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PCI DSS 11.1.2: Assigning Security Testing Roles and Responsibilities

Security testing effectiveness depends on clear role assignment and documented responsibilities. PCI DSS 11.1.2 requires organizations to define, assign, and communicate who owns vulnerability scanning, penetration testing, and remediation activities. Without explicit ownership, critical security gaps slip through and compliance audits reveal control failures.

What this means

Requirement 11.1.2 mandates that your organization document and assign specific roles and responsibilities for all security testing activities under Requirement 11. This includes defining who conducts vulnerability assessments, who performs penetration testing, who reviews results, and who manages remediation. Everyone involved must understand their duties. This prevents gaps in coverage, ensures testing happens consistently, and establishes accountability when issues arise.

How to comply

  1. 1.Document all security testing activities required by PCI DSS Requirement 11 (vulnerability scanning, penetration testing, etc.)
  2. 2.Assign specific individuals or teams to each role: scanner operator, penetration tester, results reviewer, remediation owner, and management oversight
  3. 3.Define the scope, frequency, and success criteria for each role's responsibilities
  4. 4.Ensure roles are communicated in writing to all stakeholders and testing personnel
  5. 5.Verify that assigned personnel have appropriate training, qualifications, and access to perform their duties
  6. 6.Review and update role assignments annually or when staff changes occur

Evidence auditors look for

  • Security testing responsibility matrix documenting roles, names, and duties
  • Job descriptions or role definitions for vulnerability scanners and penetration testers
  • Testing procedures or SOPs signed by responsible parties
  • Evidence of role communication (email confirmations, training records, acknowledgments)
  • Organizational charts or responsibility assignments linking personnel to testing activities
  • Change logs showing role updates when staff transitions occur

Frequently asked questions

When will FAQs be available?

The FAQ for this control is currently being prepared.

GRCWatch's role management module automates security testing responsibility assignment, maintains audit-ready documentation of who owns each activity, and triggers reminders when responsibilities need annual review.

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Related controls

PCI DSS 11.1.1 — Requirement 11 Roles and Responsibilities OverviewPCI DSS 11.2.2 — Quarterly Vulnerability ScanningPCI DSS 11.3 — Penetration Testing RequirementsPCI DSS 6.2 — Security Development Lifecycle