Information security officers for credit institutions

PCI DSS v4.0 blog entry for October

PCI DSS 4.0 Evidence Guidelines

In this episode of our PCI DSS v4.0 blog, we explain assessors’ respon­si­bil­ities for providing evidence of their assessment findings, and how to prepare the provision of appro­priate evidence for PCI DSS v4.0 assessments.

Assessment process

During a PCI DSS assessment, assessors check the extent to which a company has imple­mented the PCI DSS requirements.

Typically, an assessment process includes the following steps:

  • Review of documents,
  • Review of system components/settings,
  • Review of processes,
  • Review of physical condi­tions, 
  • review of protocols/results, and
  • Inter­views with staff.

This does not change with the migration to PCI DSS v4.0.

Evidence require­ments

It usually remains hidden for the assessed company how an assessor makes notes and files evidence. We provide insight into the corre­sponding changes with PCI DSS v4.0.

With the new reporting template for PCI DSS v4.0 as well as with an update of the PCI DSS Program Guide for QSAs, the PCI SSC has now clarified that they require the assessor to file a corre­sponding evidence for each assessment step. The PCI SSC checks whether the assessor companies meet this by taking samples.

For documents, this is easy: the respective document itself is the required evidence. Regarding protocols/results, it is similar – here you just have to make sure that it is clear which system or process you are talking about.

 If you send a screenshot or file to an assessor as evidence, please make sure to include the infor­mation which system component and/or process it is about. When reviewing system components/settings, the assessor must take dedicated notes on the system and setting in question.

When reviewing processes or physical condi­tions, the respective condition must be described in detail and it must be shown what conclu­sions the assessor draws from the obser­vation. Similarly, in an interview, the assessor is expected to roughly write down the questions and answers.

Please give the assessor enough time to take notes during the assessment. In many cases, it can shorten the paperwork if the assessor is provided with copies or screen­shots or is allowed to take photos.

The PCI DSS v4.0 lists about 250 sub-items for the 12 main require­ments — the assessor will need a corre­spond­ingly large amount of evidence.

Retention require­ments

The PCI DSS Program Guide requires that all of the above evidence must be securely retained by the assessor company for at least three years and made available to the PCI SSC and associated companies upon request.

For reasons of privacy or confi­den­tiality, companies sometimes do not allow the assessor to take and file certain evidence. In this case, the PCI SSC stipu­lates that the evidence may be filed with the assessed company instead. The require­ments for retention period and avail­ability are the same in this case.

Since the oblig­a­tions to provide evidence have become greater with PCI DSS v4.0, this case is expected to occur more frequently in the future.

 If you expect that not all evidence may be passed on to the assessor, the best way to prepare yourself as an assessed company is by

  • preparing an audit-proof storage of the evidence for at least three years,
  • keeping a list of documents and evidence not handed over during the assessment,
  • preparing a written confir­mation for the assessor, in which you 
    • name the place of storage,
    • name the contact person whom the PCI SSC can contact if it wishes to inspect evidence, and
    • confirm audit-proof storage until a specific date at least three years in the future.

Dealing with deviations

How about evidence if the assessment did not immedi­ately demon­strate compliance with all require­ments, but devia­tions were found?

Planned devia­tions

In the simplest case is when you, as the assessed company, have already recog­nised in advance that you cannot fulfil a requirement or do not want to fulfil it in the specified way. In this case, you have already prepared documen­tation of a compen­sating control or a customised approach for the assessment. A PCI DSS expert can also help you with this — but it must not be the same individual who then assesses the implementation.

We will comment in detail on the Customised Approach in a later episode of our PCI DSS v4.0 blog.

In both cases, the assessor will review the evidence of your company’s Compen­sating Control or Customised Approach, ask questions if necessary, and then derive and implement appro­priate testing methods. The oblig­a­tions to collect evidence result from the respective assessment method.

Unplanned devia­tions — “INFI”

If unplanned devia­tions from PCI DSS require­ments occur during an assessment period, they must be remedied and the remedi­ation verified by the assessor. This was already the case in PCI DSS v3.2.1.

Additionally, PCI DSS v4.0 additionally explicitly requires that the cause for the occur­rence of the deviation is identified and that processes are imple­mented to prevent a recur­rence of such a deviation. Only if this is the case, the assessor can still consider the requirement as in place.

All devia­tions, their causes, corrective and preventive controls must be documented in the new “Items Noted For Improvement” (INFI) document for any PCI DSS v4.0 assessment.

The assessor provides the INFI document to the assessed company at the end of the assessment and both parties sign it. The INFI document proves that the assessed company has success­fully managed the devia­tions. The document can be used inter­nally within the assessed company — e.g. in compliance and risk depart­ments — and can also be shared with third parties if desired. There is no oblig­ation to present the INFI document anywhere, nor is it refer­enced in the Attes­tation of Compliance (A.O.C).

 Partic­u­larly for processes that have to be repeated regularly, it happens from time to time that one instance is delayed, e.g. within the imple­men­tation of 

  • security awareness trainings,
  • inspection of payment devices,
  • vulner­a­bility scans, or
  • instal­lation of patches.

It is best to consider in advance how you can design your processes in such a way that you adhere to the prescribed time periods and notice delays immedi­ately.

For further questions feel free to contact Mrs Jana Ehlers.