What evidence do auditors commonly ask for on 9.4.1.2 Annual review of offline backup location security?

Procedure defining the annual security review of each backup storage location; Completed inspection reports or checklists for each location dated within the last 12 months; Findings and remediation records from those reviews; Vendor assurance report or site visit record for commercial storage facilities.

What is the most common gap auditors find on 9.4.1.2?

Only the primary vault reviewed while a secondary storage site is overlooked

PCI DSS v4.0.1 · Req 9: Restrict Physical Access

`9.4.1.2` Annual review of offline backup location security

Each location that stores offline backup media holding cardholder data must have its security reviewed at least every 12 months. Applicability: entities with offline backup storage locations. Objective under the customized approach: the security controls guarding offline backups are periodically confirmed through inspection. The guidance explains that regular reviews let the entity address identified security issues promptly and keep the entity aware of how well its media storage area is protected.

Source: PCI DSS v4.0.1, 9.4.1.2. 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.

artefacts

held by a system

at each review

hard

to go live

Backup / DR tooling

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

Procedure defining the annual security review of each backup storage location · Backup / DR tooling
Findings and remediation records from those reviews · Data governance / DLP tooling
Vendor assurance report or site visit record for commercial storage facilities · Physical access / facilities

governing documentDocuments that govern the control

Completed inspection reports or checklists for each location dated within the last 12 months · Policy repository / GRC workspace

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

Only the primary vault reviewed while a secondary storage site is overlooked
Last review of the off-site facility more than 12 months old
Review consists of accepting a vendor brochure rather than inspecting controls

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

9.4.1.1 Secure storage location for offline backups · 9.4.2 Classification of media by data sensitivity