Mandatory compliance checks that must be performed for assurance of PCI DSS 4.0 Requirements.

1. Scope Identification

2. Security Policy

  • Draft a comprehensive security policy document.
  • Include all relevant security requirements.
  • Distribute the policy to all employees.
  • Ensure access to the policy is easy for all staff.
  • Require employees to acknowledge receipt and understanding.
  • Set a calendar reminder for annual reviews.
  • Assign a team to evaluate the current policy.
  • Incorporate feedback from employees and stakeholders.
  • Document changes clearly and communicate to staff.
  • Ensure updates align with the latest regulatory requirements.
  • Identify key personnel responsible for security.
  • Clearly outline their specific security tasks.
  • Document roles in the security policy.
  • Ensure accountability for security practices.
  • Review and adjust roles as necessary.
  • Specify acceptable and unacceptable behaviors.
  • Outline consequences for violations.
  • Include guidelines for personal use of company assets.
  • Communicate the policy to all employees.
  • Reinforce guidelines through regular training.
  • Establish a vulnerability assessment schedule.
  • Define tools and methodologies for assessments.
  • Assign responsibilities for vulnerability management.
  • Document and communicate findings promptly.
  • Track remediation efforts and updates.
  • Identify critical third-party vendors.
  • Establish security requirements for vendor contracts.
  • Implement a vendor risk assessment process.
  • Review vendor compliance regularly.
  • Document findings and actions taken.
  • Define what constitutes a security incident.
  • Establish a clear reporting structure.
  • Provide contact information for reporting.
  • Ensure timely response procedures are documented.
  • Regularly train employees on incident reporting.
  • Define risk assessment methodologies.
  • Schedule regular risk assessments.
  • Document and prioritize identified risks.
  • Establish risk mitigation strategies.
  • Review and update the framework regularly.
  • Define data classification levels (e.g., public, confidential).
  • Document handling procedures for each classification.
  • Train employees on data classification importance.
  • Review classifications regularly for accuracy.
  • Ensure compliance with data protection regulations.
  • Identify applicable laws and regulations.
  • Incorporate compliance requirements into the policy.
  • Regularly review changes in legal obligations.
  • Document compliance efforts and evidence.
  • Train employees on relevant laws.
  • Develop training materials based on the policy.
  • Schedule regular training sessions for employees.
  • Use multiple formats (e.g., workshops, e-learning).
  • Evaluate training effectiveness through assessments.
  • Encourage ongoing security awareness.
  • Schedule regular internal audits.
  • Define the scope and methodology for audits.
  • Document and report audit findings.
  • Establish corrective action plans.
  • Review audit results with management.
  • Clearly outline disciplinary actions for violations.
  • Communicate consequences to all employees.
  • Ensure consistent enforcement of consequences.
  • Document incidents of non-compliance.
  • Review and update consequences as necessary.
  • Develop a feedback mechanism (e.g., surveys, suggestion boxes).
  • Encourage open communication about policy effectiveness.
  • Review feedback regularly and incorporate changes.
  • Communicate updates based on employee feedback.
  • Recognize employees for constructive suggestions.

3. Risk Assessment

  • Gather information on cardholder data flows.
  • Identify potential threats and vulnerabilities.
  • Analyze existing security measures.
  • Engage stakeholders for input and insights.
  • Document findings for further analysis.
  • Outline specific actions to address identified risks.
  • Assign responsibilities for each mitigation strategy.
  • Set timelines for implementation.
  • Define success criteria for mitigation efforts.
  • Ensure documentation is accessible for review.
  • Gather information on cardholder data flows.
  • Identify potential threats and vulnerabilities.
  • Analyze existing security measures.
  • Engage stakeholders for input and insights.
  • Document findings for further analysis.
  • Outline specific actions to address identified risks.
  • Assign responsibilities for each mitigation strategy.
  • Set timelines for implementation.
  • Define success criteria for mitigation efforts.
  • Ensure documentation is accessible for review.

4. Access Control

  • Define roles and responsibilities for personnel accessing cardholder data.
  • Utilize role-based access control (RBAC) to limit data access.
  • Establish an approval process for granting access.
  • Document and review access requests for accountability.
  • Schedule regular reviews of user access rights.
  • Adjust access based on changes in job roles or responsibilities.
  • Maintain records of review dates and actions taken.
  • Ensure that reviews involve relevant stakeholders.
  • Assign unique usernames to all users accessing sensitive data.
  • Avoid shared accounts to maintain accountability.
  • Implement logging for all user actions tied to unique IDs.
  • Regularly verify the uniqueness of each ID.
  • Define minimum password complexity requirements.
  • Set a maximum password age for regular changes.
  • Educate users about password best practices.
  • Implement automated reminders for password changes.
  • Select appropriate MFA methods (e.g., SMS, authenticator apps).
  • Ensure MFA is mandatory for all access to sensitive systems.
  • Provide training on MFA usage to all personnel.
  • Regularly test the effectiveness of MFA mechanisms.
  • Conduct a data access needs assessment for each role.
  • Implement strict policies for data access requests.
  • Review and document access rights periodically.
  • Ensure users understand the principle of least privilege.
  • Create and regularly update an access control list (ACL).
  • Include details such as user IDs, roles, and access levels.
  • Ensure the ACL is reviewed by management periodically.
  • Store the ACL securely to prevent unauthorized changes.
  • Set a maximum inactivity time for user sessions.
  • Configure automatic log-off for inactive sessions.
  • Notify users before sessions time out to prevent loss of data.
  • Test session timeout functionality regularly.
  • Implement logging mechanisms for all access events.
  • Store logs securely and ensure they are tamper-proof.
  • Regularly review logs for suspicious activities.
  • Set up alerts for unauthorized access attempts.
  • Define the scope of background checks based on roles.
  • Conduct checks before granting access to sensitive data.
  • Document all findings and decisions related to background checks.
  • Review background check policies periodically.
  • Identify all systems that process cardholder data.
  • Integrate access control measures into system design.
  • Conduct regular audits to ensure compliance with access controls.
  • Provide training on access control measures to all staff.
  • Establish a formal offboarding process for terminating access.
  • Ensure immediate revocation of access upon employee departure.
  • Document access termination actions in personnel records.
  • Communicate changes in access rights to relevant teams.

5. Data Protection

  • Use TLS for data in transit.
  • Employ AES-256 or stronger for data at rest.
  • Verify encryption implementation regularly.
  • Document encryption protocols used.
  • Maintain encryption keys securely.
  • Choose industry-standard cryptographic algorithms.
  • Implement secure key management practices.
  • Regularly update cryptographic libraries.
  • Avoid deprecated algorithms.
  • Ensure secure configuration of systems.
  • Schedule periodic reviews of algorithms.
  • Stay informed on industry trends.
  • Update documentation reflecting changes.
  • Conduct training on new practices.
  • Assess alignment with regulatory requirements.
  • Define data retention policies.
  • Implement data minimization techniques.
  • Regularly audit stored cardholder data.
  • Securely delete data that exceeds retention.
  • Document data retention justifications.
  • Evaluate tokenization solutions available.
  • Integrate tokenization into existing systems.
  • Document tokenization processes.
  • Conduct regular reviews of tokenization effectiveness.
  • Ensure tokens are stored securely.
  • Implement role-based access controls.
  • Regularly review access permissions.
  • Maintain an access control list.
  • Log access to sensitive data.
  • Conduct periodic access audits.
  • Schedule vulnerability assessments quarterly.
  • Engage third-party testers for impartiality.
  • Prioritize identified vulnerabilities for remediation.
  • Document testing results and actions taken.
  • Review assessment methodologies annually.
  • Create a detailed asset inventory.
  • Regularly update the inventory.
  • Classify assets based on sensitivity.
  • Assign ownership for each asset.
  • Review inventory for compliance regularly.
  • Select appropriate DLP solutions.
  • Configure rules to detect sensitive data.
  • Conduct regular testing of DLP effectiveness.
  • Review incident reports generated by DLP.
  • Update DLP policies as necessary.
  • Assess third-party compliance status.
  • Obtain and review PCI DSS attestation.
  • Include data protection clauses in contracts.
  • Monitor third-party security practices.
  • Conduct regular audits of third-party compliance.
  • Establish clear data disposal procedures.
  • Utilize secure deletion tools.
  • Train staff on data disposal methods.
  • Document disposal actions taken.
  • Review policies annually for effectiveness.
  • Schedule regular training sessions.
  • Develop training materials focused on data security.
  • Assess staff understanding through quizzes.
  • Update training content as needed.
  • Document attendance and training completion.

6. Monitoring and Testing

  • Perform vulnerability scans at least quarterly and after any significant changes.
  • Conduct penetration testing annually, or after changes to the environment.
  • Ensure scans and tests cover all systems handling cardholder data.
  • Log all access attempts to cardholder data systems.
  • Store logs securely for at least one year.
  • Regularly review logs for anomalies and unauthorized access.
  • Deploy intrusion detection systems (IDS) for real-time alerts.
  • Utilize security information and event management (SIEM) tools.
  • Establish clear thresholds for alerting on suspicious activities.
  • Conduct weekly or monthly reviews of security logs.
  • Document findings and escalate any potential incidents.
  • Use automated tools to assist in log analysis.
  • Review configurations at least biannually or after major changes.
  • Test firewall rules for effectiveness against established policies.
  • Ensure documentation of configuration reviews is maintained.
  • Implement a patch management schedule for all systems.
  • Prioritize vulnerabilities based on risk and impact.
  • Document remediation efforts and verify effectiveness post-patching.
  • Conduct risk assessments annually or after significant changes.
  • Perform security audits to validate control implementation.
  • Document and address any identified weaknesses.
  • Deploy file integrity monitoring (FIM) solutions.
  • Set baseline configurations for all systems.
  • Regularly review alerts generated by monitoring tools.
  • Review incident response plans at least annually.
  • Incorporate lessons learned from recent incidents and tests.
  • Conduct tabletop exercises to test the effectiveness of plans.
  • Create an inventory of all systems handling cardholder data.
  • Verify monitoring coverage for all identified systems.
  • Update monitoring protocols as new systems are added.
  • Keep detailed records of all monitoring results.
  • Review documentation for completeness and accuracy regularly.
  • Ensure records are accessible for audits and compliance checks.
  • Schedule annual assessments with qualified third-party experts.
  • Provide them access to monitoring and testing documentation.
  • Review their findings and recommendations for improvements.

7. Incident Response

  • Identify potential security incidents.
  • Outline detection, response, and recovery procedures.
  • Assign resources and responsibilities for incident management.
  • Establish a timeline for plan implementation.
  • Integrate the plan with existing security policies.
  • Schedule regular testing dates.
  • Conduct tabletop exercises to simulate incidents.
  • Evaluate team performance and response times.
  • Document findings and areas for improvement.
  • Update the plan based on test results.
  • Identify potential security incidents.
  • Outline detection, response, and recovery procedures.
  • Assign resources and responsibilities for incident management.
  • Establish a timeline for plan implementation.
  • Integrate the plan with existing security policies.
  • Schedule regular testing dates.
  • Conduct tabletop exercises to simulate incidents.
  • Evaluate team performance and response times.
  • Document findings and areas for improvement.
  • Update the plan based on test results.
  • Define communication channels for incident reporting.
  • Create templates for incident reports.
  • Identify key stakeholders for notifications.
  • Establish a timeline for communication.
  • Review the protocol with all team members.
  • List all team members and their specific roles.
  • Assign a team leader for coordination.
  • Ensure redundancy in key roles.
  • Communicate roles to all personnel.
  • Review and update roles periodically.
  • Schedule training sessions for all staff.
  • Provide role-specific training for incident response team.
  • Use real-life scenarios for training exercises.
  • Evaluate training effectiveness through assessments.
  • Document training completion and feedback.
  • Create a standardized incident log format.
  • Record details of each incident promptly.
  • Include response actions and timelines.
  • Review logs regularly for trends.
  • Utilize logs to enhance future response efforts.
  • Gather the incident response team post-incident.
  • Analyze response actions and outcomes.
  • Identify strengths and weaknesses in response.
  • Document lessons learned and recommendations.
  • Disseminate findings to relevant stakeholders.
  • Review incident logs and post-incident reports.
  • Incorporate feedback from team members.
  • Adjust procedures and protocols as necessary.
  • Communicate updates to all personnel.
  • Ensure version control of the response plan.
  • Compile a list of external contacts.
  • Verify contact details periodically.
  • Establish agreements with external parties in advance.
  • Train the incident response team on engagement procedures.
  • Maintain a centralized contact directory.
  • Draft notification templates for various scenarios.
  • Determine notification timelines based on legal requirements.
  • Establish a communication channel for inquiries.
  • Coordinate messaging with legal and public relations teams.
  • Document all communications for compliance.
  • Designate personnel responsible for evidence collection.
  • Establish protocols for handling and storing evidence.
  • Ensure evidence integrity through chain of custody.
  • Train staff on evidence preservation techniques.
  • Document evidence collection procedures thoroughly.
  • Schedule regular policy review meetings.
  • Incorporate feedback from incident reviews.
  • Stay informed on emerging threats and trends.
  • Engage with industry best practices and compliance updates.
  • Communicate changes to all relevant personnel.

8. Training and Awareness

  • Schedule training sessions once a year.
  • Use a mix of formats: in-person, online, and recorded.
  • Track attendance and completion rates.
  • Gather feedback for continuous improvement.
  • Clarify individual responsibilities related to PCI DSS.
  • Provide examples of compliance and non-compliance.
  • Use role-specific scenarios for better understanding.
  • Encourage questions and discussions during training.
  • Identify roles with access to sensitive data.
  • Develop specific training modules for these roles.
  • Schedule training sessions regularly.
  • Include real-life scenarios and case studies.
  • Assess understanding through quizzes or evaluations.
  • Design realistic phishing scenarios.
  • Distribute simulated phishing emails to employees.
  • Monitor and analyze response rates.
  • Provide immediate feedback on employee actions.
  • Offer follow-up training based on results.
  • Subscribe to security threat intelligence feeds.
  • Schedule periodic updates on recent threats.
  • Create a newsletter or bulletin for employees.
  • Incorporate threat updates into training sessions.
  • Encourage discussion of threats in team meetings.
  • Draft concise, clear security policies.
  • Choose effective communication channels (e.g., email, intranet).
  • Schedule regular updates and reminders.
  • Ensure policies are accessible to all employees.
  • Solicit feedback on clarity and understanding.
  • Utilize multimedia formats (videos, infographics).
  • Incorporate quizzes to assess knowledge.
  • Make training interactive with scenarios.
  • Gather employee feedback on material effectiveness.
  • Update materials based on new information.
  • Create an anonymous feedback channel.
  • Encourage questions during training sessions.
  • Hold regular feedback meetings or forums.
  • Implement a suggestion box for ideas.
  • Review feedback to enhance training programs.
  • Conduct surveys after training sessions.
  • Use assessments to measure knowledge retention.
  • Analyze survey results for trends.
  • Identify topics requiring further training.
  • Adjust training content based on assessments.
  • Consult department heads for specific needs.
  • Customize training content for each department.
  • Schedule department-specific training sessions.
  • Gather feedback on training relevance.
  • Adjust materials based on departmental input.
  • Monitor changes in PCI DSS requirements.
  • Schedule refresher training sessions promptly.
  • Communicate changes clearly to all employees.
  • Include practical implications of changes.
  • Assess understanding of updated materials.
  • Develop a recognition program for security champions.
  • Publicly acknowledge employees' contributions.
  • Offer incentives for reporting incidents.
  • Share success stories within the organization.
  • Foster open discussions about security practices.

9. Documentation and Reporting

  • Collect records of all compliance activities.
  • Include evidence such as audit logs and assessment results.
  • Ensure documentation is up-to-date and accurate.
  • Store documents in a secure location.
  • Identify all relevant stakeholders and regulatory bodies.
  • Gather necessary data and information for reports.
  • Format reports according to regulatory guidelines.
  • Submit reports within specified deadlines.
  • Collect records of all compliance activities.
  • Include evidence such as audit logs and assessment results.
  • Ensure documentation is up-to-date and accurate.
  • Store documents in a secure location.
  • Identify all relevant stakeholders and regulatory bodies.
  • Gather necessary data and information for reports.
  • Format reports according to regulatory guidelines.
  • Submit reports within specified deadlines.
  • Track every change with date, author, and reason.
  • Maintain a version history for all documents.
  • Ensure stakeholders are notified of changes.
  • Archive old versions for reference.
  • Select a secure and accessible storage solution.
  • Organize documents by categories for easy navigation.
  • Implement access controls to manage permissions.
  • Regularly back up the repository.
  • Set specific dates for reviews based on compliance cycles.
  • Assign responsible personnel for each review.
  • Document any changes made during reviews.
  • Notify stakeholders of updated documentation.
  • Track dates, topics, and trainers of sessions.
  • Collect attendance records for participants.
  • Store training materials in the centralized repository.
  • Review training logs for trends and compliance gaps.
  • Create a standardized format for documenting exceptions.
  • Include the reasons and approval for each exception.
  • Review exceptions periodically for relevance.
  • Ensure exceptions are communicated to relevant stakeholders.
  • Implement encryption for sensitive documents.
  • Use access controls to limit document availability.
  • Conduct regular security audits on documentation storage.
  • Train staff on best practices for document security.
  • Schedule periodic assessments of documentation.
  • Compare current documents against latest PCI DSS standards.
  • Make necessary updates based on assessment outcomes.
  • Involve relevant stakeholders in the review process.
  • Create a documentation template for uniformity.
  • Define required sections and content for compliance documents.
  • Include examples and best practices in guidelines.
  • Ensure guidelines are communicated to all departments.
  • Define user roles and access levels for documentation.
  • Implement a user-friendly interface for document access.
  • Train personnel on how to locate and use documentation.
  • Regularly review access permissions for updates.
  • Compile key findings from compliance assessments.
  • Highlight areas of concern and necessary actions.
  • Format summary for clarity and ease of understanding.
  • Present summary to management with actionable items.

10. Continuous Compliance

  • Define roles and responsibilities for compliance monitoring.
  • Utilize a compliance management framework.
  • Set up regular meetings to discuss compliance status.
  • Integrate compliance into daily operations.
  • Schedule monthly compliance review sessions.
  • Document findings and action items.
  • Assign responsibilities for gap remediation.
  • Track progress on addressing identified gaps.
  • Select appropriate compliance monitoring tools.
  • Configure tools to align with PCI DSS requirements.
  • Schedule regular updates and maintenance for tools.
  • Review tool effectiveness periodically.
  • Develop an internal audit schedule.
  • Create an audit checklist based on PCI DSS requirements.
  • Assign auditors and ensure they are trained.
  • Document audit findings and recommended improvements.
  • Create a centralized compliance requirements document.
  • Update the inventory regularly as requirements change.
  • Assign compliance status to each requirement.
  • Review and validate the inventory periodically.
  • Establish a review frequency (e.g., quarterly, annually).
  • Involve key stakeholders in the review process.
  • Document changes made during reviews.
  • Communicate updates to all relevant personnel.
  • Identify reputable third-party assessment firms.
  • Schedule assessments at least annually.
  • Provide necessary documentation and access to auditors.
  • Review and implement recommendations from assessments.
  • Create a dedicated communication channel for feedback.
  • Encourage employees to report issues without fear.
  • Review and address feedback regularly.
  • Recognize and reward compliance contributions.
  • Develop a training plan covering PCI DSS updates.
  • Schedule training sessions after major changes.
  • Provide materials and resources for self-study.
  • Evaluate training effectiveness through assessments.
  • Collect compliance data over defined periods.
  • Use data analytics tools to identify trends.
  • Document recurring issues and root causes.
  • Develop action plans to address identified trends.
  • Implement a document management system for compliance records.
  • Ensure records are securely stored and easily accessible.
  • Establish retention policies for compliance documentation.
  • Regularly review and update records for accuracy.
  • Identify key stakeholders in compliance processes.
  • Schedule regular collaboration meetings.
  • Share compliance goals and achievements.
  • Encourage cross-departmental initiatives for compliance.

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