DS11.2:

DS 11.2 Storage and Retention Arrangements

Control Objective: Controls provide reasonable assurance that data recorded, processed and reported remain complete, accurate and valid throughout the update and storage process.

Define and implement procedures for data storage and archival, so data remain accessible and usable. The procedures should consider retrieval requirements, cost-effectiveness, continued integrity and security requirements. Establish storage and retention arrangements to satisfy legal, regulatory and business requirements for documents, data, archives, programs, reports and messages (incoming and outgoing) as well as the data (keys, certificates) used for their encryption and authentication.

Rationale — Managing data include the controls and procedures used to support information integrity, including its completeness, accuracy, authorization and validity. Controls are designed to support initiating, recording, processing and reporting financial information. Deficiencies in this area could significantly impact financial reporting. For instance, without appropriate authorization controls over the initiation of transactions, resulting financial information may not be reliable.

Applicability:

Sarbanes-Oxley

HIPAA

GLBA

PCI

FISMA

NIST SP 800-66

Ditscap

Control Exception

User Defined

Risk Association Control Activities:

1. Risk: Lost data could significantly impact financial reporting.

a. SOX.2.7.9 Policies and procedures exist for the distribution and retention of data and reporting output.

2. Risk: Lost data could significantly impact financial reporting.

a. SOX.2.7.10 Management protects sensitive information— logically and physically, in storage and during transmission—against unauthorized access or modification.

3. Risk: Lost data could significantly impact financial reporting.

a. SOX.2.7.11 Retention periods and storage terms are defined for documents, data, programs, reports and messages (incoming and outgoing), as well as the data (keys, certificates) used for their encryption and authentication.

4. Risk: Lost data could significantly impact financial reporting.

a. SOX.2.7.12 Management has implemented a strategy for cyclical backup of data and programs.

5. Risk: Lost data could significantly impact financial reporting.

a. SOX.2.7.13 The restoration of backup media is periodically tested.

6. Risk: Lost data could significantly impact financial reporting.

a. SOX.2.7.14 Changes to data structures are authorized, made in accordance with design specifications and implemented in a timely manner.

• PCI.3.3: Mask account numbers when displayed (the first six and last four digits are the maximum number of digits to be displayed).
  

• PCI.3.4: Render sensitive cardholder data unreadable anywhere it is stored (including data on portable media, backup media, in logs, and data received from or stored by wireless networks) by using any of the following approaches: One-way hashes (hashed indexes), such as SHA-1, Truncation, Index tokens and PADs, with the PADs being securely stored, Strong cryptography, such as Triple-DES 128-bit or Advanced Encryption Standard (AES) 256-bit with associated key management processes and procedures.
  

• PCI-4.1.1 For wireless networks transmitting cardholder data, encrypt the transmissions by using Wi-Fi Protected Access (WPA) technology if WPA capable, or VPN or SSL at 128-bit. Never rely exclusively on WEP to protect confidentiality and access to a wireless LAN. Use one of the above methodologies in conjunction with WEP at 128 bit, and rotate shared WEP keys quarterly and whenever there are personnel changes.
  

Process Narrative
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Process Illustration
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Control Commentary
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Control Exception Commentary
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Evidence Archive Location
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Control Status and Auditors Commentary
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Remediation Plan
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Supplemental Information: