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3.7.7 Prevention of unauthorized substitution of cryptographic keys

Original requirement from PCI DSS v4.0.1

Defined Approach Requirements

3.7.7 Key management policies and procedures are implemented to include the prevention of unauthorized substitution of cryptographic keys.

Customized Approach Objective

Cryptographic keys cannot be substituted by unauthorized personnel.

Defined Approach Testing Procedures

3.7.7.a Examine the documented key-management policies and procedures for keys used for protection of stored account data and verify that they define prevention of unauthorized substitution of cryptographic keys.

3.7.7.b Interview personnel and/or observe processes to verify that unauthorized substitution of keys is prevented.

Purpose

If an attacker is able to substitute an entity's key with a key the attacker knows, the attacker will be able to decrypt all data encrypted with that key.

Good Practice

The encryption solution should not allow for or accept substitution of keys from unauthorized sources or unexpected processes.

Controls should include ensuring that individuals with access to key components or shares do not have access to other components or shares that form the necessary threshold to derive the key.

purpose

Ensure personnel are trained on data retention and disposal requirements.

compliance strategies

  • Annual training
  • Awareness campaigns

typical policies

  • Data Retention Training Policy

common pitfalls

  • Untrained staff
  • No training records

type

Training/Process Control

difficulty

Low

key risks

  • Improper data handling

recommendations

  • Track and document training completion

Eligible SAQ

  • SAQ-D MERCHANT
  • SAQ-D SERVICE PROVIDER

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