12.4.1 Executive management responsibility for the PCI DSS compliance program (service providers)
Additional requirement for service providers only. Executive management establishes responsibility for the protection of cardholder data and for a PCI DSS compliance program, covering overall accountability for maintaini
5
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
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- Board or executive meeting minutes recording the assignment and the program reporting · Policy repository / GRC workspace
governing documentDocuments that govern the control
- Documented assignment by executive management of responsibility for protecting cardholder data · Document repository
- The PCI DSS compliance program charter and evidence it was communicated to executive management · Policy repository / GRC workspace
- Named executive or role holding overall accountability for maintaining PCI DSS compliance · Policy repository / GRC workspace
- Organisation chart or role description tying the accountability to a real position · Policy repository / GRC workspace
First move
This control is evidenced by people and documents, not systems. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date. Do not try to automate it.
Common gaps auditors find
- Accountability implied by an org chart but never formally established
- Charter drafted by the security team and never taken to executive management
- Assignment made to a departed individual and not reassigned
- Entity is a service provider but treats this requirement as not applicable
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 sheet12.3.4 Hardware and software technologies reviewed annually · 12.4.2 Quarterly PCI compliance reviews (SP)