12.1.1 Overall information security policy established and disseminated
The organisation must have one overarching information security policy that is formally set up, made available in published form, kept under maintenance, and distributed to every relevant member of personnel and to vendors and business partners who are relevant. The guidance defines 'relevant' as anyone whose role, internal or as an outside provider of services or functions, touches some or all of the topics the policy addresses. The guidance explains that this top-level policy governs the more specific technical and discipline policies beneath it. Objective under the customized approach: the strategic aims and principles of information security are set out, formally adopted, and understood by everyone who works for the entity.
Source: PCI DSS v4.0.1, 12.1.1. 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
- Policy maintenance history showing changes over time · Policy repository / GRC workspace
periodic reviewEvidence produced at each review
- Distribution records to staff and to relevant vendors and business partners · Vendor register / contract repository
governing documentDocuments that govern the control
- Approved overarching information security policy with version and owner · Policy repository / GRC workspace
- Policy publication location (intranet page or document portal) and access records · Policy repository / GRC workspace
First move
Common gaps auditors find
- Policy exists but was never shared with third parties who perform in-scope functions
- Several conflicting policies with no single top-level document governing them
- Published copy on the intranet differs from the approved master version
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 sheet11.6.1 Payment page tamper detection · 12.1.2 Security policy reviewed annually and updated as needed