In part one of Meeting PCI-DSS Requirements for Encryption Key Management I discussed Separation of Duties and Dual Control, two critical components necessary towards meeting Section 3 of PCI DSS for encryption key management compliance.  Equally important to meeting section 3 are the notions of Split Knowledge, Audit Trail Logging and Strong Key Usage and Protection.

Section 3.6.1 of PCI DSS v2.0 states that your encryption solution must generate strong keys as defined by PCI DSS and PA-DSS using "strong cryptography."  On our Alliance Key Manager (AKM) all data encryption keys, key encryption keys, and authentication keys are generated using a NIST approved and certified cryptographically secure random number generator.  This meets NIST requirements for strong encryption key creation and establishment.  Furthermore in regards to Key Encryption Keys and Authentication Keys that protect your data encryption key database, the former keys are protected by a 2048-bit RSA key.  Since AKM is FIPS 140-2 certified and meets NIST requirements, you're covered on how keys are stored in a protected format, detection of key corruption, and the separation of data encryption keys from your key encryption keys.

Split Knowledge can also play a crucial role in protecting your data encryption keys.  Parts of the security standard state that you shouldn’t export a key in the clear from the AKM database and that the key needs to be protected.  For this to occur, you'd first have to have your Admin latch up to the key server utilizing a secure TLS connection with the proper credentials and authenticate to the server.  Once the connection is established, the admin is free to export or import symmetric keys, however upon export they will be required to protect the symmetric key with a RSA key. No manual establishment of keys in the clear is supported. By default this is out of the box functionality; we ensure this requirement by setting a configuration option for PCI-DSS mode.

Finally, there is the important item of collecting your system logs and transmitting them over your network to a waiting log collection server.  This waiting log server would ideally be running a SIEM product that monitors and analyzes log messages looking for malicious activity or critical errors. Specifically, AKM writes logs to four different log files; audit, error, backup, and trace logging, when enabled.  The key manager comes with Syslog-ng built in and ready to be configured.  You simply select your sources and define your destination of the collection server to begin transmission of your log files.  You can configure your SIEM product to send out alerts when certain events or errors occur that you want to be on the lookout for.

Want to learn more?  You can view a pre-recorded webinar titled "Encryption Key Management Simplified" and learn how encryption key management can be easy, why encryption key management is important, and what the barriers are to good encryption key management.