9.4.1.1 Secure storage location for offline backups
Offline media backups that contain cardholder data must be kept in a secure location. The guidance describes off-site storage, for instance at a commercial storage provider or an alternate or backup site, as good practice, and notes that backups in a non-secured facility could be lost, stolen or copied. Applicability: entities keeping offline backups with cardholder data. Customized approach objective: unauthorized personnel cannot reach offline backups by unauthorized personnel.
Source: PCI DSS v4.0.1, 9.4.1.1. 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.
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
- Tape or disk check-in and check-out logs at the storage site · SIEM / log platform
periodic reviewEvidence produced at each review
none for this control
governing documentDocuments that govern the control
- Backup media storage procedure naming the secure storage location · Policy repository / GRC workspace
- Contract and security description for any commercial off-site storage vendor · Vendor register / contract repository
- Access list for the backup storage room or vault · Policy repository / GRC workspace
First move
Common gaps auditors find
- Backup tapes stored in an unlocked office cupboard awaiting courier pickup
- Off-site vendor used with no evidence of its security controls
- Backup media stored alongside production in the same unsecured room
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 sheet9.4.1 Physical security of all media · 9.4.1.2 Annual review of offline backup location security