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

3.6.1.3 Cleartext key component access limited to minimum custodians

Access to cryptographic key components in cleartext must be limited to the smallest number of custodians needed. Guidance advises that only staff with defined custodian duties (creating, changing, rotating, distributing or maintaining keys) receive access to key components, ideally a very small group. Guidance explains that limiting who can reach cleartext components lowers the chance that unauthorized parties retrieve stored account data or make it visible. Customized approach objective: only necessary personnel can access cleartext cryptographic key components.

Source: PCI DSS v4.0.1, 3.6.1.3. 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
2
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

  • Safe access logs · Identity provider / directory

periodic reviewEvidence produced at each review

  • Custodian appointment records with defined duties · Identity provider / directory
  • Periodic review of custodian access · Identity provider / directory

governing documentDocuments that govern the control

  • Access list for key component safes, envelopes or HSM smart cards · Policy repository / GRC workspace

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.

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3.6.1.2 Permitted storage forms for secret and private keys · 3.6.1.4 Cryptographic keys kept in fewest locations