PCI DSS Security Maturity Model·AWS v1.1.0

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Quick Wins Security GovernanceSecurity domain from the AWS Cloud Adoption Framework (CAF) Security Perspective, used to organize the controls. 👤 CustomerAWS Shared Responsibility Model: who implements and operates this control. Customer = you own it; AWS = AWS operates it and you inherit it; Shared = both have obligations.

c12.2 Establish security and acceptable use policies

Establish, publish, and maintain a comprehensive information security policy and acceptable use policies for technologies, reviewed at least annually.

Quick Wins
Foundational
Efficient
Optimized
Effort: Low Impact: Medium Applies to CDE: No

Requirement 12

Support Information Security with Organizational Policies and Programs

PCI sub-requirements coveredCoverage shown per PCI DSS v4.0.1 sub-control. “Covered” = addressed by this AWS recommendation. “Roadmap” = technical, planned. “Your responsibility” = organizational/process control. “Out of scope” = physical or third-party control not implemented in AWS.

12.1 A comprehensive information security policy is established, published, maintained, and disseminated
  • 12.1.1 Information security policy established, published, maintained Your responsibility
  • 12.1.2 Information security policy reviewed at least annually Your responsibility
  • 12.1.3 Security policy defines roles and responsibilities Your responsibility
  • 12.1.4 Responsibility for information security formally assigned to a CISO Your responsibility
12.2 Acceptable use policies for end-user technologies are defined and implemented
  • 12.2.1 Acceptable use policies for end-user technologies defined Your responsibility

How to implement on AWS

Document the security and acceptable use policies and publish them to personnel. Codify the technical controls that back the policy as guardrails (SCPs, Config rules) so the policy intent is technically enforced. Review and update the policies at least every 12 months.

Practical implementation

How this control is implemented in each reference architecture:

Write and publish the security and acceptable-use policies, and make their intent technically enforceable rather than aspirational.

  1. Document the information security policy and acceptable-use policies and publish them to personnel.
    Governance documentation
  2. Back the policy with technical guardrails (Config rules, IAM policies) so the intent is enforced, not just written.
    Account-wide AWS Config IAM
  3. Review and update the policies at least every 12 months.
    Governance documentation

How to validate: The policies exist, are published, reviewed within 12 months, and are reflected in enforcing Config/IAM controls.

Avoid: A policy PDF with no technical backing. Encode the intent as guardrails so it is actually enforced.

Single-account, 3-tier →

Codify policy intent as organization-wide guardrails so the written policy is technically enforceable in every account.

  1. Publish the org-level security and acceptable-use policies once for all personnel.
    Org governance documentation
  2. Enforce the policy with SCPs on the PCI OU plus Config conformance packs org-wide.
    PCI OU (guardrail) AWS Organizations AWS Config
  3. Review and update policies and guardrails at least annually.
    Org governance

How to validate: SCPs and conformance packs implement the written policy across all accounts, and the policy review is current.

Avoid: Policies that each account interprets differently. Encode them as org-wide SCPs/conformance packs for uniform enforcement.

Multi-account with a dedicated PCI OU →

PCI validation

Testing methods: examineinterview

Testing procedures

  • Examine the information security policy and interview personnel to verify it is established, published, maintained, and reviewed at least every 12 months (12.1.1, 12.1.2).
  • Examine the acceptable use policies for end-user technologies and interview personnel to verify they are documented and implemented per the requirement (12.2.1).

Evidence in AWS

  • Security and acceptable use policy documents with annual review history.
  • Technical guardrails (SCPs/Config rules) that reflect the policy.
  • Evidence of communicating the policies to personnel.

Customized approach

Requires a targeted risk analysis (Req 12.3.2).

Customized Approach Objective

  • 12.1 — The strategic objectives and principles of information security are defined, adopted, and known to all personnel.
  • 12.2 — The use of end-user technologies is defined and managed to ensure authorized usage.

AWS services

AWS Organizations AWS Config

Learning resources

References

  • PCI DSS v4.0.1 Requirements 12.1, 12.2