What evidence do auditors commonly ask for on A3.2.5.2 Response procedures when cleartext PAN is found outside the CDE?

Documented cleartext PAN discovery response procedure; Response tickets for recent out-of-CDE PAN findings; Root cause and source analysis records; Secure deletion or migration evidence; Track data co-location check results.

What is the most common gap auditors find on A3.2.5.2?

PAN deleted but root cause never investigated

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

`A3.2.5.2` Response procedures when cleartext PAN is found outside the CDE

Response procedures must be ready to be triggered whenever cleartext PAN turns up outside the CDE and must include: deciding what to do with it, covering retrieving it, deleting it securely and/or moving it into the defined CDE as applicable; working out how the data came to be outside the CDE; fixing the data leaks or process gaps that caused it; identifying the data's source; and determining whether any track data is stored alongside the PANs. Guidance: contributing factors such as business processes, user behaviour or misconfiguration should be addressed to stop recurrence. Applies only to designated entities. Objective under the customized approach: not eligible for the customized approach; only the defined approach can be used.

Source: PCI DSS v4.0.1, A3.2.5.2. 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

hard

to go live

Document repository

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

Response tickets for recent out-of-CDE PAN findings · Ticketing / ITSM

periodic reviewEvidence produced at each review

Root cause and source analysis records · Document repository
Secure deletion or migration evidence · Document repository
Track data co-location check results · Document repository

governing documentDocuments that govern the control

Documented cleartext PAN discovery response procedure · Policy repository / GRC workspace

First move

Mostly documents and reviews. Pull the 1 system-held artefact from your Ticketing / ITSM 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

PAN deleted but root cause never investigated
No check whether track data sits alongside discovered PAN
Same leak location reappears in later scans

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

A3.2.5.1 Annual confirmation of data-discovery effectiveness · A3.2.6 Mechanisms to detect and block cleartext PAN leaving the CDE