How to Create a PCI DSS Compliant Incident Response Plan

Even organizations with strong security controls can experience a data breach. When payment card data is involved, a security incident can have serious consequences—both for your operations and for your customers.

For organizations that process, store, or transmit payment card data, preparing for these scenarios is an essential part of complying with the Payment Card Industry Data Security Standard (PCI DSS). Specifically, PCI DSS Requirement 12.10 requires organizations to implement an incident response plan and be prepared to respond immediately to a system breach.

What Should Your Incident Response Plan Include?

PCI DSS Requirements 12.10.1, 12.10.5, 12.10.6, and 12.10.7 outline what a PCI-compliant incident response plan must address, including:

1. Roles, responsibilities, and communication strategies: Identify who is responsible for responding to incidents, establish communication protocols, and document procedures for notifying payment brands and acquiring banks.
2. Incident containment and mitigation: Define specific response procedures for different types of security incidents, including the steps needed to contain threats and limit their impact.
3. Business recovery and continuity: Establish procedures for restoring critical business operations following an incident.
4. Data backup processes: Document how data is backed up and how backups will support recovery efforts.
5. Legal and regulatory reporting requirements: Identify applicable legal obligations for reporting payment card data compromises.
6. Critical system coverage and security monitoring: Ensure response procedures address all critical system components and include monitoring and responding to alerts from security tools, such as intrusion detection and prevention systems, network security controls, file change-detection mechanisms, and unauthorized wireless access point detection.
7. Payment brand procedures: Reference or incorporate incident response procedures established by the relevant payment brands.
8. Unexpected account data discovery: Establish procedures for responding when primary account numbers (PANs) are discovered in unexpected locations. This includes determining how to retrieve, securely delete, or appropriately migrate the data; identifying whether sensitive authentication data is also present; investigating how the data ended up there; and addressing any resulting data leaks or process gaps.
9. Ongoing plan improvement: Establish processes for updating incident response procedures based on lessons learned and developments in the industry.

According to guidance from the PCI Security Standards Council (PCI SSC), incident response plans should be thoroughly documented, distributed to the responsible individuals, and understood by everyone involved. Organizations should also test their plans at least annually to confirm that the procedures work as intended.

These requirements provide a foundation for an effective PCI incident response plan, but putting them into practice requires careful planning and coordination. Here’s where to start:

1. Define Roles and Responsibilities

When a security incident occurs, confusion about who should take action can delay containment and increase the potential impact. Your plan should identify who is on the incident response team and clearly define everyone’s responsibilities. 

PCI DSS Requirement 12.10.4 notes that “personnel responsible for responding to suspected and confirmed security incidents” must be “appropriately and periodically trained on their incident response responsibilities.” Depending on your organization, this may include IT and security personnel, network administrators, executive leadership, legal counsel, and individuals responsible for communicating with affected customers. 

“The frequency of periodic training for incident response personnel is defined in the entity’s targeted risk analysis, which is performed according to all elements specified in Requirement 12.3.1,” the standard adds.

In addition, per PCI DSS Requirement 12.10.3, “specific personnel are designated to be available on a 24/7 basis to respond to suspected or confirmed security incidents.” 

You should also establish who has the authority to make critical decisions, such as isolating systems, engaging external investigators, and notifying payment processors or other stakeholders. Having these responsibilities documented in advance helps ensure that everyone understands their role and can act quickly when an incident occurs. 

2. Establish Incident Classification Procedures

Not every security event requires the same response. Your plan should establish a clear system for classifying incidents based on their severity and potential impact, along with predefined thresholds for determining how quickly they must be addressed. 

For each classification, document the steps required to track the incident, investigate its cause, contain the threat, and remediate the underlying issue. The objective is to give your team a clear, actionable process to follow rather than leaving critical decisions to be made under pressure.

3. Make a Plan for Evidence Preservation

When a breach occurs or is suspected, preserving evidence is essential to understanding what happened, determining the scope of the incident, and identifying its root cause. Your plan should outline how your organization will preserve relevant evidence, including security events, web and database logs, firewall records, and other information that may help investigators reconstruct the incident.

“It may be tempting to reboot devices, clear up log files, update security patches, remove suspect software, and generally try to recover as quickly as possible,” the PCI SSC notes. “However, careful preservation of evidence is vital both in isolating the root cause of the breach and in identifying the perpetrators. Because digital evidence is easily contaminated, maintaining a strict chain of custody is crucial to achieving useful investigation results.”

The PCI SSC also recommends establishing procedures for documenting response activities, including the dates and times of actions taken and the individuals involved. 

4. Understand Notification Requirements

A payment card data breach may require communication with several parties, including acquiring banks, payment card brands, customers, and other stakeholders. Your plan should identify which parties may need to be notified, the circumstances that trigger notification, and the applicable contractual or legal requirements. It should also document who is responsible for making those notifications. Maintain accurate contact information for all relevant parties and review it regularly to ensure it remains current.

You should also designate an individual to coordinate communications with affected customers, helping ensure that information about the incident and its potential impact is communicated appropriately and consistently.

5. Account for Third-Party Service Providers

Many organizations rely on third-party service providers (TPSPs) for payment processing, hosting, technical support, and other services that may affect the security of their cardholder data environment (CDE).

Your incident response procedures should account for how you’ll coordinate with these providers during a security incident. Identify key contacts, establish communication protocols, and ensure contracts address incident response responsibilities. Addressing these considerations during vendor onboarding and contract negotiations can help prevent delays when an incident occurs.

6. Prepare for Forensic Investigation

Depending on the circumstances of a suspected payment card data breach, your organization may be required to undergo an independent forensic investigation by a PCI SSC-approved Payment Card Industry Forensic Investigator (PFI).

A PFI specializes in investigating payment card data compromises and can help determine what happened, identify the scope of the incident, and provide recommendations for containment and remediation. Identifying qualified investigators before an incident occurs can help reduce delays when an investigation is needed.

In its guidance, the PCI SSC says, “Since acquirers and the payment brands each have their own rules and thresholds about when a PFI must be engaged, contact the acquirers or payment brands to make this determination.”

Keep in mind that a forensic investigation is not the same as a PCI DSS assessment. Although a PFI may identify compliance deficiencies during an investigation, the investigation does not establish whether an organization is fully compliant with PCI DSS. An organization cannot use the same firm to conduct a PFI investigation if that firm is also providing its Qualified Security Assessor (QSA) services.

7. Test and Maintain Your Plan

PCI DSS Requirement 12.10.2 calls for organizations to review, update, and test their incident response plans at least annually. Tabletop exercises and other simulations can help teams practice responding to realistic scenarios, identify gaps in their procedures, and clarify responsibilities before a real incident occurs.

After each exercise or actual incident, document the lessons learned and update the plan as needed. Changes to your technology environment, third-party relationships, personnel, or notification obligations may also require updates.

Regular training and testing help ensure that your plan remains relevant and that your organization is prepared to respond effectively when it matters most.

The Bottom Line

A PCI DSS incident response plan is more than just a checklist. To be effective, organizations must establish clear response processes, preserve critical evidence, and educate team members about their roles and responsibilities.

Need help developing an incident response plan or preparing for PCI DSS compliance? Contact our expert team today for a free consultation.