Townsend Security Data Privacy Blog

Best Practices for Deploying a Key Manager in AWS

The cloud has transformed the way most industries manage their data. With services that offer cost-effective, scalable, “pay-as-you-go” options, it is increasingly rare to find a company that doesn’t want to migrate business-critical applications from an in-house data center to the cloud. Companies will make different decisions based on industry risk assessment, their own tolerance for risk, and compliance regulations, however, some Enterprises have been holding back on their migration to the cloud until comfortable that they can properly protect their most vital information. Data security was a concern when we had a fully controlled hardware environment, and now that we are moving to shared, multi-tenant virtual environments it has become even more critical.

Data encryption has had a reputation of being the hardest security measure to achieve and yet it is the best way to secure digital information that needs protection. One of the most important elements of encryption is using encryption key management best practices to keep the encryption keys safely stored away from the data they protect. An Enterprise key management solution will also provide dual control, separation of duties, and proper rotation of encryption keys to ensure that you (and only you) control, manage, and have access to your encryption keys and the data they protect.

Any cloud platform brings with it an additional set of security concerns, including the ability to implement and demonstrate regulatory compliance, as applications and services move into the cloud. Whether Enterprises bring their own applications and operating systems into the AWS cloud, or use the variety of options and rich set of services supplied by Amazon, lets take a look at ways data can be encrypted and the use of appropriate technologies to protect those vital encryption keys.

Virtual machine migration:  Probably the most typical cloud deployment involves IaaS (infrastructure as a service) where the operating system, database, and everything is contained with an application. By using industry standard encryption and key management,  vulnerabilities are significantly reduced and organizations are able to enforce compliance requirements.

Data storage options: Whether you are encrypting an entire database, or using column-level encryption for a more granular approach, you have options for database (data-at-rest) encryption.

Amazon Relational Database Service (RDS) While RDS does not support encryption key retrieval and on device encryption services internally, it does to make it easy for applications to encrypt data going into and out of the RDS. You can retrieve encryption keys for application-level encryption or use on-device encryption before writing to, or reading data from, the RDS.

Amazon Simple Storage Service (S3) is very popular for video, audio, and large files now with server-side customer supplied encryption and key management support. Each file can have it’s own encryption key, or you can use the same key to encrypt multiple files. With recent enhancements by Amazon, you can easily “bring your own key” and integrate a key manager to encrypt data being stored in S3 and decrypt data that is retrieved from S3 storage.

Amazon Elastic Block Storage (EBS) is available for any virtual machine running in an Amazon context to retrieve encryption keys and encrypt data in very straightforward application environment.

Choosing an Encryption Key Management Solution

Make sure your key management solution provides a rich set of SDKs and client-side libraries all of which run in cloud platforms and can be used through all of the storage services that Amazon provides. You should be able to choose to host the key manager in the AWS cloud as an Amazon Machine Instance (AMI), or in a hosted cloud HSM (which is gives you a dedicated HSM in a SOC 3 audited data center with a PCI DSS letter of attestation for compliance) or within a physical HSM under your full control within your own data center. Look for a key manager solution that runs exactly the same way in all of these environments, and ensures that you maintain ownership of your encryption keys at all times. So if you deploy in one location and then need to migrate, you can easily store your data in the appropriate locations. Also, using industry standard encryption and certified solutions for key management are critically important for meeting compliance regulations and following security best practices. Using a third party Cloud HSM gives you the assurance that your encryption keys are kept safely apart from your sensitive data. It is very important to make sure no one else has administrative access, because above all, encryption keys are the secret that must be protected within your encryption strategy.

With options for fee-based encryption key management services, as well as bring-your-own-license solutions, Townsend Security's Alliance Key Manager (AKM) for AWS allows Enterprises to properly manage their encryption keys while meeting security requirements in less time and at a lower cost. While it is not possible to perform FIPS 140-2 validation in a cloud service provider context, Alliance Key Manager uses the same FIPS 140-2 compliant key management technology available in Townsend Security's HSM and in use by over 3,000 customers worldwide. Alliance Key Manager for AWS provides full life-cycle management of encryption keys for a wide variety of applications to help organizations meet PCI DSS, HIPAA, and PII compliance at an affordable price.

To learn more about protecting your data in AWS, download this recent podcast by industry expert Patrick Townsend:

With encryption and key management now being offered on a variety of hardware, virtualized, and cloud platforms, is it simply just a matter of preference or is one option better for you than another?  

Companies of all sizes now have options for securely protecting sensitive data using the appropriate security technology for their situation and industry regulations. Being responsible for the safekeeping of sensitive data like credit cards, social security numbers, or e-mail addresses, makes your encryption and key management strategy critically important. Once your sensitive data is encrypted, key managers are the specialized security devices that are designed to safeguard your encryption key (which is the secret that must be protected). Before deciding on how an enterprise should deploy an encryption key manager there are several questions to ask and factors to consider.

What different device options are available to organizations needing an encryption key manager?

Hardware Devices
Today we have many options for key management solutions, including the traditional key management hardware security module (HSM), which is now more cost effective and easy to deploy than it was even five years ago. HSMs are network attached in your data center and accessed when encryption keys are needed. If your company has a physical data center and the infrastructure to support it, an HSM can still be your most secure option.

Cloud-hosted HSM
The cloud-hosted key management HSM functions in much the same way as the traditional security device. However, you do not need to have the infrastructure of a physical data center in order deploy or maintain the cloud-based HSM since it is hosted by the cloud hosting provider.  Be aware of your cloud environment (is it shared or private?), and make sure to choose an option that provides real-time mirroring and redundant backups in geographically diverse locations.

Virtualization Options
Additionally it is now possible to deploy virtualized key management appliances. There is no hardware when you deploy a VMware or Hyper-v or Xen virtualized appliance inside your own virtualization infrastructure. A true cloud-based key management solution like VMware gives you a path to run key management solutions in vCloud either as standard cloud instance or virtual private clouds. Microsoft Azure and Amazon Web Service and other cloud platforms provide a mechanism for deploying virtualized key management appliances too.

What are some factors people need to consider when deciding which key management option is right for their organization?

Risk Tolerance
Risk tolerance is perhaps the main driving force for which of the key management options you might choose. If you're very risk-averse then probably you will want to deploy a hardware security module (HSM) in your own data center.  If you have a moderate level of risk tolerance  you might consider a cloud-based HSM hosted by a cloud vendor with appropriate security technology. A company dealing with small amounts of data might bear some additional risk and use a key management solution to help protect encryption keys in a virtual environment. Cloud or virtual solutions can be much more cost-effective and give enough protection for encryption keys to meet a lower risk tolerance level.

Compliance Regulations
Most compliance regulations give clear guidance on best practices about where encryption key management can and should run. Generally speaking, regulations are based on your industry and what type of sensitive data you store. 

PCI Security Standards Council has issued Cloud Computing Guidelines as well as guidance around virtualization of data protection solutions, so you can be PCI compliant with a cloud-based key management and encryption solution.

Cloud Security Alliance (CSA) has issued good guidance around key management and cloud environments - version 3.

Other regulations are not yet providing concrete guidance,and in some cases it is best to confirm with qualified auditors and assessors to really understand whether or not you can be in compliance and deploy true cloud-based virtualized key management solutions.

Infrastructure
Your key management options are also based on where your data is stored. If you don't have a traditional data center, for example if you are using a software as a service (SaaS) solution, you may not have your own IT infrastructure or personnel with which to deploy a traditional encryption key management HSM internally. So the physical and organizational structure will come to bear in terms of the choices that you have around deploying key management.

Cost
Budget is always an important factor. As you consider various options, ask about endpoint licensing fees and make sure you have predictable maintenance costs as more databases/applications request key access. Remember to consider the costs of not properly managing sensitive data when doing the security cost benefit analysis.

Whatever option you choose, it is always wise to use key management best practices:

• Always separate the encryption keys from the protected data
• Use dual control
• Practice separation of duties
• Manage key rotation
• Look for NIST validations like FIPS 140-2

Please download our most recent podcast on Encryption Key Management Options to hear more about how to meet the challenges of running cloud or virtual applications where implementations are inherently shared, multi-tenant environments!

(That’s the Way) You Need it…

Now that you have the tune from Journey running through your head, let’s talk about how you are going to protect your data with encryption and key management.  

So you have all this sensitive data that you need to secure… how are you going to protect it? What kind of key management choices do you have? How do you decide what encryption to use? Just how do you decide what you need, and where you will put your key management device, and will it be hardware or virtual? In many cases, regulations require you to protect sensitive information. Beyond being a compliance requirement, it is also a responsibility to your business and your customers. We understand all those questions can be a bit daunting at first, but there are a variety of encryption key management options to choose from.

The main consideration that will be determined within each of the following factors is your Risk Tolerance. What kind of sensitive data are you storing? What will happen to that information if there is a data breach? What will the impact be to your company, to your customers, if that information gets accessed by the wrong people? What are your liabilities? No matter whether it lives in a single PC hard drive or a vast data center, or even in a shared cloud environment, the type of information you need to protect will have a large impact on what level of risk tolerance you have.  

Here are four factors you need to consider as you devise or revise your data security plan:

Infrastructure: Where your data lives (client side application) determines what kind of options you have. Is your data all in one location (on a PC, or in a data center)? or is it in the cloud? or a combination? Are there requirements that would limit where your key server could be located? How will data need to be transmitted from one location to another? Once you have a clear picture of the sensitive information you are responsible for then you can move on to the next set of questions.  

Compliance Regulations: If you are dealing with Personal Identifiable Information (PII) or Protected Health Information (PHI) or Payment Card Industry (PCI), you have a great responsibility to protect that information and meet different compliance regulations. Depending on what industry you are in and where you live, different regulations may come into play. If you take credit card payments, you will certainly fall under PCI-DSS and be required to encrypt that data. If you are a part of or even partner with the medical sector then you also need to comply with HIPAA/HITECH Act requirements for security of Protected Health Information (PHI). GLBA/FFIEC sets regulations for banks, credit unions, credit reporting agencies, and anyone in the financial industry. FISMA is for Federal US Government Agencies and businesses that partner with them. The Federal Trade Commission (FTC) also gets involved with anyone who issues a privacy statement. On top of those regulations, more than 45 states also have their own privacy rules that strongly recommend encryption of any personally identifiable information (PII).

Availability:  Beyond just the availability of your encryption key management options, think about how many people need access to your data. What kind of security procedures do you need in order to keep the wrong people out and yet allow the right people to do their jobs? Will you have a key management system that supports separation of duties and dual control of your encryption keys?  

Cost: Your budget will also determine what kind of key management system you use. While cloud options may present a cost savings, you would potentially need a higher risk tolerance in a shared environment.  

Once you have identified your level of risk tolerance and the other factors listed, you will need to consider what kind of encryption and key management options are available to you:

Data Center - Hardware Security Module (HSM) - This is probably the most common option for companies that have their own data centers. The HSM is “under your roof” and you provide the security and IT support for the device.  

Cloud HSM -  If your data lives in the cloud and in a variety of client side applications, perhaps hosting your key server in a cloud HSM makes more sense for you. In a cloud HSM, look for two dedicated redundant HSMs in geographically diverse locations that are managed for you. Options and access will vary depending on which cloud HSM solution you deploy. With Alliance Key Manager Cloud HSM, you maintain exclusive access to your key servers.

In the Cloud -  If your data lives primarily in the cloud, you may want to go with a key server deployed directly in the cloud. Ways to make that option more secure would be to locate your key server in a different cloud environment from your data or even in a virtual private cloud (VPC). Cloud options are certainly cost-effective and easy to deploy, just make sure that you have a high enough risk tolerance for a shared environment!

I know there are a lot of questions that each company needs to consider and answer for themselves during this security planning process. The good news is that we have solutions that can encrypt your data and protect your encryption keys in all of those locations. We offer affordable and easy to deploy solutions with what we feel is the best customer support in the industry.  

Check out this complimentary eBook on Key Management, then give us a call and let’s see how we can partner together to protect your data!
 

After our latest webinar “Encryption & Key Management with Microsoft SQL Server” there were a number of great questions asked by attendees and answered by security expert Patrick Townsend.

Here is an informative recap of that Q&A session:

Q: Are there any special considerations when deploying an encryption key manager in the cloud?

A: The cloud always presents some additional security challenges related to encryption and security in general and has the impression of being less secure and having some new challenges around security. In the cloud, the encryption key manager itself is only one component to consider, and you need a good FIPS 140-2 compliant solution like our Alliance Key Manager for SQL Server. You also need client side applications and libraries, so when you're thinking about moving to the cloud, paying attention to that particular issue is very important. Also know that not all libraries can easily migrate to cloud. We develop ours from the ground up with the cloud in mind, so all of our components that talk back to our key manager for encryption keys or encryption services are cloud-enabled and can be deployed there.

From a compliance point of view, it is very important to take a look at the Cloud Security Alliance (CSA.org) document on cloud security - version 3.

We also provide a compliance brief about domain 11 which talks about encryption key management and issues around the security in the cloud.  

Q: Can you go a little more in-depth about what gets installed on SQL Server?

A: For the SQL Server platform (the client side software) Microsoft allows for Extensible Key Management (EKM) which allows vendors like Townsend Security to plug into their environment. Our Key Connection for SQL Server is an EKM provider and it is a GUI (Graphical User Interface)  install, so you load it on your own SQL Server platform and it walks you through some questions:

• It will ask what SQL Server instances you want to protect
• It will ask for your authentication credentials in order to execute the necessary commands  
• It will allow you to install certificates into the Windows certificate store that are used to communicate with the key manager HSM
• It allows you to define the location of your production and multiple high-availability failover key servers (most companies deploy one production and one HA key server. However, you can actually identify a more complex environment if needed)  
• Then it allows you to actually test, right there in the install dialog, your connection to your key manager to confirm it is working the way it is supposed to

Side Note: We do not charge based on the number of endpoints that talk to our Alliance Key Manager. This is something that is unique to us as a vendor. We believe the encryption should be easy to do and affordable, so no additional license fees are required to actually use it. We want our customers to deploy encryption and use it to protect data.

Q: What are the minimum requirements for the key server?  

A: The Alliance Key Manager product is available as either a hardware security module (HSM) device or virtual appliance. As an HSM it has a 1U server footprint, so it looks like any normal 1U server in your data center. However if you use our Alliance Key Manager Cloud HSM implementation, the encryption key manager is installed for you in a secure data center. It is also our philosophy that these are customer install processes, so we don't have consulting fees because it is a user deployed device. The server administration is done through a secure web browser session with our Townsend Security technical experts. The encryption key management security functions are done through a specific Windows application that talks to one or more key servers to actually create and deploy encryption keys whether they’re for Oracle or SQL Server EKM.  

Also, we do provide our encryption key manager as a VMware virtual appliance, which allows you to deploy a key manager within your VMware infrastructure and we give you guidance on that process. With this option you don't have to purchase a hardware appliance, you can run it in your VM infrastructure or within a vCloud architecture. We strongly recommend that a review of the PCI Security Council's - Cloud Computing Guidelines as well as their guidance around virtualization when deploying a virtual encryption key manager.

Q:  Does your key manager handle encryption and decryption or just key management?

A: Our encryption key management appliance itself does support on-board encryption and decryption.

Q: Can the same EKM module be used to encrypt servers in both data centers and cloud environments?

A: Yes. You can mix and match these anyway you want. You can use the same encryption key management solution for applications running in either environment, and they can talk to each other. You should be aware of a good security practice guidance around using different encryption keys for different kinds of applications, or different user communities, even in a high-availability data center or disaster recovery centers.  

Q: What are the performance impacts on encryption?

A: Encryption always has performance impacts. Generally it can impose a penalty somewhere between 2% and 4% in terms of computing resources. Guidance from Microsoft regarding very large SQL Server databases show that performance can become an issue with certain operations. For example, encrypted indexes may require the entire index to be decrypted in order to be processed. Very large SQL Server databases can impose a bigger performance penalty than 4%. Sometimes, cell level encryption has been a better performing implementation than transparent data encryption. We support both TDE and cell level encryption, allowing our customers to use our product as needed.

We strongly recommend to our customers, especially those with larger more complex SQL Server applications, that they contact us and ask for a complimentary evaluation of our encryption key manager. The complimentary product trial is fully functional and allows an opportunity to do analysis of the performance impacts. We want you to give it a try and make sure you understand the impacts personally.

Q: Is there any limit to the number of servers that you can hook up to the key manager?

A: No. There's no license limit. If you're considering putting up multiple servers we recommend you engage our pre-sales support team and get some guidance on your project. You will never come to us for additional licensing fees around adding a new platform, new SQL Server, or any other application that talks to the encryption key management server. We are unique in the industry that way and is part of our philosophy; we believe encryption needs to go everywhere, data needs protection wherever it lives, and we should lower the barriers -not raise them- when it comes to getting data protection in place. You can connect as many client-side applications to the key server as you wish.

Q: How do you keep system administrators from getting at the data and the keys at the same time.

A: Tasks such as the management of the server, putting it on the network, establishing system logging options, setting the timeservers - all network administration processes - are segmented from the actual management of the encryption keys. Good security practice says that those should be different people engaging in those activities. We provide completely different interfaces to simplify separation of duties.

If you are using our Cloud HSM environment, it is not administered, managed, or accessed by the cloud provider nor by Townsend Security. You have exclusive access and control over your encryption key managers. We even provide a path if you wish to take the encryption key manager out of the cloud environment and install it in your own data center. We believe strongly that a security device should be exclusively under your control, not under the control or management of the cloud provider.

I encourage you to download the recording of the entire webinar and Q&A session:

What to look for in a Cloud HSM solution

With the latest advances in encryption technology, organizations are now able to protect sensitive data with encryption key management in the cloud. The lower costs for maintenance and software (on the operational side) makes the cloud an attractive place for companies to move their data centers and for technology companies to deploy their applications. However, these multi-tenant cloud environments provide some real challenges in terms of protecting data from exposure and meeting special requirements in terms of security. In traditional IT data center environments you would normally place a hardware security module (HSM) key management device directly into your rack. However, traditional encryption key management systems don’t function well in cloud environments, and often companies moving to the cloud don’t have a traditional IT infrastructure. This creates new issues and challenges for administrators to provide the level of security for encryption keys needed to protect data and meet compliance regulations. When considering the move of your data to the cloud, think about whether or not you will have:

Access:

When it comes to encryption key management, only you should have access to encryption keys that protect your data. When you consider a Cloud HSM, be sure to ask if the cloud provider will have access to the HSM and your keys. The answer may surprise you! Because the encryption keys are the “secret” that protects your sensitive information, no one else should have access to your data encryption keys or to the systems that protect those keys. This is the same rule that applies in a traditional IT infrastructure and needs to be followed when you deploy data protection in a cloud environment. Not only is it a compliance requirement to protect encryption keys, but using a secure HSM is a security best practice.

Control:

HSMs are a vital part of any data protection strategy. Encryption key managers that serve for protecting data in the cloud need to be fully under your control. To make sure that you have proper controls, your key management solution should be:

• Segmented from your cloud data
• Independent of your cloud vendor
• Able to meet the highest level of security requirements
• Designed to follow encryption key management system best practices

Mobility:

With an encryption key management and HSM solution that's protecting data in the cloud it matters where your key managers are located. If you're deploying a solution that is proprietary to your cloud vendor, your keys are locked into that cloud vendor and if you move your data, you can’t access or move your encryption keys. You also want to make sure your cloud vendor has no administrative access to that key manager. Fundamental things to think about when you deploy a key management solution:

• Are you a locked into that cloud platform?
• Do you have full and exclusive control of your keys?

Compliance regulations are very explicit about protecting sensitive data with proper encryption key management, and recommend good key management practices as a core principle. When you move to the cloud, you don’t automatically have that level of security for your data.  To meet PCI-DSS requirements for protecting credit card information you should really look at the PCI-Data Security Council - Cloud Computing Guidelines as well as their guidance around virtualization since cloud environments are virtualized environments.

Excerpt from PCI-DSS Cloud Computing Guidelines - Executive Summary:

“Cloud computing is a form of distributed computing that is yet to be standardized. There are a number of factors to be considered when migrating to cloud services, and organizations need to clearly understand their needs before they can determine if and how they will be met by a particular solution or provider. As cloud computing is still an evolving technology, evaluations of risks and benefits may change as the technology becomes more established and its implications become better understood.
...
It’s important to note that all cloud services are not created equal. Clear policies and procedures should be agreed between client and cloud provider for all security requirements, and responsibilities for operation, management and reporting should be clearly defined and understood for each requirement.”

It is also important to look at the Cloud Security Alliance recommendations for cloud security - version 3. Whether you are a cloud vendor or a cloud user, the CSA provides very practical and straightforward guidance on security in the cloud environment. In order to properly secure and protect vital information, you need to understand the security posture of your cloud provider. Don't be satisfied with general statements about security, look for external audits and regular expressions of compliance reviews so you know for sure that you're truly covered. Be sure your encryption keys are in geographically dispersed data centers under an ITIL-based control environment independently validated for compliance against PCI DSS and SOC frameworks to properly manage risk.

Please download our latest Podcast “Encryption Key Management in the Cloud” which covers these topics in greater depth and also talks about how organizations deal with High Accessibility (HA) and Disaster Recovery when their HSM is in the cloud. The podcast will also cover our new Alliance Key Manager Cloud HSM solution that lets you protect data in Amazon Web Services, in Microsoft Azure, Rack-Space, or any cloud environment where you deploy data.

Have questions or concerns about data security in the cloud?  Please leave a comment here and we will get right back to you!