3.1.1 All security policies and operational procedures that are identified in Requirement 3 are documented, kept up to date, in use, and known to all affected parties.
Defined Approach Requirements
3.1.1 All security policies and operational procedures that are identified in Requirement 3 are: • Documented. • Kept up to date. • In use. • Known to all affected parties.
Customized Approach Objective
Expectations, controls, and oversight for meeting activities within Requirement 3 are defined and adhered to by affected personnel. All supporting activities are repeatable, consistently applied, and conform to management's intent.
Defined Approach Testing Procedures
3.1.1 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.
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 this reason, 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.
purpose
Document and communicate policies and procedures for protecting stored account data.
compliance strategies
- Centralized policy repository
- Annual review and staff training
typical policies
- Data Storage Policy
- Retention and Disposal Procedures
common pitfalls
- Outdated documentation
- Staff unaware of retention rules
type
Documentation Control
difficulty
Low
key risks
- Uncontrolled storage of cardholder data
recommendations
- Use document management systems for version control
Eligible SAQ
- SAQ-A
- SAQ-A-EP
- SAQ-B
- SAQ-B-IP
- SAQ-C
- SAQ-C-VT
- SAQ-D MERCHANT
- SAQ-D SERVICE PROVIDER
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