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

3.7.8 Key custodians formally acknowledge responsibilities

Key-management policies and procedures must be in place requiring each key custodian to confirm formally (on paper or electronically) that they understand the custodian duties and accept them. Guidance suggests an annual reaffirmation to remind custodians of their duties. Customized approach objective: key custodians understand their responsibilities for cryptographic operations and can obtain help and guidance when they need it.

Source: PCI DSS v4.0.1, 3.7.8. 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
0
held by a system
2
at each review
hard
to go live
HR system / LMS
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

none for this control

periodic reviewEvidence produced at each review

  • Signed or electronically accepted acknowledgements for every current custodian · HR system / LMS
  • Records of any periodic reaffirmation · Document repository

governing documentDocuments that govern the control

  • Key custodian responsibility form or agreement template · Vendor register / contract repository
  • Custodian register cross-referenced to acknowledgements · HR system / LMS

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

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

3.7.7 Prevent unauthorized substitution of keys · 3.7.9 Key guidance for service provider customers