EvidenceSheet
PCI DSS v4.0.1 · Appendix A3: Designated Entities Supplemental Validation (DESV)

A3.2.5.1 Annual confirmation of data-discovery effectiveness

The entity must confirm its data-discovery methods by: testing their effectiveness; making sure they can find cleartext PAN on every type of system component and every file format in use; and confirming that effectiveness at least every 12 months. Linked to the PCI DSS scoping section. Guidance: one approach is planting test PANs on in-use platforms and formats and checking they are detected. Applies only to designated entities. Customized approach objective: not eligible for the customized approach; only the defined approach can be used.

Source: PCI DSS v4.0.1, A3.2.5.1. 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.

4
artefacts
0
held by a system
1
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

  • Seeded test-PAN results by platform and file format · Document repository

governing documentDocuments that govern the control

  • Data-discovery effectiveness test plan · Policy repository / GRC workspace
  • Inventory of operating systems, platforms and file formats in use · Policy repository / GRC workspace
  • Last annual effectiveness test report and resulting tool tuning · Document repository

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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A3.2.5 Data-discovery methodology for cleartext PAN · A3.2.5.2 Response procedures when cleartext PAN is found outside the CDE