What evidence do auditors commonly ask for on 12.10.7 Response procedures for PAN found in unexpected locations?

Procedure for unexpected PAN discovery; Data discovery scan results and triggered response tickets; Root cause analysis records identifying source of leaked PAN; Secure deletion or migration evidence; Remediation records for process gaps.

What is the most common gap auditors find on 12.10.7?

PAN deleted but no root cause identified, so it recurs

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

`12.10.7` Response procedures for PAN found in unexpected locations

Incident response procedures must exist, to be started whenever stored PAN is found where it is not expected, and must include: deciding what to do with PAN found outside the CDE, such as retrieving it, securely deleting it and/or moving it into the defined CDE as applicable; determining whether sensitive authentication data is stored alongside the PAN; establishing the source of the account data and how it reached the unexpected location; and fixing the data leaks or process gaps that caused it. Objective under the customized approach: processes exist to respond quickly, analyse and resolve cases where cleartext PAN is detected where it should not be. Future-dated: treated as a best practice up to 31 March 2025 and mandatory since then.

Source: PCI DSS v4.0.1, 12.10.7. 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.

artefacts

held by a system

at each review

hard

to go live

Document repository

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

Data discovery scan results and triggered response tickets · Vulnerability scanner / patch tooling

periodic reviewEvidence produced at each review

Root cause analysis records identifying source of leaked PAN · Document repository
Secure deletion or migration evidence · Document repository
Remediation records for process gaps · Document repository

governing documentDocuments that govern the control

Procedure for unexpected PAN discovery · Policy repository / GRC workspace

First move

Mostly documents and reviews. Pull the 1 system-held artefact from your Vulnerability scanner / patch tooling on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.

Common gaps auditors find

PAN deleted but no root cause identified, so it recurs
No check for sensitive authentication data alongside PAN
Procedure not linked to data discovery tooling outputs

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 sheet

12.10.6 Plan evolved from lessons learned and industry developments · A1.1.1 Logical separation between provider and customer environments