EvidenceSheet

3.6.1.2 Permitted storage forms for secret and private keys

Secret and private keys that protect stored account data must at all times exist in one or more of these forms: (1) wrapped by a key-encrypting key whose strength equals or exceeds that of the data-encrypting key, held apart from it; (2) inside a secure cryptographic device (SCD), for example an HSM or a point-of-interaction device with PTS approval; (3) split into at least two full-length components or shares using a method the industry accepts. Applicability: public keys need not be held in these forms; keys held in a KMS that uses SCDs are acceptable; merely splitting a key into two halves does not comply, and any key component or share has to be generated either by an approved random number generator inside an SCD OR in line with ISO 19592 or an equivalent standard for secret key share generation. Objective under the customized approach: secret and private keys are kept in a secure form that stops unauthorized retrieval or access.

Source: PCI DSS v4.0.1, 3.6.1.2. 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
2
at each review
moderate
to go live
Key management / PKI
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

  • HSM or KMS configuration showing keys never exported in clear · Key management / PKI
  • Configuration evidence of KEK strength and separate storage from DEKs · Cloud console / configuration management

periodic reviewEvidence produced at each review

  • Key component or share generation records (RNG within SCD or ISO 19592 method) · Document repository
  • PTS approval listing for POI devices holding keys · Endpoint management (MDM / EDR)

governing documentDocuments that govern the control

  • Key storage procedure naming permitted forms · Policy repository / GRC workspace

First move

Start with the 2 of 5 artefacts that already live in a system (Key management / PKI); 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

3.6.1.1 Service provider cryptographic architecture documented · 3.6.1.3 Cleartext key component access limited to minimum custodians