EvidenceSheet

9.3.1 Personnel physical access procedures for the CDE

Procedures must be in operation for authorizing and managing physical entry to the CDE by personnel, covering: how personnel are identified; how changes to a person's physical access needs are handled; how personnel identification is revoked or terminated; and limiting who can reach the identification process or system (such as the badge system and badge stock) to authorized people only. The guidance gives badges as one way to identify personnel and stresses visually identifying whether someone present is an employee or a visitor. Applicability: all entities. Objective under the customized approach: rules for physical entry into the CDE are set and applied so that personnel are identified and authorized.

Source: PCI DSS v4.0.1, 9.3.1. 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
1
at each review
moderate
to go live
Physical access / facilities
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

  • Badge request and approval forms, and change tickets for access modifications · Physical access / facilities
  • Badge system administrator account list and blank badge stock custody log · Physical access / facilities

periodic reviewEvidence produced at each review

  • Observation notes confirming personnel in the CDE wear identification · Physical access / facilities

governing documentDocuments that govern the control

  • Documented badge issuance, change and revocation procedure for CDE access · Policy repository / GRC workspace
  • Termination checklists showing badge deactivation · Policy repository / GRC workspace

First move

Start with the 2 of 5 artefacts that already live in a system (Physical access / facilities); 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

9.2.4 Locking of consoles in sensitive areas · 9.3.1.1 Personnel access to sensitive areas controlled