12.6.1 Formal security awareness program implemented
A formal security awareness program is implemented to make all personnel aware of the entity's information security policy and procedures and of their own role in protecting cardholder data, so personnel understand the t
5
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
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- Completion and attendance records covering all personnel · HR system / LMS
- Evidence the program is formally owned and approved · HR system / LMS
governing documentDocuments that govern the control
- The documented security awareness program and its curriculum · HR system / LMS
- Program content showing coverage of the information security policy and procedures and of personnel's role in protecting cardholder data · Policy repository / GRC workspace
- Coverage report reconciling completions against the full personnel roster including contractors · HR system / LMS
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
- Awareness delivered as an informal email rather than a formal program
- Content covers generic phishing only and never mentions cardholder data
- Contractors, temporary staff and third parties excluded from the roster
- Completion tracked but non-completers never chased
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 sheet12.5.3 Impact analysis on org structure changes (SP) · 12.6.2 Security awareness program reviewed annually