10.2.1.1 Logs capture individual user access to cardholder data
Audit logs must record each instance of an individual user reaching cardholder data. Applies to all entities. The guidance notes that such a record links access to a specific user and helps show which accounts may have been misused or compromised, including accounts an attacker has created. Customized approach objective: every access to cardholder data by an individual user leaves a record.
Source: PCI DSS v4.0.1, 10.2.1.1. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open PCI DSS v4.0.1 in the compliance library.
Version 4.0.1 is the active version; 4.0 has been retired. Appendix A1 applies only to multi-tenant service providers, A2 only to card-present POS POI terminals that still use SSL or early TLS, and A3 only when a payment brand or acquirer requires it. Which requirements apply to you follows your validation type.
These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.
system holds itEvidence a system already holds
- Database or application audit configuration showing read access to cardholder data tables is logged · SIEM / log platform
- Sample log entries tying a named user ID to a cardholder data query or screen view · SIEM / log platform
periodic reviewEvidence produced at each review
none for this control
governing documentDocuments that govern the control
- Application logging design document for PAN display and retrieval functions · Policy repository / GRC workspace
- List of data stores holding cardholder data mapped to their access logging · Policy repository / GRC workspace
First move
Common gaps auditors find
- Access through shared service or application accounts hides which individual viewed the data
- Only changes to cardholder data are logged, not read access
- File shares or exports containing PAN have no access auditing
Do this for your whole sheet
Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.
Build my evidence sheet10.2.1 Audit logging enabled on all system components · 10.2.1.2 Logs capture all administrative actions