EvidenceSheet

3.2.1 Data retention and disposal minimise stored account data

The entity limits stored account data through policies, procedures and processes governing how long data is kept and how it is disposed of, which address at minimum: (1) every location where account data is stored; (2) any sensitive authentication data (SAD) held before authorization completes; (3) restricting the volume held and the retention period to what legal, regulatory and/or business needs demand; (4) defined retention periods for stored account data, each with a documented business justification; (5) processes to securely delete account data, or make it unrecoverable, once the retention policy says it is no longer needed; and (6) a check performed at least every three months confirming that account data held beyond its retention period has been made unrecoverable or deleted securely. Applicability: where the data is stored by a third-party service provider such as a cloud provider, the entity is responsible for working with it to understand how the provider satisfies this requirement, with considerations including secure deletion of every geographic instance of a data element. Objective under the customized approach: account data is kept only where needed, for the shortest necessary time, and is securely removed or made unrecoverable afterwards. Future-dated (bullet covering SAD stored before authorization completes): treated as a best practice up to 31 March 2025 and mandatory since then.

Source: PCI DSS v4.0.1, 3.2.1. 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.

6
artefacts
1
held by a system
2
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

  • Secure deletion tool configuration or output (for example NIST SP 800-88 aligned wiping) and sample evidence of unrecoverable data · Cloud console / configuration management

periodic reviewEvidence produced at each review

  • Quarterly purge verification records (at least every three months) with results and sign-off · Data governance / DLP tooling
  • Pre-authorization SAD handling and retention records · Data governance / DLP tooling

governing documentDocuments that govern the control

  • Data retention and disposal policy with retention periods and business justification per data type · Policy repository / GRC workspace
  • Inventory or data-flow map of all account data storage locations, including backups, archives, removable media, paper and call recordings · Policy repository / GRC workspace
  • TPSP responsibility statements describing how cloud or hosting providers delete data across regions · Policy repository / GRC workspace

First move

Mostly documents and reviews. Pull the 1 system-held artefact from your Cloud console / configuration management on a schedule; put the documents under version control with an owner and review date, and log each review 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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3.1.2 Assigned duties for Requirement 3 activities · 3.3.1 SAD not retained after authorization, even encrypted