3.5.1.1 Hashes of PAN use keyed cryptographic functions
Hashes used to render PAN unreadable are keyed cryptographic hashes of the entire PAN with associated key management processes.
5
artefacts
1
held by a system
3
at each review
hard
to go live
Document repository
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
- HMAC or equivalent configuration · Cloud console / configuration management
periodic reviewEvidence produced at each review
- Key custodian records · Document repository
- Code review showing entire PAN hashed · Source control / CI pipeline
- Key rotation evidence · Key management / PKI
governing documentDocuments that govern the control
- Algorithm and key length documentation · Document repository
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
- Plain SHA without key
- Truncated PAN hashed
- No key rotation
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 sheet3.5.1 PAN rendered unreadable wherever stored · 3.5.1.2 Disk-level encryption with logical access controls