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Understand the nuances of PCI DSS v4.0 Requirement 12.3 with this insightful guide. Learn about the documentation and evidence your assessing QSA will request during your annual assessment and gain invaluable insights into how you can navigate this process with ease.

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Navigating your annual Payment Card Industry Data Security Standard (PCI DSS) assessment is no easy feat. With the new PCI DSS v4.0, Requirement 12.3 comes into play with its rigorous demands on businesses like yours. This requirement revolves around risk analysis and risk reduction in connection with security policies and operational procedures. If you are feeling overwhelmed or unsure about how to prepare, this guide is for you.

A Deeper Look at Requirement 12.3

To effectively address Requirement 12.3, it’s crucial to understand what it entails. This requirement covers four major aspects:

  1. Risk analysis for each PCI DSS requirement (12.3.1)
  2. Customized Approach for risk analysis (12.3.2)
  3. Cryptographic cipher suites and protocols (12.3.3)
  4. Hardware and software technologies in use (12.3.4)

Your organization is expected to conduct regular risk analyses and keep up-to-date inventories of technologies and cryptographic cipher suites and protocols used. These processes must be documented, reviewed annually, and presented as evidence during your annual assessment.

Documents & Evidence: The Essential Checklist

Your Qualified Security Assessor (QSA) will request several pieces of evidence during the annual assessment. Here’s what you should prepare:

For Requirement 12.3.1:

  • A documented risk analysis for each PCI DSS requirement where the standard does not define a minimum frequency for recurring activities but instead allows for the requirement to be met “periodically”
  • Evidence of the annual review of the risk analysis
  • Evidence of updated risk analyses, as determined by the annual review

For Requirement 12.3.2:

  • Documented evidence detailing each element specified in Appendix D: Customized Approach, including a controls matrix and risk analysis
  • Evidence of senior management’s approval of the documented evidence
  • Evidence of the annual performance of the targeted analysis of risk

For Requirement 12.3.3:

  • An up-to-date inventory of all cryptographic cipher suites and protocols in use
  • Evidence of active monitoring of industry trends regarding the continued viability of all cryptographic cipher suites and protocols in use
  • A documented strategy to respond to anticipated changes in cryptographic vulnerabilities

For Requirement 12.3.4:

  • Documentation of a review and analysis of the technologies (hardware and software) in use
  • Documentation of any industry announcements or trends related to a technology
  • Documentation of a plan, approved by senior management, to remediate outdated technologies

Embrace the Process

Remember, PCI DSS v4.0 is all about flexibility, customization, and risk-based approaches to securing cardholder data. Stay organized, prepare the necessary documentation and evidence, and engage in a regular review process. By doing so, your annual PCI DSS assessment will not just be a regulatory chore but an opportunity to better understand and mitigate the risks facing your organization.

TLDR: Preparing for the PCI DSS v4.0 Requirement 12.3 assessment involves regular risk analyses, maintaining updated inventories of cryptographic cipher suites and technologies, and having a well-documented strategy for addressing changes. This guide provides an overview of the documents and evidence you’ll need for a smooth assessment process.

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