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(12.5) Chief Security Officer (or equivalent) is responsible for overseeing all aspects of information security, including but not limited to:

• (12.5.1) creating and distributing security policies and procedures
• (12.5.2) monitoring and analyzing security alerts and distributing information to appropriate information security and business unit management personnel
• (12.5.3) (12.9) creating and distributing security incident response and escalation procedures that include:
• (12.9.1) roles, responsibilities, and communication
• (12.9.1) coverage and responses for all critical system components
• (12.9.1) notification, at a minimum, of credit card associations and acquirers
• (12.9.1) strategy for business continuity post compromise
• (12.9.1) reference or inclusion of incident response procedures from card associations
• (12.9.1) analysis of legal requirements for reporting compromises (for example, per California bill 1386)
• (12.9.2) annual testing
• (12.9.3, 12.9.5) designation of personnel to monitor for intrusion detection, intrusion prevention, and file integrity monitoring alerts on a 24/7 basis
• (12.9.4) plans for periodic training
• (12.9.6) a process for evolving the incident response plan according to lessons learned and in response to industry developments
• (12.6; 12.6.1.a) maintaining a formal security awareness program for all employees that provides multiple methods of communicating awareness and educating employees (for example, posters, letters, meetings)
• (10.6.a) review security logs at least daily and follow-up on exceptions

(12.2.a) The Information Technology Office (or equivalent) shall maintain daily administrative and technical operational security procedures that are consistent with the PCI-DSS (for example, user account maintenance procedures, and log review procedures).

System and Application Administrators shall:

• (12.5.2) monitor and analyze security alerts and information and distribute to appropriate personnel
• (12.5.4) administer user accounts and manage authentication
• (12.5.5) monitor and control all access to data
• (12.8.1) maintain a list of service providers
• (12.8.3) ensure there is a process for engaging service providers including proper due diligence prior to engagment
• (12.8.4, 12.4) maintain a program to verify service providers’ PCI-DSS compliant status, with supporting documentation
• (10.7.a ) retain audit logs for at least one year

The Human Resources Office (or equivalent) is responsible for tracking employee participation in the security awareness program, including:

• (12.6.1.b) facilitating participation upon hire and at least annually
• (12.6.2) ensuring that employees acknowledge in writing at least annually that they have read and understand the company’s information security policy
• (12.7) screen potential employees prior to hire to minimize the risk of attacks from internal sources

Internal Audit (or equivalent) is responsible for executing an annual (12.1.2) risk assessment process that identifies threats, vulnerabilities, and results in a formal risk assessment.

General Counsel (or equivalent) will ensure that for service providers with whom cardholder information is shared:

• (12.8.1, 12.4) written contracts require adherence to PCI-DSS by the service provider
• (12.8.2, 12.4) written contracts include acknowledgement or responsibility for the security of cardholder data by the service provider

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(7.1) Procedures for data control must be maintained by each department and must incorporate the following:

• Access rights to privileged User IDs are restricted to least privileges necessary to perform job responsibilities
• Assignment of privileges is based on individual personnel’s job classification and function
• Requirement for an authorization form signed by management that specifies required privileges
• Implementation of an automated access control system

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(9.7) Distribution, maintenance, and storage of media containing cardholder data, must be controlled, including that distributed to individuals. (9.9) Procedures must include periodic media inventories in order to validate the effectiveness of these controls.

(3.1) Procedures for data retention and disposal must be maintained by each department and must include the following:

• legal, regulatory, and business requirements for data retention, including specific requirements for retention of cardholder data
• provisions for disposal of data when no longer needed for legal, regulatory, or business reasons, including disposal of cardholder data
• coverage for all storage of cardholder data, including database servers, mainframes, transfer directories, and bulk data copy directories used to transfer data between servers, and directories used to
• a programmatic (automatic) process to remove, at least on a quarterly basis, stored cardholder data that exceeds business retention requirements, or, alternatively, an audit process, conducted at least on a quarterly basis, to verify that stored cardholder data does not exceed business retention requirements
• (9.10) destruction of media when it is no longer needed for business or legal reasons as follows:
• cross-cut shred,  incinerate, or pulp hardcopy materials
• purge, degauss, shred, or otherwise destroy electronic media such that data cannot be reconstructed

[If records management is a centralized function, you may choose to offload the above section to a data retention standard and/or procedure, and then reference that procedure in the policy.]

(3.3) Credit card numbers must be masked when displaying cardholder data.  Those with a need to see full credit card numbers must request an exception to this policy using the exception process.

(4.2.b) Unencrypted Primary Account Numbers may not be sent via email

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(2.2.a) Configuration standards must be maintained for applications, network components, critical servers, and wireless access points. These standards must be consistent with industry-accepted hardening standards as defined, for example, by SysAdmin Assessment Network Security Network (SANS), National Institute of Standards Technology (NIST), and Center for Internet Security (CIS). [2.2.b should be captured in your system configuration standard; 2.2.c and 2.2.3.b should be covered in your procedure for new server set-up]

Configuration standards must include:

• (5.2) updating of anti-virus software and definitions
• (6.1.b) provision for installation of all relevant new security patches within one month
• (8.5.8.b) prohibition of group and shared passwords