSMs) provide a high level of security for key storage.

Requirement 3.7.4

Purpose

Cryptographic keys have a limited effective lifetime. Using keys beyond their crypto period increases the risk that the encryption can be compromised. Regular key changes help maintain encryption strength.

Good Practice

Key changes should occur at the end of the defined crypto period and when the integrity of the key has been weakened, such as after departure of an employee with knowledge of the key or when compromise is suspected.

Requirement 3.7.5

Purpose

When cryptographic keys reach the end of their crypto period or are suspected of being compromised, they should be retired and no longer used for encryption. Proper retirement practices prevent old keys from being misused.

Good Practice

Retired keys should be securely archived if needed for decryption of previously encrypted data, or securely destroyed if no longer needed. Retired keys should not be used for new encryption operations.

Requirement 3.7.6

Purpose

Split knowledge and dual control of cryptographic keys ensures that no single person has access to the complete key, reducing the risk of insider threats and key compromise.

Good Practice

Key management procedures should define how keys are split among multiple custodians and require the involvement of at least two custodians for key operations.

Definitions

Split knowledge is a method in which two or more people separately have key components, where each person knows only their own key component, and the individual key components convey no knowledge of the original key. Dual control requires two or more people to perform an operation, with no single person having access to or knowledge of the authentication material of another.

Requirement 3.7.7

Purpose

Unauthorized substitution of cryptographic keys could allow an attacker to decrypt data or to encrypt data with a key they control. Preventing unauthorized key substitution helps maintain the integrity of the encryption system.

Good Practice

Controls should be in place to detect and prevent unauthorized key substitution attempts. Key management procedures should include verification steps to confirm the authenticity of keys before they are used.

Requirement 3.7.8

Purpose

Key custodians play a critical role in protecting cryptographic keys. If custodians do not understand their responsibilities, keys may not be adequately protected.

Good Practice

Key custodians should formally acknowledge that they understand and accept their key-custodian responsibilities. This acknowledgement should be documented and retained.

Requirement 3.7.9

Purpose

As cryptographic technologies and computing power evolve, previously strong encryption algorithms and key lengths may become vulnerable. Ensuring that cryptographic implementations remain current helps maintain the protection of stored account data.

Good Practice

Organizations should monitor industry guidance on cryptographic strength and update their implementations as needed. When cryptographic algorithms or key lengths are no longer considered strong, data should be re-encrypted using current strong cryptographic methods.

3.7: Key-management policies and procedures are implemented to include secure distribution of cryptographic keys used to protect stored account data.
  • Examine the documented key-management policies and procedures for keys used for protection of stored account data to verify that they define secure distribution of cryptographic keys.
  • Observe the method for distributing keys to verify that keys are distributed securely.
Description

Requirement 3.7.1

Purpose

The strength of the encryption depends on the strength of the cryptographic keys. If keys are not generated using strong methods, the encryption they provide may be weak and vulnerable to attack.

Good Practice

Key generation should use industry-accepted algorithms and random number generators. The key generation process should be documented and auditable.

Definitions

Strong cryptographic key generation uses algorithms and key lengths that are recognized as being resistant to current and anticipated future attacks, as defined by industry standards such as NIST SP 800-57.

Requirement 3.7.2

Purpose

If cryptographic keys are not distributed securely, they could be intercepted and used by unauthorized individuals to decrypt protected data. Secure distribution methods help ensure that only authorized parties receive the keys.

Good Practice

Keys should be distributed using secure methods such as key-wrapping with a key-encrypting key, loading keys directly into secure cryptographic devices, or using secure key exchange protocols. Keys should never be distributed in cleartext.

Requirement 3.7.3

Purpose

If cryptographic keys are not stored securely, they could be accessed by unauthorized individuals and used to decrypt protected data. Secure storage methods help maintain the confidentiality of encrypted account data.

Good Practice

Keys should be stored in a secure form, such as encrypted with a key-encrypting key. If stored on disk, they should be protected with strong access controls. Hardware security modules (HSMs) provide a high level of security for key storage.

Requirement 3.7.4

Purpose

Cryptographic keys have a limited effective lifetime. Using keys beyond their crypto period increases the risk that the encryption can be compromised. Regular key changes help maintain encryption strength.

Good Practice

Key changes should occur at the end of the defined crypto period and when the integrity of the key has been weakened, such as after departure of an employee with knowledge of the key or when compromise is suspected.

Requirement 3.7.5

Purpose

When cryptographic keys reach the end of their crypto period or are suspected of being compromised, they should be retired and no longer used for encryption. Proper retirement practices prevent old keys from being misused.

Good Practice

Retired keys should be securely archived if needed for decryption of previously encrypted data, or securely destroyed if no longer needed. Retired keys should not be used for new encryption operations.

Requirement 3.7.6

Purpose

Split knowledge and dual control of cryptographic keys ensures that no single person has access to the complete key, reducing the risk of insider threats and key compromise.

Good Practice

Key management procedures should define how keys are split among multiple custodians and require the involvement of at least two custodians for key operations.

Definitions

Split knowledge is a method in which two or more people separately have key components, where each person knows only their own key component, and the individual key components convey no knowledge of the original key. Dual control requires two or more people to perform an operation, with no single person having access to or knowledge of the authentication material of another.

Requirement 3.7.7

Purpose

Unauthorized substitution of cryptographic keys could allow an attacker to decrypt data or to encrypt data with a key they control. Preventing unauthorized key substitution helps maintain the integrity of the encryption system.

Good Practice

Controls should be in place to detect and prevent unauthorized key substitution attempts. Key management procedures should include verification steps to confirm the authenticity of keys before they are used.

Requirement 3.7.8

Purpose

Key custodians play a critical role in protecting cryptographic keys. If custodians do not understand their responsibilities, keys may not be adequately protected.

Good Practice

Key custodians should formally acknowledge that they understand and accept their key-custodian responsibilities. This acknowledgement should be documented and retained.

Requirement 3.7.9

Purpose

As cryptographic technologies and computing power evolve, previously strong encryption algorithms and key lengths may become vulnerable. Ensuring that cryptographic implementations remain current helps maintain the protection of stored account data.

Good Practice

Organizations should monitor industry guidance on cryptographic strength and update their implementations as needed. When cryptographic algorithms or key lengths are no longer considered strong, data should be re-encrypted using current strong cryptographic methods.

3.7: Key-management policies and procedures are implemented to include secure storage of cryptographic keys used to protect stored account data.
  • Examine the documented key-management policies and procedures for keys used for protection of stored account data to verify that they define secure storage of cryptographic keys.
  • Observe the method for storing keys to verify that keys are stored securely.
Description

Requirement 3.7.1

Purpose

The strength of the encryption depends on the strength of the cryptographic keys. If keys are not generated using strong methods, the encryption they provide may be weak and vulnerable to attack.

Good Practice

Key generation should use industry-accepted algorithms and random number generators. The key generation process should be documented and auditable.

Definitions

Strong cryptographic key generation uses algorithms and key lengths that are recognized as being resistant to current and anticipated future attacks, as defined by industry standards such as NIST SP 800-57.

Requirement 3.7.2

Purpose

If cryptographic keys are not distributed securely, they could be intercepted and used by unauthorized individuals to decrypt protected data. Secure distribution methods help ensure that only authorized parties receive the keys.

Good Practice

Keys should be distributed using secure methods such as key-wrapping with a key-encrypting key, loading keys directly into secure cryptographic devices, or using secure key exchange protocols. Keys should never be distributed in cleartext.

Requirement 3.7.3

Purpose

If cryptographic keys are not stored securely, they could be accessed by unauthorized individuals and used to decrypt protected data. Secure storage methods help maintain the confidentiality of encrypted account data.

Good Practice

Keys should be stored in a secure form, such as encrypted with a key-encrypting key. If stored on disk, they should be protected with strong access controls. Hardware security modules (HSMs) provide a high level of security for key storage.

Requirement 3.7.4

Purpose

Cryptographic keys have a limited effective lifetime. Using keys beyond their crypto period increases the risk that the encryption can be compromised. Regular key changes help maintain encryption strength.

Good Practice

Key changes should occur at the end of the defined crypto period and when the integrity of the key has been weakened, such as after departure of an employee with knowledge of the key or when compromise is suspected.

Requirement 3.7.5

Purpose

When cryptographic keys reach the end of their crypto period or are suspected of being compromised, they should be retired and no longer used for encryption. Proper retirement practices prevent old keys from being misused.

Good Practice

Retired keys should be securely archived if needed for decryption of previously encrypted data, or securely destroyed if no longer needed. Retired keys should not be used for new encryption operations.

Requirement 3.7.6

Purpose

Split knowledge and dual control of cryptographic keys ensures that no single person has access to the complete key, reducing the risk of insider threats and key compromise.

Good Practice

Key management procedures should define how keys are split among multiple custodians and require the involvement of at least two custodians for key operations.

Definitions

Split knowledge is a method in which two or more people separately have key components, where each person knows only their own key component, and the individual key components convey no knowledge of the original key. Dual control requires two or more people to perform an operation, with no single person having access to or knowledge of the authentication material of another.

Requirement 3.7.7

Purpose

Unauthorized substitution of cryptographic keys could allow an attacker to decrypt data or to encrypt data with a key they control. Preventing unauthorized key substitution helps maintain the integrity of the encryption system.

Good Practice

Controls should be in place to detect and prevent unauthorized key substitution attempts. Key management procedures should include verification steps to confirm the authenticity of keys before they are used.

Requirement 3.7.8

Purpose

Key custodians play a critical role in protecting cryptographic keys. If custodians do not understand their responsibilities, keys may not be adequately protected.

Good Practice

Key custodians should formally acknowledge that they understand and accept their key-custodian responsibilities. This acknowledgement should be documented and retained.

Requirement 3.7.9

Purpose

As cryptographic technologies and computing power evolve, previously strong encryption algorithms and key lengths may become vulnerable. Ensuring that cryptographic implementations remain current helps maintain the protection of stored account data.

Good Practice

Organizations should monitor industry guidance on cryptographic strength and update their implementations as needed. When cryptographic algorithms or key lengths are no longer considered strong, data should be re-encrypted using current strong cryptographic methods.

3.7: Key management policies and procedures are implemented for cryptographic key changes for keys that have reached the end of their cryptoperiod, as defined by the associated application vendor or key owner, and based on industry best practices and guidelines, including the following: (a) A defined cryptoperiod for each key type in use, (b) A process for key changes at the end of the defined cryptoperiod.
  • Examine the documented key-management policies and procedures for keys used for protection of stored account data to verify that they define changes to cryptographic keys that have reached the end of their cryptoperiod and include all elements specified in this requirement.
  • Interview personnel, examine documentation, and observe key storage locations to verify that keys are changed at the end of the defined cryptoperiod(s).
Description

Requirement 3.7.1

Purpose

The strength of the encryption depends on the strength of the cryptographic keys. If keys are not generated using strong methods, the encryption they provide may be weak and vulnerable to attack.

Good Practice

Key generation should use industry-accepted algorithms and random number generators. The key generation process should be documented and auditable.

Definitions

Strong cryptographic key generation uses algorithms and key lengths that are recognized as being resistant to current and anticipated future attacks, as defined by industry standards such as NIST SP 800-57.

Requirement 3.7.2

Purpose

If cryptographic keys are not distributed securely, they could be intercepted and used by unauthorized individuals to decrypt protected data. Secure distribution methods help ensure that only authorized parties receive the keys.

Good Practice

Keys should be distributed using secure methods such as key-wrapping with a key-encrypting key, loading keys directly into secure cryptographic devices, or using secure key exchange protocols. Keys should never be distributed in cleartext.

Requirement 3.7.3

Purpose

If cryptographic keys are not stored securely, they could be accessed by unauthorized individuals and used to decrypt protected data. Secure storage methods help maintain the confidentiality of encrypted account data.

Good Practice

Keys should be stored in a secure form, such as encrypted with a key-encrypting key. If stored on disk, they should be protected with strong access controls. Hardware security modules (HSMs) provide a high level of security for key storage.

Requirement 3.7.4

Purpose

Cryptographic keys have a limited effective lifetime. Using keys beyond their crypto period increases the risk that the encryption can be compromised. Regular key changes help maintain encryption strength.

Good Practice

Key changes should occur at the end of the defined crypto period and when the integrity of the key has been weakened, such as after departure of an employee with knowledge of the key or when compromise is suspected.

Requirement 3.7.5

Purpose

When cryptographic keys reach the end of their crypto period or are suspected of being compromised, they should be retired and no longer used for encryption. Proper retirement practices prevent old keys from being misused.

Good Practice

Retired keys should be securely archived if needed for decryption of previously encrypted data, or securely destroyed if no longer needed. Retired keys should not be used for new encryption operations.

Requirement 3.7.6

Purpose

Split knowledge and dual control of cryptographic keys ensures that no single person has access to the complete key, reducing the risk of insider threats and key compromise.

Good Practice

Key management procedures should define how keys are split among multiple custodians and require the involvement of at least two custodians for key operations.

Definitions

Split knowledge is a method in which two or more people separately have key components, where each person knows only their own key component, and the individual key components convey no knowledge of the original key. Dual control requires two or more people to perform an operation, with no single person having access to or knowledge of the authentication material of another.

Requirement 3.7.7

Purpose

Unauthorized substitution of cryptographic keys could allow an attacker to decrypt data or to encrypt data with a key they control. Preventing unauthorized key substitution helps maintain the integrity of the encryption system.

Good Practice

Controls should be in place to detect and prevent unauthorized key substitution attempts. Key management procedures should include verification steps to confirm the authenticity of keys before they are used.

Requirement 3.7.8

Purpose

Key custodians play a critical role in protecting cryptographic keys. If custodians do not understand their responsibilities, keys may not be adequately protected.

Good Practice

Key custodians should formally acknowledge that they understand and accept their key-custodian responsibilities. This acknowledgement should be documented and retained.

Requirement 3.7.9

Purpose

As cryptographic technologies and computing power evolve, previously strong encryption algorithms and key lengths may become vulnerable. Ensuring that cryptographic implementations remain current helps maintain the protection of stored account data.

Good Practice

Organizations should monitor industry guidance on cryptographic strength and update their implementations as needed. When cryptographic algorithms or key lengths are no longer considered strong, data should be re-encrypted using current strong cryptographic methods.

3.7: Key management policies procedures are implemented to include the retirement, replacement, or destruction of keys used to protect stored account data, as deemed necessary when: (a) The key has reached the end of its defined cryptoperiod, (b) The integrity of the key has been weakened, including when personnel with knowledge of a cleartext key component leaves the company, or the role for which the key component was known, (c) The key is suspected of or known to be compromised. Retired or replaced keys are not used for encryption operations.
  • Examine the documented key-management policies and procedures for keys used for protection of stored account data and verify that they define retirement, replacement, or destruction of keys in accordance with all elements specified in this requirement.
  • Interview personnel to verify that processes are implemented in accordance with all elements specified in this requirement.
Description

Requirement 3.7.1

Purpose

The strength of the encryption depends on the strength of the cryptographic keys. If keys are not generated using strong methods, the encryption they provide may be weak and vulnerable to attack.

Good Practice

Key generation should use industry-accepted algorithms and random number generators. The key generation process should be documented and auditable.

Definitions

Strong cryptographic key generation uses algorithms and key lengths that are recognized as being resistant to current and anticipated future attacks, as defined by industry standards such as NIST SP 800-57.

Requirement 3.7.2

Purpose

If cryptographic keys are not distributed securely, they could be intercepted and used by unauthorized individuals to decrypt protected data. Secure distribution methods help ensure that only authorized parties receive the keys.

Good Practice

Keys should be distributed using secure methods such as key-wrapping with a key-encrypting key, loading keys directly into secure cryptographic devices, or using secure key exchange protocols. Keys should never be distributed in cleartext.

Requirement 3.7.3

Purpose

If cryptographic keys are not stored securely, they could be accessed by unauthorized individuals and used to decrypt protected data. Secure storage methods help maintain the confidentiality of encrypted account data.

Good Practice

Keys should be stored in a secure form, such as encrypted with a key-encrypting key. If stored on disk, they should be protected with strong access controls. Hardware security modules (HSMs) provide a high level of security for key storage.

Requirement 3.7.4

Purpose

Cryptographic keys have a limited effective lifetime. Using keys beyond their crypto period increases the risk that the encryption can be compromised. Regular key changes help maintain encryption strength.

Good Practice

Key changes should occur at the end of the defined crypto period and when the integrity of the key has been weakened, such as after departure of an employee with knowledge of the key or when compromise is suspected.

Requirement 3.7.5

Purpose

When cryptographic keys reach the end of their crypto period or are suspected of being compromised, they should be retired and no longer used for encryption. Proper retirement practices prevent old keys from being misused.

Good Practice

Retired keys should be securely archived if needed for decryption of previously encrypted data, or securely destroyed if no longer needed. Retired keys should not be used for new encryption operations.

Requirement 3.7.6

Purpose

Split knowledge and dual control of cryptographic keys ensures that no single person has access to the complete key, reducing the risk of insider threats and key compromise.

Good Practice

Key management procedures should define how keys are split among multiple custodians and require the involvement of at least two custodians for key operations.

Definitions

Split knowledge is a method in which two or more people separately have key components, where each person knows only their own key component, and the individual key components convey no knowledge of the original key. Dual control requires two or more people to perform an operation, with no single person having access to or knowledge of the authentication material of another.

Requirement 3.7.7

Purpose

Unauthorized substitution of cryptographic keys could allow an attacker to decrypt data or to encrypt data with a key they control. Preventing unauthorized key substitution helps maintain the integrity of the encryption system.

Good Practice

Controls should be in place to detect and prevent unauthorized key substitution attempts. Key management procedures should include verification steps to confirm the authenticity of keys before they are used.

Requirement 3.7.8

Purpose

Key custodians play a critical role in protecting cryptographic keys. If custodians do not understand their responsibilities, keys may not be adequately protected.

Good Practice

Key custodians should formally acknowledge that they understand and accept their key-custodian responsibilities. This acknowledgement should be documented and retained.

Requirement 3.7.9

Purpose

As cryptographic technologies and computing power evolve, previously strong encryption algorithms and key lengths may become vulnerable. Ensuring that cryptographic implementations remain current helps maintain the protection of stored account data.

Good Practice

Organizations should monitor industry guidance on cryptographic strength and update their implementations as needed. When cryptographic algorithms or key lengths are no longer considered strong, data should be re-encrypted using current strong cryptographic methods.

3.7: Where manual cleartext cryptographic key- management operations are performed by personnel, key-management policies and procedures are implemented, including managing these operations using split knowledge and dual control.
  • Examine the documented key-management policies and procedures for keys used for protection of stored account data and verify that they define using split knowledge and dual control.
  • Interview personnel and/or observe processes to verify that manual cleartext keys are managed with split knowledge and dual control.
Description

Requirement 3.7.1

Purpose

The strength of the encryption depends on the strength of the cryptographic keys. If keys are not generated using strong methods, the encryption they provide may be weak and vulnerable to attack.

Good Practice

Key generation should use industry-accepted algorithms and random number generators. The key generation process should be documented and auditable.

Definitions

Strong cryptographic key generation uses algorithms and key lengths that are recognized as being resistant to current and anticipated future attacks, as defined by industry standards such as NIST SP 800-57.

Requirement 3.7.2

Purpose

If cryptographic keys are not distributed securely, they could be intercepted and used by unauthorized individuals to decrypt protected data. Secure distribution methods help ensure that only authorized parties receive the keys.

Good Practice

Keys should be distributed using secure methods such as key-wrapping with a key-encrypting key, loading keys directly into secure cryptographic devices, or using secure key exchange protocols. Keys should never be distributed in cleartext.

Requirement 3.7.3

Purpose

If cryptographic keys are not stored securely, they could be accessed by unauthorized individuals and used to decrypt protected data. Secure storage methods help maintain the confidentiality of encrypted account data.

Good Practice

Keys should be stored in a secure form, such as encrypted with a key-encrypting key. If stored on disk, they should be protected with strong access controls. Hardware security modules (HSMs) provide a high level of security for key storage.

Requirement 3.7.4

Purpose

Cryptographic keys have a limited effective lifetime. Using keys beyond their crypto period increases the risk that the encryption can be compromised. Regular key changes help maintain encryption strength.

Good Practice

Key changes should occur at the end of the defined crypto period and when the integrity of the key has been weakened, such as after departure of an employee with knowledge of the key or when compromise is suspected.

Requirement 3.7.5

Purpose

When cryptographic keys reach the end of their crypto period or are suspected of being compromised, they should be retired and no longer used for encryption. Proper retirement practices prevent old keys from being misused.

Good Practice

Retired keys should be securely archived if needed for decryption of previously encrypted data, or securely destroyed if no longer needed. Retired keys should not be used for new encryption operations.

Requirement 3.7.6

Purpose

Split knowledge and dual control of cryptographic keys ensures that no single person has access to the complete key, reducing the risk of insider threats and key compromise.

Good Practice

Key management procedures should define how keys are split among multiple custodians and require the involvement of at least two custodians for key operations.

Definitions

Split knowledge is a method in which two or more people separately have key components, where each person knows only their own key component, and the individual key components convey no knowledge of the original key. Dual control requires two or more people to perform an operation, with no single person having access to or knowledge of the authentication material of another.

Requirement 3.7.7

Purpose

Unauthorized substitution of cryptographic keys could allow an attacker to decrypt data or to encrypt data with a key they control. Preventing unauthorized key substitution helps maintain the integrity of the encryption system.

Good Practice

Controls should be in place to detect and prevent unauthorized key substitution attempts. Key management procedures should include verification steps to confirm the authenticity of keys before they are used.

Requirement 3.7.8

Purpose

Key custodians play a critical role in protecting cryptographic keys. If custodians do not understand their responsibilities, keys may not be adequately protected.

Good Practice

Key custodians should formally acknowledge that they understand and accept their key-custodian responsibilities. This acknowledgement should be documented and retained.

Requirement 3.7.9

Purpose

As cryptographic technologies and computing power evolve, previously strong encryption algorithms and key lengths may become vulnerable. Ensuring that cryptographic implementations remain current helps maintain the protection of stored account data.

Good Practice

Organizations should monitor industry guidance on cryptographic strength and update their implementations as needed. When cryptographic algorithms or key lengths are no longer considered strong, data should be re-encrypted using current strong cryptographic methods.

3.7: Key management policies and procedures are implemented to include the prevention of unauthorized substitution of cryptographic keys.
  • Examine the documented key-management policies and procedures for keys used for protection of stored account data and verify that they define prevention of unauthorized substitution of cryptographic keys.
  • Interview personnel and/or observe processes to verify that unauthorized substitution of keys is prevented.
Description

Requirement 3.7.1

Purpose

The strength of the encryption depends on the strength of the cryptographic keys. If keys are not generated using strong methods, the encryption they provide may be weak and vulnerable to attack.

Good Practice

Key generation should use industry-accepted algorithms and random number generators. The key generation process should be documented and auditable.

Definitions

Strong cryptographic key generation uses algorithms and key lengths that are recognized as being resistant to current and anticipated future attacks, as defined by industry standards such as NIST SP 800-57.

Requirement 3.7.2

Purpose

If cryptographic keys are not distributed securely, they could be intercepted and used by unauthorized individuals to decrypt protected data. Secure distribution methods help ensure that only authorized parties receive the keys.

Good Practice

Keys should be distributed using secure methods such as key-wrapping with a key-encrypting key, loading keys directly into secure cryptographic devices, or using secure key exchange protocols. Keys should never be distributed in cleartext.

Requirement 3.7.3

Purpose

If cryptographic keys are not stored securely, they could be accessed by unauthorized individuals and used to decrypt protected data. Secure storage methods help maintain the confidentiality of encrypted account data.

Good Practice

Keys should be stored in a secure form, such as encrypted with a key-encrypting key. If stored on disk, they should be protected with strong access controls. Hardware security modules (HSMs) provide a high level of security for key storage.

Requirement 3.7.4

Purpose

Cryptographic keys have a limited effective lifetime. Using keys beyond their crypto period increases the risk that the encryption can be compromised. Regular key changes help maintain encryption strength.

Good Practice

Key changes should occur at the end of the defined crypto period and when the integrity of the key has been weakened, such as after departure of an employee with knowledge of the key or when compromise is suspected.

Requirement 3.7.5

Purpose

When cryptographic keys reach the end of their crypto period or are suspected of being compromised, they should be retired and no longer used for encryption. Proper retirement practices prevent old keys from being misused.

Good Practice

Retired keys should be securely archived if needed for decryption of previously encrypted data, or securely destroyed if no longer needed. Retired keys should not be used for new encryption operations.

Requirement 3.7.6

Purpose

Split knowledge and dual control of cryptographic keys ensures that no single person has access to the complete key, reducing the risk of insider threats and key compromise.

Good Practice

Key management procedures should define how keys are split among multiple custodians and require the involvement of at least two custodians for key operations.

Definitions

Split knowledge is a method in which two or more people separately have key components, where each person knows only their own key component, and the individual key components convey no knowledge of the original key. Dual control requires two or more people to perform an operation, with no single person having access to or knowledge of the authentication material of another.

Requirement 3.7.7

Purpose

Unauthorized substitution of cryptographic keys could allow an attacker to decrypt data or to encrypt data with a key they control. Preventing unauthorized key substitution helps maintain the integrity of the encryption system.

Good Practice

Controls should be in place to detect and prevent unauthorized key substitution attempts. Key management procedures should include verification steps to confirm the authenticity of keys before they are used.

Requirement 3.7.8

Purpose

Key custodians play a critical role in protecting cryptographic keys. If custodians do not understand their responsibilities, keys may not be adequately protected.

Good Practice

Key custodians should formally acknowledge that they understand and accept their key-custodian responsibilities. This acknowledgement should be documented and retained.

Requirement 3.7.9

Purpose

As cryptographic technologies and computing power evolve, previously strong encryption algorithms and key lengths may become vulnerable. Ensuring that cryptographic implementations remain current helps maintain the protection of stored account data.

Good Practice

Organizations should monitor industry guidance on cryptographic strength and update their implementations as needed. When cryptographic algorithms or key lengths are no longer considered strong, data should be re-encrypted using current strong cryptographic methods.

3.7: Key management policies and procedures are implemented to include that cryptographic key custodians formally acknowledge (in writing or electronically) that they understand and accept their key-custodian responsibilities.
  • Examine the documented key-management policies and procedures for keys used for protection of stored account data and verify that they define acknowledgments for key custodians in accordance with all elements specified in this requirement.
  • Examine documentation or other evidence showing that key custodians have provided acknowledgments in accordance with all elements specified in this requirement.
Description

Requirement 3.7.1

Purpose

The strength of the encryption depends on the strength of the cryptographic keys. If keys are not generated using strong methods, the encryption they provide may be weak and vulnerable to attack.

Good Practice

Key generation should use industry-accepted algorithms and random number generators. The key generation process should be documented and auditable.

Definitions

Strong cryptographic key generation uses algorithms and key lengths that are recognized as being resistant to current and anticipated future attacks, as defined by industry standards such as NIST SP 800-57.

Requirement 3.7.2

Purpose

If cryptographic keys are not distributed securely, they could be intercepted and used by unauthorized individuals to decrypt protected data. Secure distribution methods help ensure that only authorized parties receive the keys.

Good Practice

Keys should be distributed using secure methods such as key-wrapping with a key-encrypting key, loading keys directly into secure cryptographic devices, or using secure key exchange protocols. Keys should never be distributed in cleartext.

Requirement 3.7.3

Purpose

If cryptographic keys are not stored securely, they could be accessed by unauthorized individuals and used to decrypt protected data. Secure storage methods help maintain the confidentiality of encrypted account data.

Good Practice

Keys should be stored in a secure form, such as encrypted with a key-encrypting key. If stored on disk, they should be protected with strong access controls. Hardware security modules (HSMs) provide a high level of security for key storage.

Requirement 3.7.4

Purpose

Cryptographic keys have a limited effective lifetime. Using keys beyond their crypto period increases the risk that the encryption can be compromised. Regular key changes help maintain encryption strength.

Good Practice

Key changes should occur at the end of the defined crypto period and when the integrity of the key has been weakened, such as after departure of an employee with knowledge of the key or when compromise is suspected.

Requirement 3.7.5

Purpose

When cryptographic keys reach the end of their crypto period or are suspected of being compromised, they should be retired and no longer used for encryption. Proper retirement practices prevent old keys from being misused.

Good Practice

Retired keys should be securely archived if needed for decryption of previously encrypted data, or securely destroyed if no longer needed. Retired keys should not be used for new encryption operations.

Requirement 3.7.6

Purpose

Split knowledge and dual control of cryptographic keys ensures that no single person has access to the complete key, reducing the risk of insider threats and key compromise.

Good Practice

Key management procedures should define how keys are split among multiple custodians and require the involvement of at least two custodians for key operations.

Definitions

Split knowledge is a method in which two or more people separately have key components, where each person knows only their own key component, and the individual key components convey no knowledge of the original key. Dual control requires two or more people to perform an operation, with no single person having access to or knowledge of the authentication material of another.

Requirement 3.7.7

Purpose

Unauthorized substitution of cryptographic keys could allow an attacker to decrypt data or to encrypt data with a key they control. Preventing unauthorized key substitution helps maintain the integrity of the encryption system.

Good Practice

Controls should be in place to detect and prevent unauthorized key substitution attempts. Key management procedures should include verification steps to confirm the authenticity of keys before they are used.

Requirement 3.7.8

Purpose

Key custodians play a critical role in protecting cryptographic keys. If custodians do not understand their responsibilities, keys may not be adequately protected.

Good Practice

Key custodians should formally acknowledge that they understand and accept their key-custodian responsibilities. This acknowledgement should be documented and retained.

Requirement 3.7.9

Purpose

As cryptographic technologies and computing power evolve, previously strong encryption algorithms and key lengths may become vulnerable. Ensuring that cryptographic implementations remain current helps maintain the protection of stored account data.

Good Practice

Organizations should monitor industry guidance on cryptographic strength and update their implementations as needed. When cryptographic algorithms or key lengths are no longer considered strong, data should be re-encrypted using current strong cryptographic methods.

3.7: Additional requirement for service providers only: Where a service provider shares cryptographic keys with its customers for transmission or storage of account data, guidance on secure transmission, storage and updating of such keys is documented and distributed to the service provider’s customers.
  • Additional testing procedure for service provider assessments only: If the service provider shares cryptographic keys with its customers for transmission or storage of account data, examine the documentation that the service provider provides to its customers to verify it includes guidance on how to securely transmit, store, and update customers’ keys in accordance with all elements specified in Requirements 3.7.1 through 3.7.8 above.
Description

Requirement 3.7.1

Purpose

The strength of the encryption depends on the strength of the cryptographic keys. If keys are not generated using strong methods, the encryption they provide may be weak and vulnerable to attack.

Good Practice

Key generation should use industry-accepted algorithms and random number generators. The key generation process should be documented and auditable.

Definitions

Strong cryptographic key generation uses algorithms and key lengths that are recognized as being resistant to current and anticipated future attacks, as defined by industry standards such as NIST SP 800-57.

Requirement 3.7.2

Purpose

If cryptographic keys are not distributed securely, they could be intercepted and used by unauthorized individuals to decrypt protected data. Secure distribution methods help ensure that only authorized parties receive the keys.

Good Practice

Keys should be distributed using secure methods such as key-wrapping with a key-encrypting key, loading keys directly into secure cryptographic devices, or using secure key exchange protocols. Keys should never be distributed in cleartext.

Requirement 3.7.3

Purpose

If cryptographic keys are not stored securely, they could be accessed by unauthorized individuals and used to decrypt protected data. Secure storage methods help maintain the confidentiality of encrypted account data.

Good Practice

Keys should be stored in a secure form, such as encrypted with a key-encrypting key. If stored on disk, they should be protected with strong access controls. Hardware security modules (HSMs) provide a high level of security for key storage.

Requirement 3.7.4

Purpose

Cryptographic keys have a limited effective lifetime. Using keys beyond their crypto period increases the risk that the encryption can be compromised. Regular key changes help maintain encryption strength.

Good Practice

Key changes should occur at the end of the defined crypto period and when the integrity of the key has been weakened, such as after departure of an employee with knowledge of the key or when compromise is suspected.

Requirement 3.7.5

Purpose

When cryptographic keys reach the end of their crypto period or are suspected of being compromised, they should be retired and no longer used for encryption. Proper retirement practices prevent old keys from being misused.

Good Practice

Retired keys should be securely archived if needed for decryption of previously encrypted data, or securely destroyed if no longer needed. Retired keys should not be used for new encryption operations.

Requirement 3.7.6

Purpose

Split knowledge and dual control of cryptographic keys ensures that no single person has access to the complete key, reducing the risk of insider threats and key compromise.

Good Practice

Key management procedures should define how keys are split among multiple custodians and require the involvement of at least two custodians for key operations.

Definitions

Split knowledge is a method in which two or more people separately have key components, where each person knows only their own key component, and the individual key components convey no knowledge of the original key. Dual control requires two or more people to perform an operation, with no single person having access to or knowledge of the authentication material of another.

Requirement 3.7.7

Purpose

Unauthorized substitution of cryptographic keys could allow an attacker to decrypt data or to encrypt data with a key they control. Preventing unauthorized key substitution helps maintain the integrity of the encryption system.

Good Practice

Controls should be in place to detect and prevent unauthorized key substitution attempts. Key management procedures should include verification steps to confirm the authenticity of keys before they are used.

Requirement 3.7.8

Purpose

Key custodians play a critical role in protecting cryptographic keys. If custodians do not understand their responsibilities, keys may not be adequately protected.

Good Practice

Key custodians should formally acknowledge that they understand and accept their key-custodian responsibilities. This acknowledgement should be documented and retained.

Requirement 3.7.9

Purpose

As cryptographic technologies and computing power evolve, previously strong encryption algorithms and key lengths may become vulnerable. Ensuring that cryptographic implementations remain current helps maintain the protection of stored account data.

Good Practice

Organizations should monitor industry guidance on cryptographic strength and update their implementations as needed. When cryptographic algorithms or key lengths are no longer considered strong, data should be re-encrypted using current strong cryptographic methods.