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4.1.1 All security policies and operational procedures that are identified in Requirement 4 are.

Original requirement from PCI DSS v4.0.1

Defined Approach Requirements

4.1.1 All security policies and operational procedures that are identified in Requirement 4 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 4 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

4.1.1 Examine documentation and interview personnel to verify that security policies and operational procedures identified in Requirement 4 are managed in accordance with all elements specified in this requirement.

Purpose

Requirement 4.1.1 is about effectively managing and maintaining the various policies and procedures specified throughout Requirement 4. While it is important to define the specific policies or procedures called out in Requirement 4, 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. Policies and procedures, including updates, are actively communicated to all affected personnel, and are supported by operating procedures describing how to perform activities.

purpose

Document and communicate policies and procedures for protecting cardholder data with strong cryptography during transmission over open, public networks.

compliance strategies

  • Centralized policy repository
  • Annual review and staff training

typical policies

  • Data Transmission Security Policy
  • Encryption Policy

common pitfalls

  • Outdated documentation
  • Staff unaware of secure transmission requirements

type

Documentation Control

difficulty

Low

key risks

  • Inconsistent protection of cardholder data in transit

recommendations

  • Use document management systems for version control

Eligible SAQ

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

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