Why is Requirement 12 not covered by us, even when our clients are in the 'safe harbor' that we call preFIX? Well, there is good reason.
Requirement 12 is all about people and policies. As a compliant organization, you are expected to have an Incident Response Plan, for example.
Having such a plan allows you to know what to do in the even of a breach, and ensures that the right people in your company are lined up to
take the right steps in the event of foreseeable actions.
What else does Requirement 12 cover? It expects you to train your staff to know how to handle secure data. It expects your senior management
to support the company security initiatives. It makes sure that you are choosing your 'service provider' very carefully. Any third party company that
goes close to your cardholder data (your hosting company and your software developers, for example) should be carefully interviewed to make sure that
their concern about your security is equal to your own concern, and that they are following regulations put in place by the PCI council.
So, here at Vortx we are proud of the way we keep our clients safe, but we can't vouch for other providers, and we can't talk about
YOUR incident response plan.