What evidence do auditors commonly ask for on 9.4.2 Classification of media by data sensitivity?

Data and media classification standard referencing cardholder data; Media inventory or log showing a classification value for each item; Labelling or marking scheme used for media; Sample media observed with classification apparent.

What is the most common gap auditors find on 9.4.2?

Classification scheme exists but media logs have no classification field

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

`9.4.2` Classification of media by data sensitivity

Every item of media with cardholder data must be classified according to how sensitive the data is. The guidance adds that media should be identified so its classification status is apparent, which does not mean it needs a literal confidential label. Applicability: all entities holding cardholder data on media. Customized approach objective: media are classified and given appropriate protection.

Source: PCI DSS v4.0.1, 9.4.2. 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

moderate

to go live

SIEM / log platform

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

Media inventory or log showing a classification value for each item · SIEM / log platform

periodic reviewEvidence produced at each review

none for this control

governing documentDocuments that govern the control

Data and media classification standard referencing cardholder data · Policy repository / GRC workspace
Labelling or marking scheme used for media · Policy repository / GRC workspace
Sample media observed with classification apparent · Policy repository / GRC workspace

First move

Start with the 1 of 4 artefacts that already live in a system (SIEM / log platform); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

Classification scheme exists but media logs have no classification field
Printed reports with PAN not treated as classified media
Removable media issued with no classification at all

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

9.4.1.2 Annual review of offline backup location security · 9.4.3 Securing media sent outside the facility