Dave,

You win my weekly erudition award :)

-Mark

Mark A. Kruger, MCSE, CFG
(402) 408-3733 ext 105
www.cfwebtools.com
www.coldfusionmuse.com
www.necfug.com


-----Original Message-----
From: Dave Watts [mailto:[email protected]] 
Sent: Thursday, February 18, 2010 6:41 PM
To: cf-talk
Subject: Re: Where to encrypt - cf or db or both?


> Yes Maureen - I know this. What "we" are asking is - What if the customer
> DOESN'T WANT TO USE THOSE - What if they want you to store the credit card
> anyway... regardless of compliance. (Compliance isn't law...)  What if
that
> is your option?
>
> What then? How "should you do it"?

Sometimes the best answer to "how should you do it" is "you shouldn't
do it". So you should expect to get that a lot, when asking a question
like this. Is your customer going to hold you blameless when bad
things happen? Or are they going to try to share the legal
responsibility with you?

>From the perspective of you, the consultant, the answers to these
questions are much more important than the technical details of
encryption algorithms, which really don't matter all that much. That
is, if you choose an acceptable implementation of an industry-standard
encryption algorithm, you've met your due diligence requirements and
you can be very confident that no one is going to access that data by
breaking the encryption. But if you get sued out of existence by your
client for not preventing the client from doing what you recommended
they didn't do - and if you think this doesn't happen I can confirm
otherwise - well, you're done.

> Matt's original question wasn't what are other methods - but what is the
> best choice for encrypting the data. (And what is required for
compliance.)
> And I would like to know as well... (Minus the compliance part... That
data
> is here: https://www.pcisecuritystandards.org And here:
> http://www.innovativemerchant.com/pdf/pci_dss_summary.pdf  )

Again, though, the specific encryption mechanisms don't matter that
much. From a technical perspective, what really matters is (a) did you
use an acceptable implementation of an industry-standard algorithm,
and (b) did you manage key access responsibly? The strength of the
encryption doesn't matter if your specific implementation has, say, a
predictable key-generation pattern, or if the keys could be snarfed
from your server by some other exploit.

> To me, recommending a service is like answering the question "How do you
> hammer a nail?" with the answer being "Hire a contractor."

That illustrates the problem with analogies. They lose their
descriptive power very quickly. The cost of hammering a nail poorly is
very small. You're not likely to get sued for hammering a nail poorly.
A better analogy, in my opinion, would be answering the question "how
do you win a court case" with "hire a lawyer". You may be the smartest
guy around, but that doesn't give you any special preparation for
representing yourself in court, and you're then responsible for your
own mistakes when you're not prepared to be.

Dave Watts, CTO, Fig Leaf Software
http://www.figleaf.com/
http://training.figleaf.com/

Fig Leaf Software is a Veteran-Owned Small Business (VOSB) on
GSA Schedule, and provides the highest caliber vendor-authorized
instruction at our training centers, online, or onsit



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