9.4.1 Physical security of all media
Every item of media that holds cardholder data must be physically secured. The guidance explains that unprotected data on removable or portable media, printouts or material left on a desk can be viewed, copied or scanned by unauthorized people. Applicability: all entities that hold cardholder data on any media. Customized approach objective: people without authorization cannot get at media that contains cardholder data.
Source: PCI DSS v4.0.1, 9.4.1. 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
none for this control
periodic reviewEvidence produced at each review
- Evidence of locked storage such as safes, locked cabinets or secure rooms · Data governance / DLP tooling
- Clean desk policy and spot-check results · Data governance / DLP tooling
governing documentDocuments that govern the control
- Media handling procedure covering paper, removable and portable electronic media with cardholder data · Policy repository / GRC workspace
- Access list for media storage locations · Policy repository / GRC workspace
First move
Common gaps auditors find
- Printed settlement reports left in open trays
- Procedure covers backup tapes but ignores USB drives and paper forms
- Media cabinets unlocked or keys widely held
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 sheet9.3.4 Visitor logs for facility and sensitive areas · 9.4.1.1 Secure storage location for offline backups