PCI DSS 9.4.5: Maintain Electronic Media Inventory Logs
Control 9.4.5 requires organizations to keep detailed inventory logs of every electronic device and storage medium that contains cardholder data. Without documented media tracking, you risk losing visibility into sensitive data locations and failing audits. This control is foundational to preventing unauthorized access and supporting incident response.
What this means
You must establish and maintain comprehensive logs documenting all electronic media that stores, processes, or transmits cardholder data. These logs should track device type, location, owner, and status throughout the device lifecycle. The inventory serves as your control point for ensuring data security measures are applied consistently and for identifying potential weak points in your environment.
How to comply
- 1.Create a centralized registry listing all electronic media containing cardholder data, including desktops, laptops, servers, USB drives, and external hard drives
- 2.Document the device type, model, serial number, and physical location for each item in your inventory
- 3.Record the business owner and responsible party for each device
- 4.Update logs whenever new media is added, removed, or transferred between locations
- 5.Conduct quarterly physical audits to verify inventory accuracy and reconcile logs with actual devices
- 6.Mark and label all media included in the inventory for easy identification during audits
- 7.Maintain historical records showing device additions, removals, and location changes
Evidence auditors look for
- Electronic media inventory spreadsheet or database with device details and ownership information
- Quarterly inventory audit reports showing physical verification of devices
- Change logs documenting additions, retirements, or transfers of media containing cardholder data
- Device labeling records and photographs confirming media identification
- Management sign-off on inventory accuracy at regular intervals
- Incident reports cross-referenced with inventory to demonstrate traceability
Frequently asked questions
When will FAQs be available?
The FAQ for this control is currently being prepared.
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