EvidenceSheet

12.4.1 Executive responsibility for a PCI DSS compliance program

Service providers only: executive management must set up responsibility for protecting cardholder data and for a PCI DSS compliance program, covering: overall accountability for keeping PCI DSS compliance; and defining a charter for the compliance program along with communication to executive management. Applicability: applies only where the assessed entity is a service provider. Executive management can mean C-level roles, the board or an equivalent, with titles depending on the organisation's structure; responsibility for the program may be allocated to individual roles and/or business units. Customized approach objective: executives are answerable and accountable for cardholder data security.

Source: PCI DSS v4.0.1, 12.4.1. 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
1
at each review
hard
to go live
Policy repository / GRC workspace
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

  • Records of charter communication to executive management · Policy repository / GRC workspace

governing documentDocuments that govern the control

  • PCI DSS compliance program charter · Policy repository / GRC workspace
  • Board or executive resolution assigning overall accountability · Policy repository / GRC workspace
  • Organisation chart showing program ownership · Document repository

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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12.3.4 Annual review of hardware and software technologies · 12.4.2 Quarterly reviews that personnel follow security procedures