A3.2.6.1 Response procedures for attempted removal of cleartext PAN
Response procedures must start when an attempt to move cleartext PAN out of the CDE through an unauthorized channel, method or process is detected, and must include: procedures for responsible personnel to investigate alerts promptly; and procedures to fix data leaks or process gaps where needed so that data is not lost. Related PCI DSS requirement 12. Guidance: such attempts may signal theft or simply staff unaware of correct methods. 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, A3.2.6.1. 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.
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
- Investigation tickets linked to DLP alerts with timestamps · SIEM / log platform
- Metrics on alert triage times · SIEM / log platform
periodic reviewEvidence produced at each review
- Remediation records such as process changes, user retraining or access removal · Document repository
governing documentDocuments that govern the control
- DLP alert response runbook · Policy repository / GRC workspace
First move
Common gaps auditors find
- No defined timeframe for investigating DLP alerts
- Investigations closed with no remediation of the underlying process gap
- Responsible personnel for DLP alerts not named
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 sheetA3.2.6 Mechanisms to detect and block cleartext PAN leaving the CDE · A3.3.1 Prompt detection and alerting of critical security control failures