Requirement 10: Log and Monitor All Access to System Components and Cardholder Data
Overview
Logging mechanisms and the ability to track user activities are critical in preventing, detecting, or minimizing the impact of a data compromise. The presence of logs on all system components and in the cardholder data environment (CDE) allows thorough tracking, alerting, and analysis when something does go wrong. Determining the cause of a compromise is difficult, if not impossible, without system activity logs.
This requirement applies to user activities, including those by employees, contractors, consultants, and internal and external vendors, and other third parties (for example, those providing support or maintenance services).
These requirements do not apply to user activity of consumers (cardholders).
Refer to Appendix G for definitions of PCI DSS terms.
Sections
- 10.1: Processes and mechanisms for logging and monitoring all access to system components and cardholder data are defined and understood.
- 10.2: Audit logs are implemented to support the detection of anomalies and suspicious activity, and the forensic analysis of events.
- 10.3: Audit logs are protected from destruction and unauthorized modifications.
- 10.4: Audit logs are reviewed to identify anomalies or suspicious activity.
- 10.5: Audit log history is retained and available for analysis.
- 10.6: Time-synchronization mechanisms support consistent time settings across all systems.
- 10.7: Failures of critical security control systems are detected, reported, and responded to promptly.
10. Log and Monitor Access to Cardholder Data
Enable detection and response to security incidents by maintaining detailed audit logs of access to cardholder data environments (CDE) and implementing continuous monitoring mechanisms.
Control Types
Key Risks
Frequently Asked Questions
What are the critical logging requirements under PCI DSS 4.0.1?
PCI DSS 4.0.1 mandates logging of 1) All individual user accesses to cardholder data, 2) Actions taken by privileged users, 3) Invalid access attempts, and 4) Changes to authentication mechanisms. Logs must capture at minimum: user identity, event type, timestamp, success/failure indication, and affected resources. The update emphasizes cryptographic hashing of logs using SHA-256 or better to prevent tampering.
How often must audit logs be reviewed?
Organizations must perform: 1) Daily automated reviews of critical security events (e.g., failed logins, privilege escalations), 2) Weekly manual reviews of aggregated logs by security personnel, and 3) Immediate investigation of high-severity alerts. PCI DSS 4.0.1 requires correlation of logs across network devices, applications, and security systems using SIEM tools.
What are the log retention requirements?
Maintain logs for 90 days immediately available for analysis, with at least 12 months of historical logs archived. PCI DSS 4.0.1 specifies cryptographic protection for archived logs using AES-256 encryption. Cloud implementations must ensure log integrity despite provider rotation policies through services like AWS CloudWatch Logs Archive.
How should log integrity be maintained?
Implement: 1) Write-once-read-many (WORM) storage for raw logs, 2) Blockchain-based timestamping for critical events, 3) HMAC-SHA256 hashing of log streams, and 4) Strict access controls limiting log modification. Use hardware security modules (HSMs) to protect encryption keys for log archives.
What monitoring tools satisfy PCI DSS 4.0.1 requirements?
Deploy: 1) SIEM systems (Splunk Enterprise Security, IBM QRadar) with real-time alerting, 2) File integrity monitoring (Tripwire, OSSEC), 3) UEBA solutions detecting anomalous behavior patterns, and 4) Cloud-native tools (AWS CloudTrail, Azure Monitor). PCI DSS 4.0.1 requires testing monitoring tools quarterly through simulated attack scenarios.
Common QSA Questions
Demonstrate log integrity protection mechanisms?
We implement: 1) Immutable S3 buckets with object locking for raw logs, 2) Hashicorp Vault-generated SHA-384 hashes stored in HSMs, 3) Quarterly validation of log hashes using AWS Lambda integrity checks. Evidence includes cryptographically signed log manifest files and alert logs showing 0 unauthorized modification attempts in 18 months.
Show real-time alerting for critical security events?
Our Splunk ES configuration triggers alerts for: 1) >5 failed authentication attempts in 5 minutes, 2) Privileged account activity outside business hours, 3) Data exports exceeding 500 records. Sample alerts show 98.7% true positive rate with escalation to SOC within 5 minutes. Last penetration test detected simulated exfiltration in 43 seconds.
Provide evidence of log review processes?
Documentation includes: 1) Daily SOC shift reports analyzing 250k+ events, 2) Weekly review checklists signed by L2 analysts, 3) Quarterly audit of 1% random log samples. Automated workflows in ServiceNow track 100% of high-risk alerts to resolution. CloudTrail logs show 90-day retention compliance across 15 AWS accounts.
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