Requirement 12: Support Information Security with Organizational Policies and Programs
Overview
The organization's overall information security policy sets the tone for the whole entity and informs personnel what is expected of them. All personnel should be aware of the sensitivity of cardholder data and their responsibilities for protecting it.
For the purposes of Requirement 12, "personnel" refers to full-time and part-time employees, temporary employees, contractors, and consultants with security responsibilities for protecting account data or that can impact the security of cardholder data and/or sensitive authentication data.
Refer to Appendix G for definitions of PCI DSS terms.
Sections
- 12.1: A comprehensive information security policy that governs and provides direction for protection of the entity's information assets is known and current.
- 12.2: Acceptable use policies for end-user technologies are defined and implemented.
- 12.3: Risks to the cardholder data environment are formally identified, evaluated, and managed.
- 12.4: PCI DSS compliance is managed.
- 12.5: PCI DSS scope is documented and validated.
- 12.6: Security awareness education is an ongoing activity.
- 12.7: Personnel are screened to reduce risks from insider threats.
- 12.8: Risk to information assets associated with third-party service provider (TPSP) relationships is managed.
- 12.9: Additional requirements for service providers only
- 12.10: Suspected and confirmed security incidents that could impact the CDE are responded to immediately.
12. Maintain an Information Security Policy
Establish comprehensive governance through documented policies, third-party risk management, and incident response preparedness to protect cardholder data environments and align organizational practices with PCI DSS objectives.
Control Types
Key Risks
Frequently Asked Questions
What are the critical updates to Requirement 12 in PCI DSS 4.0.1?
PCI DSS 4.0.1 introduces three key clarifications: 1) Explicit requirement for targeted risk analyses (12.3.1) to validate control effectiveness , 2) Expanded third-party service provider agreements requiring written confirmation of PCI DSS responsibilities , and 3) Mandated 24/7 incident response capabilities with immediate action on suspected events . The update emphasizes continuous policy adaptation rather than annual reviews alone, requiring integration with business change management processes.
What documentation is required for third-party service provider compliance?
Organizations must maintain: 1) Written agreements specifying PCI DSS responsibilities , 2) Quarterly reviews of service providers' compliance status , 3) Inventory of all third parties with access to CDE, and 4) Evidence of due diligence during vendor selection. PCI DSS 4.0.1 specifically requires service providers to acknowledge in writing their responsibility for cardholder data security, including detailed incident reporting procedures.
How should incident response plans be structured under Requirement 12.10?
Incident response plans must include: 1) 24/7 availability of trained personnel , 2) Integration with security monitoring systems (IDS/IPS, FIM) , 3) Business continuity procedures for payment operations, and 4) Post-incident analysis processes. PCI DSS 4.0.1 mandates immediate response to suspected incidents with automated alerts from security tools and annual penetration testing of response procedures.
What are the requirements for security policy maintenance?
Policies must be: 1) Reviewed annually and after significant environmental changes , 2) Distributed to all personnel with role-specific training , 3) Integrated with risk assessment processes (12.3), and 4) Version-controlled with change histories. PCI DSS 4.0.1 requires policies to address emerging threats like Magecart attacks and cloud misconfigurations, with executive leadership formally approving all revisions.
How does Requirement 12.3.1 impact risk management practices?
Targeted risk analyses under 12.3.1 require organizations to: 1) Conduct quarterly assessments of high-risk areas (e.g., third-party access, cloud migrations), 2) Document risk acceptance criteria for compensating controls, and 3) Align risk tolerance with payment brand requirements. PCI DSS 4.0.1 mandates these analyses use standardized frameworks like NIST CSF and integrate findings into policy updates.
Common QSA Questions
Show evidence of executive review and approval for the current security policy?
We maintain version-controlled policy documents signed by our CISO and Board Risk Committee, dated 03/15/2025. The approval package includes change logs highlighting updates for cloud access controls and third-party monitoring procedures. Our governance portal tracks 100% employee acknowledgment, with quarterly attestation reports for privileged users.
Demonstrate third-party PCI DSS responsibility agreements?
Our vendor management system contains 78 active agreements with sections 4.2-4.5 specifying: 1) Incident notification SLAs (<1 hour for confirmed breaches), 2) Right-to-audit clauses, and 3) Cryptographic standards for data transmission. Sample contracts show service providers' written acceptance of PCI DSS obligations, validated through annual re-certifications.
Provide incident response test results from the last 12 months?
Our 01/2025 tabletop exercise simulated a ransomware attack on payment gateways, achieving full containment in 23 minutes. Evidence includes: 1) IRP checklist completion timestamps, 2) Splunk alert correlation metrics, and 3) Post-mortem analysis improving cloud backup verification procedures. Quarterly phishing simulations show 98% staff adherence to reporting protocols.
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