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10.2.1.1 Audit logs capture all individual user access to cardholder data.

Original requirement from PCI DSS v4.0.1

Defined Approach Requirements

10.2.1.1 Audit logs capture all individual user access to cardholder data.

Customized Approach Objective

Records of all individual user access to cardholder data are captured.

Defined Approach Testing Procedures

10.2.1.1 Examine audit log configurations and log data to verify that all individual user access to cardholder data is logged.

Purpose

It is critical to have a process or system that links user access to system components accessed. Malicious individuals could obtain knowledge of a user account with access to systems in the CDE, or they could create a new, unauthorized account to access cardholder data.

Good Practice

A record of all individual access to cardholder data can identify which accounts may have been compromised or misused.

purpose

Log all individual user access to cardholder data.

compliance strategies

  • Enable access logging
  • Unique user IDs

typical policies

  • Access Logging Policy

common pitfalls

  • Shared accounts
  • Missing user attribution

type

Technical Control

difficulty

Moderate

key risks

  • Untraceable data access

recommendations

  • Enforce unique logins for all system access

Eligible SAQ

  • SAQ-A-EP
  • SAQ-D MERCHANT
  • SAQ-D SERVICE PROVIDER

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