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

3.7.1 Generation of strong cryptographic keys

Key-management policies and procedures must be in place covering the generation of strong keys that secure stored account data. Guidance points to the Appendix G sources on cryptographic key generation. Guidance explains that strong keys materially raise the protection of encrypted account data. Customized approach objective: the keys the entity generates are strong.

Source: PCI DSS v4.0.1, 3.7.1. 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.

4
artefacts
1
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 key generation logs · Key management / PKI

periodic reviewEvidence produced at each review

  • Key ceremony records · Document repository
  • Observation of a key generation event · Document repository

governing documentDocuments that govern the control

  • Key generation procedure specifying algorithms, key lengths and approved random number generators · Policy repository / GRC workspace

First move

Start with the 1 of 4 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.

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3.6.1.4 Cryptographic keys kept in fewest locations · 3.7.2 Secure distribution of cryptographic keys