What evidence do auditors commonly ask for on 3.1.2 Assigned duties for Requirement 3 activities?

RACI matrix or role descriptions for data retention, masking, encryption and key custodian activities; Named assignments (people or teams) for each Requirement 3 activity; Signed or electronic acknowledgements of assigned responsibilities; Interview notes with owners of key management and data disposal tasks.

What is the most common gap auditors find on 3.1.2?

Roles documented generically with no named owner for quarterly data purge checks

PCI DSS v4.0.1 · Req 3: Protect Stored Account Data

`3.1.2` Assigned duties for Requirement 3 activities

The roles and duties for carrying out the activities in Requirement 3 must be written down, allocated to named people or functions, and understood by the individuals who hold them. Guidance notes they may sit inside the policies and procedures or in separate documents, offers a responsibility matrix (RACI) as one way to record them, and suggests entities consider having staff acknowledge their assigned duties. Customized approach objective: day-to-day work for protecting stored account data is allocated, and the people involved are accountable for its ongoing, successful operation.

Source: PCI DSS v4.0.1, 3.1.2. 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.

artefacts

held by a system

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

Signed or electronic acknowledgements of assigned responsibilities · HR system / LMS
Interview notes with owners of key management and data disposal tasks · Key management / PKI

governing documentDocuments that govern the control

RACI matrix or role descriptions for data retention, masking, encryption and key custodian activities · Policy repository / GRC workspace
Named assignments (people or teams) for each Requirement 3 activity · 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

Roles documented generically with no named owner for quarterly data purge checks
Key custodian duties assigned on paper to staff who have since left
Personnel cannot describe what their assigned Requirement 3 duties are

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 sheet

3.1.1 Requirement 3 policies and procedures maintained and in use · 3.2.1 Data retention and disposal minimise stored account data