EvidenceSheet
PCI DSS v4.0.1 · Req 12: Information Security Policies

12.10.4.1 Responder training frequency set by targeted risk analysis

How often incident response personnel receive periodic training must be set out in a targeted risk analysis by the entity, carried out according to all elements of Requirement 12.3.1. The guidance says relevant factors can include entity size and complexity, rate of change, team size and staff turnover. Objective under the customized approach: responders are trained at a frequency that matches the entity's risk. Future-dated: treated as a best practice up to 31 March 2025 and mandatory since then.

Source: PCI DSS v4.0.1, 12.10.4.1. 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.

4
artefacts
0
held by a system
2
at each review
hard
to go live
HR system / LMS
where the evidence lives
teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

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

none for this control

periodic reviewEvidence produced at each review

  • Completion records matching the defined frequency · HR system / LMS
  • Annual review of the analysis under 12.3.1 · Document repository

governing documentDocuments that govern the control

  • Targeted risk analysis setting responder training frequency · HR system / LMS
  • Training schedule derived from the analysis · HR system / LMS

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

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.

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12.10.4 Periodic training for incident response personnel · 12.10.5 Plan covers alerts from security monitoring systems