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

12.7.1 Pre-hire screening of personnel with CDE access

Prospective personnel who will have CDE access must be screened before hiring, within the limits of local law, to reduce the risk of attacks from within. The guidance suggests screening depth suit the position and that entities consider screening existing staff moving into CDE-access roles. Applicability: for hires such as store cashiers who only access a single card number at a time while processing a transaction, this is a recommendation only. Customized approach objective: the risk of granting new staff CDE access is understood and managed.

Source: PCI DSS v4.0.1, 12.7.1. 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
1
held by a system
1
at each review
moderate
to go live
HR system / LMS
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

  • Screening completion records for sampled CDE-access hires · HR system / LMS

periodic reviewEvidence produced at each review

  • Legal review of screening constraints by jurisdiction · HR system / LMS

governing documentDocuments that govern the control

  • Background screening policy and procedure · HR system / LMS
  • Role list identifying positions with CDE access · Policy repository / GRC workspace

First move

Start with the 1 of 4 artefacts that already live in a system (HR system / LMS); keep the periodic reviews but log each one as a dated record with a named reviewer.

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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12.6.3.2 Awareness training covers acceptable use of end-user technologies · 12.8.1 List of third-party service providers