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3.7 Key management processes and procedures for cryptographic keys used for encryption of stored account data

This requirement focuses on key management processes and procedures covering all aspects of the key lifecycle. It ensures that organizations have controls in place to manage cryptographic keys throughout their lifecycle, from generation to destruction.

Sub-requirements

3.7. Account data retention and disposal policies are implemented and enforced.

Ensure account data is retained only as long as necessary and securely deleted when no longer needed.

https://WithPCI.com
9
Sub-requirements
17
Test Points
Low-Moderate (2.3)
Implementation Difficulty

Control Types

Process
Technical
Documentation
Training
Process: 8
Technical: 2
Documentation: 1
Training: 1

Key Risks

Retention of unnecessary data
Incomplete data deletion
Inability to demonstrate compliance

Frequently Asked Questions

Why is data retention and disposal important?

Limiting data retention reduces risk and exposure in the event of a breach.

How should data retention policies be enforced?

Through automated deletion routines, regular audits, and staff training.

What is required for data deletion verification?

Documented evidence that data was deleted, such as logs or audit reports.

How are exceptions to retention policies managed?

Through documented approval processes and regular review of exceptions.

Who should be trained on retention and disposal policies?

All personnel who handle account data or manage data storage systems.

Common QSA Questions

Can you provide your data retention and disposal policies?

Yes, we have documented policies that define retention periods and secure deletion processes.

How do you verify that data deletion is successful?

We conduct periodic audits and maintain logs of all deletion activities.

How are exceptions to data retention policies handled?

Exceptions require management approval and are reviewed regularly.

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