If you're struggling to understand encryption key management, trust me, you're not alone. If you are just beginning your research, here is the first step to lead you in the direction of a comprehensive key management plan that meets all data security compliance regulations.
Let’s start with the basics:
1. You must manage your encryption keys separate from your encrypted data.
Storing your encryption keys on the same device as your encrypted data is like taping your house key to the front of your door. It’s just a bad idea! Plain and simple. Whether you’re a DBA, IT Admin, or Auditor, PCI DSS section 3 addresses encryption keys and states that keys should be managed with Dual Control and Separation of Duties. This means the keys must be stored on a separate system designed to manage the keys.
2. Manage your keys using split knowledge, separation of duties, and dual control.
This means using multiple people to manage parts of the keys so that no one person has entire control of the keys. PCI DSS section 3 also speaks directly to this protocol. Without separation of duties and dual control, storing your keys on a separate device isn’t much better than “hiding” your key under the welcome mat.
The other day I spoke with a prospect in the healthcare industry who believed the tools he had in place for key management were sufficient, until he found out they were not. This prospect was using Software as a Service (SaaS) to manage their encryption keys. While using SaaS is a great replacement for some aspects of our work lives, it will not work for key management if you’re managing your keys on same server as you store your encrypted data.
In the healthcare industry, the HIPAA HITECH act states simply, “… covered entities and business associates should keep encryption keys on a separate device from the data that they encrypt or decrypt”.
There are some people out there still storing their keys on their database server, thinking that they are meeting compliance regulations. What they don’t realize is that they are not PCI DSS compliant and will likely fail a security audit if they are audited. My last word is this: When it comes to regulations like PCI, HIPAA/HITECH, or state privacy laws, you must physically separate encryption keys from the data they protect.
If you want to learn more about key management and PCI compliance, listen to Patrick speak about current best practices and encryption key management in the webinar, “Key Management Best Practices: What New PCI Regulations Say.”