EvidenceSheet

3.5.1.3 Disk encryption access independent of OS authentication

When whole-disk or partition encryption, rather than database file, column or field encryption, makes PAN unreadable, it must be managed so that: (1) logical access is managed apart from, and independently of, the operating system's own access control and authentication mechanisms; (2) decryption keys are not linked to user accounts; and (3) any authentication factor (password, passphrase or cryptographic key) that gives access to unencrypted data is stored securely. Applicability: such encryption must still comply with the remaining encryption and key-management rules of the standard. Guidance notes that many such tools decrypt transparently after a start-up password, which offers no defence against someone who already holds a valid account. Objective under the customized approach: disk encryption is set up so that decryption needs its own authentication and logical access controls.

Source: PCI DSS v4.0.1, 3.5.1.3. 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.

4
artefacts
1
held by a system
3
at each review
moderate
to go live
Identity provider / directory
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

  • Disk encryption product configuration showing separate pre-boot or volume authentication · Identity provider / directory

periodic reviewEvidence produced at each review

  • Evidence decryption keys are not tied to OS or domain user accounts · Identity provider / directory
  • Secure storage records for passphrases or recovery keys (vault, HSM) · Key management / PKI
  • Observation of the unlock process on a sample system · Document repository

governing documentDocuments that govern the control

none for this control

First move

Start with the 1 of 4 artefacts that already live in a system (Identity provider / directory); keep the periodic reviews but log each one 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.

Build my evidence sheet

3.5.1.2 Disk or partition encryption only on removable media · 3.6.1 Procedures protect keys against disclosure and misuse