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

3.5.1 Stored PAN rendered unreadable

PAN must be made unreadable wherever it is stored, using one of these methods: (1) one-way hashes of the whole PAN based on strong cryptography; (2) truncation, where hashing may not substitute for the removed segment, and where hashed and truncated forms, or differing truncation formats, of the same PAN coexist in an environment, added controls must stop them being correlated to rebuild the original; (3) index tokens; (4) strong cryptography with supporting key-management processes and procedures. Applicability: covers PAN in primary storage (databases, flat files such as text files or spreadsheets) and non-primary storage (backups, audit, exception or troubleshooting logs); temporary files holding cleartext PAN during encryption and decryption are not prohibited. Customized approach objective: PAN held on any storage media is never readable in the clear.

Source: PCI DSS v4.0.1, 3.5.1. 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.

5
artefacts
2
held by a system
0
at each review
moderate
to go live
SIEM / log platform
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

  • Sample database and log extracts showing PAN unreadable · SIEM / log platform
  • Backup and archive encryption evidence · Backup / DR tooling

periodic reviewEvidence produced at each review

none for this control

governing documentDocuments that govern the control

  • Data storage inventory mapping each PAN location to its protection method · Policy repository / GRC workspace
  • Encryption, hashing, truncation or tokenization design documentation including algorithms · Document repository
  • Controls preventing correlation of hashed and truncated values (for example keyed hashing, segregation) · Document repository

First move

Start with the 2 of 5 artefacts that already live in a system (SIEM / log platform); 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

3.4.2 Remote access blocks copying or relocating PAN · 3.5.1.1 PAN hashes are keyed cryptographic hashes