12.10.7 Response procedures for PAN detection in unexpected locations
Incident response procedures are in place, to be initiated upon the detection of stored PAN anywhere it is not expected, including processes to determine PAN was stored, remediation, and prevention.
5
artefacts
1
held by a system
3
at each review
hard
to go live
Document repository
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
- DLP or discovery scan results and triage · Vulnerability scanner / patch tooling
periodic reviewEvidence produced at each review
- Sample incident records with remediation · Document repository
- Root cause analysis records · Document repository
- Prevention controls update evidence · Document repository
governing documentDocuments that govern the control
- Procedure for handling PAN in unexpected locations · 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
- No discovery process
- Findings not investigated
- Preventive controls not updated
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