3.1.1 Requirement 3 policies and procedures maintained and in use
Every security policy and operational procedure that supports Requirement 3 (protection of stored account data) must be written down, kept current, actively followed in practice, and communicated to every party they affect. The guidance encourages revising these documents promptly whenever processes, technology or business objectives change rather than waiting for a scheduled review cycle. Customized approach objective: personnel involved in storing and protecting account data follow defined expectations, controls and oversight, so the supporting work is repeatable, consistent and matches what management intends.
Source: PCI DSS v4.0.1, 3.1.1. 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.
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
- Change log linking recent process or technology changes to document updates · SIEM / log platform
periodic reviewEvidence produced at each review
- Distribution or acknowledgement records showing the documents reached affected staff and third parties · HR system / LMS
governing documentDocuments that govern the control
- Data protection and cryptography policy covering all Requirement 3 topics, with version history and approval record · Policy repository / GRC workspace
- Operational procedures for retention, masking, encryption and key management with last-revision dates · Policy repository / GRC workspace
First move
Common gaps auditors find
- Policies exist but cover only encryption and omit retention, masking or SAD handling
- Documents last revised years ago and no longer match the deployed key management tooling
- Operations staff unaware of where procedures are kept or what they require
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 sheet2.3.2 Wireless encryption keys changed on triggers · 3.1.2 Assigned duties for Requirement 3 activities