PCI DSS Incident Response Plan Template

Standard Operating Procedure: PCI DSS Incident Response Plan (IRP)

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1. Executive Summary & Purpose

This procedure defines the institutional framework for detecting, containing, and remediating security incidents impacting the Cardholder Data Environment (CDE). The purpose is to ensure compliance with PCI DSS v4.0 Requirement 12.10, minimize data exfiltration, and maintain operational integrity.

2. Scope & Prerequisites

• Scope: All systems, networks, and personnel interacting with Primary Account Numbers (PAN) or Cardholder Data (CHD).
• Required Tools: SIEM (Security Information and Event Management), EDR (Endpoint Detection and Response), out-of-band communication channel (e.g., Signal/Encrypted Slack), forensic imaging software.
• Prerequisites: All IR team members must have completed annual Security Awareness Training and be provisioned with emergency administrative access.

3. Roles & Responsibilities (RACI Matrix)

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4. Step-by-Step Procedure

Phase I: Detection & Analysis

• Verify validity of alert via SIEM correlation logs.
• Determine the scope of the potential breach (number of compromised systems).
• Initiate the Incident Response log (start chronological timeline).

Phase II: Containment

• Isolate compromised segments from the network via VLAN segmentation.
• Revoke compromised credentials/API keys immediately.
• Prevent data exfiltration by blocking egress traffic to suspicious IPs.
• Capture volatile memory (RAM) and disk images for forensic analysis.

Phase III: Eradication

• Identify root cause (e.g., unpatched vulnerability, compromised credential).
• Rebuild systems from hardened, known-good images.
• Scan the CDE for secondary persistence mechanisms (e.g., web shells, backdoors).

Phase IV: Recovery

• Restore operations from clean backups.
• Perform vulnerability assessment scan on restored systems before reconnecting to the production network.
• Monitor logs intensely for 72 hours post-restoration.

Phase V: Post-Incident Activity

• Conduct "Lessons Learned" meeting within 5 business days.
• Finalize the Incident Report for PCI QSA (Qualified Security Assessor) review.
• Update IR Plan based on identified control gaps.

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5. Quality Assurance & Pro-Tips

• The "Golden Rule": Never perform forensics on a live production machine if it risks altering evidence. Always snapshot/image first.
• Common Pitfall: Failing to notify the acquiring bank or card brands within the required window (usually 24-72 hours). Ensure Legal is involved immediately.
• Metric Thresholds: Mean Time to Detect (MTTD) should be < 1 hour; Mean Time to Contain (MTTC) should be < 4 hours.

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6. Frequently Asked Questions

Q: At what point do I notify the acquiring bank? A: Immediately upon confirmation of an incident involving actual or suspected loss of cardholder data. Do not wait for a full investigation to be completed.

Q: How do we handle evidence collection for PCI compliance? A: All forensic evidence must follow a strict Chain of Custody protocol, documented with hashing (SHA-256) to ensure integrity for potential legal proceedings and QSA audits.

Q: Does this plan apply to encrypted data? A: Yes. PCI DSS scope applies to all environments where CHD is stored, processed, or transmitted, regardless of encryption status, if the keys are accessible within that environment.

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Authorized by: Julian Vance, Chief Architect, Template Registry.