9.4.5.1 Inventories of electronic media with cardholder data are conducted at least once every 12 months
Inventories of electronic media with cardholder data are conducted at least once every 12 months.
5
artefacts
1
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
system holds itEvidence a system already holds
- Electronic media inventory logs for the period showing the inventory was performed · SIEM / log platform
periodic reviewEvidence produced at each review
- Interview confirmation from personnel who performed the inventory · Data governance / DLP tooling
- Records of discrepancies found and how each was resolved · Data governance / DLP tooling
governing documentDocuments that govern the control
- Documented procedures defining the conduct of electronic media inventories at least once every 12 months · Policy repository / GRC workspace
- Evidence the inventory covers all electronic media with cardholder data, including offsite and archived media · Policy repository / GRC workspace
First move
Mostly documents and reviews. Pull the 1 system-held artefact from your SIEM / log platform on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.
Common gaps auditors find
- Inventory covers onsite media while offsite storage held by a third party is taken on the provider's word
- Inventory recorded as complete with no evidence of physical verification against the log
- Discrepancies noted with no investigation, so missing media is normalised
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 sheet9.4.5 Inventory logs of electronic media · 9.4.6 Hard copy media destruction