Scott T. Harder
Tech Support & Product Development
ASPG, Inc.
Ph:       239-649-1548 / Ext. 203
Fax:      239-649-6391
General Support Email:  [email protected]

-----Original Message-----
From: IBM Mainframe Discussion List [mailto:[email protected]] On
Behalf Of Russell Witt
Sent: Wednesday, February 11, 2009 4:42 PM
To: [email protected]
Subject: Re: Crypto-DASD?

Scott,

>Okay, if you think data stored on disk is "data at rest"; please define
>"disk". Does a SSD (Solid-State Drive) count as a disk drive? What
about a
>RAM drive (using either SRAM or DRAM)? If a RAM drive using SRAM or
DRAM is
>a disk; then what is the difference between a RAM drive and memory in a
>computer?

I think what the regs mean by "data at rest" is "where the data lives"
or "it's home location".  As you say, the term "disk" is quite
interchangeable these days. 
 
>And of course as Phil said, the decryption should not be done on an
>"automatic" basis; but rather based on rules. And who will control
those
>rules; the external-security system. So, if the external-security
system
>will control who can access the data via automatic decryption; how is
that
>different than having the external-security system control access to
the
>data in the first place.

Agreed.  But is access to encryption keys (whether stored in ICSF
hardware or otherwise) not controlled by the security system (CSFKEYS /
CSFSERV)??  I think you could make this argument about any data you
encrypt on the system.  If you have the key, you can get to the
cleartext and access to the key is controlled by RACF, CA-ACF2, CA-TSS,
etc.

>Just my opinion, but PCI really needs to do a better job of defining
what
>needs to be done.

This is the real rub of it all, isn't it?  Absolutely agreed.

Thanks!
Scott


-----Original Message-----
From: IBM Mainframe Discussion List [mailto:[email protected]]on
Behalf Of Scott T. Harder
Sent: Wednesday, February 11, 2009 11:46 AM
To: [email protected]
Subject: Re: Crypto-DASD?


Now, that's what I'm talkin' about.  Thanks, Timothy, for the info.

FWIW... to me, data stored on disk is data at rest.  It may not be all
the time, but I think that the intent of that phrase, as used in the
regulations, is pretty clear.  Whether they were correct in using it can
be argued, for sure, but....

Thanks to everyone.  

Scott T. Harder

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