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

9.4.4 Management approval for media leaving facility

Management must approve every movement of media with cardholder data outside the facility, including media handed out to individuals. The guidance explains that without firm approval before media leaves secure areas, it may not be tracked or protected and its whereabouts may be lost. Applicability: the approver should hold sufficient management authority to grant the approval, but their job title does not have to include the word manager. Objective under the customized approach: media stays inside a facility unless accountable personnel approve its removal.

Source: PCI DSS v4.0.1, 9.4.4. 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.

4
artefacts
0
held by a system
2
at each review
hard
to go live
Policy repository / GRC workspace
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

  • Signed or system-recorded approvals matched to entries in the off-site tracking log · SIEM / log platform
  • Records of media distributed to individuals with approval evidence · Data governance / DLP tooling

governing documentDocuments that govern the control

  • Procedure requiring management approval before media leaves the facility · Policy repository / GRC workspace
  • List of individuals authorized to approve media movements · 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

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.

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9.4.3 Securing media sent outside the facility · 9.4.5 Inventory logs of electronic media