3.3.3 SAD storage by issuers limited
For issuers and entities supporting issuing services that store SAD, SAD storage is limited to that needed for legitimate business need and is secured.
5
artefacts
2
held by a system
2
at each review
moderate
to go live
Cloud console / configuration management
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
- Encrypted storage configuration · Cloud console / configuration management
- Access logs to SAD stores · SIEM / log platform
periodic reviewEvidence produced at each review
- HSM integration evidence · Key management / PKI
- Annual review of need · Policy repository / GRC workspace
governing documentDocuments that govern the control
- Business justification document · Policy repository / GRC workspace
First move
Start with the 2 of 5 artefacts that already live in a system (Cloud console / configuration management); keep the periodic reviews but log each one as a dated record with a named reviewer.
Common gaps auditors find
- No documented business need
- Over-broad access
- Indefinite retention
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 sheet3.3.2 SAD stored prior to authorization is encrypted · 3.4.1 PAN is masked when displayed (the BIN and last four digits are the maximum number of digits to be displayed), such that only personnel with a legitimate business need can