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Townsend Security Data Privacy Blog

PCI Level 2 Merchants: Encryption Key Management Realization

Posted by Kristie Edwards on Sep 13, 2011 12:26:00 PM

pci logoLately we are seeing an increase in questions around PCI requirements for encryption key management.  We are hearing from Level 2 merchants who are preparing for the June 30, 2012 deadline for companies that accept Mastercard. These companies are beginning to realize that they can’t just encrypt data to meet PCI requirements, they also need to securely manage their encryption keys.

To summarize the deadline, which is effective June 30, 2012, MasterCard Level 2 merchants have 2 choices for complying with PCI-DSS requirements.   

Option 1: They can complete an annual self-assessment questionnaire AND prove that a member of their organization has attended and successfully passed PCI SSC-offered merchant training program. 

Option 2: Businesses can elect to complete an annual onsite assessment conducted by a PCI SSC approved QSA.


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Whether a business elects to certify a member of their team or undergo a PCI audit by a QSA auditor, they are becoming better educated about PCI-DSS requirements. Additionally, they are asking questions internally about how to meet requirements and seeking out answers to questions they can’t answer themselves. These Level 2 merchants are now starting to understand the NEED to be PCI complaint and realize how much they need to do. Townsend Security can help answer questions businesses have about data privacy and security because we focus on encryption and key management, which are discussed in section 3 and 3.5 of the PCI-DSS.

I talk to merchants on a daily basis around this topic and people understand the importance of encrypting data, but many don’t understand the need to securely manage their encryption keys. Storing your encryption keys on the same server as your data is problematic.  Before these new regulations Level 2 merchants weren't aware that PCI DSS requires separation of duties and dual control.  Quite simply, you don’t want the same person who has access to the encrypted data to have access to the encryption keys. Think of your encryption key as the figurative “key to the kingdom” - it unlocks the data that you have secured with encryption.  You wouldn’t lock your front door and leave a note saying the key is under the mat. You take your keys with you and only give keys to trusted people – the same philosophy should apply to the way you secure your encryption keys.

Level 2 merchants are realizing they need a secure server to protect their keys. They are researching encryption key management solutions and discovering our FIPS 140-2 certified Alliance Key Manager may be the solution they need.  

If your company is struggling with understanding PCI requirements for key management, download this whitepaper to learn more.  If you need a solution for key management and want to talk to a security advisor about the specifics in your IT environment, send us an email.  We are happy to answer your questions and schedule a 15 minute technical overview. 

I'll also be at the PCI Conference next week in Scottsdale, AZ so make sure to stop by our booth and say "hi".


Topics: Encryption Key Management, PCI

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