I think it's important to point out that ANSI X9.24 applies to financial (PIN) 
transactions/data.  And there are federal regulations, at least in the U.S. 
that mandate meeting this requirement of providing tamper resistant/tamper 
responding technology as specified in a number of standards.  The card 
associations and networks also mandate the use of tamper resistant technology.

Other standards do not mandate this technology, however, it is understood in 
cryptography that the key material is secure:  The good guys have access to the 
appropriate keys and the bad guys do not.

With PIN operations, the amount of data being protected is relatively small and 
the performance impact of secure key is acceptable.  However, the performance 
impact may not be acceptable for other applications or processes (for example, 
if you are encrypting a large (multi-megabyte or gigabyte file).  And if  you 
plan on sharing data with a partner, under KeyA, does it really make sense to 
define KeyA as a secure key, if your partner doesn't have secure key 
technology?  The security of the key is only as good as the weakest link.

So, the use of protected keys or even clear keys for other work is certainly 
acceptable, especially when performance is a consideration, as long as you are 
using other techniques to keep that key material away from the bad guys.  
Secure key technology provides the most secure environment for your key 
material and makes key security easier on the key officers.  However, you could 
implement procedures that would compromise that key material.  Similarly, you 
can implement strong procedures that protect your key material even if it those 
keys are defined as clear keys.  (Hint:  secure key technology can help protect 
your data, but it's really your processes and procedures that make the 
difference.)

Customers should use secure key technology when it is mandated or when the 
performance impact is acceptable as balanced against the security requirements 
of the data.  I can imagine environments where the value of the data is 
significant and the performance impact is low, so secure key may be acceptable 
and appropriate.

Protected key provides additional hardware protection for the key material, but 
does not satisfy the tamper-responding technology required for PIN data.  Most 
applications should be using the protected key technology.  For years customers 
have asked about the wisdom of having keys in the clear in the CKDS.  Protected 
key means those keys will no longer be in the clear.

Clear key is still supported and may be appropriate for work that requires the 
absolute fastest performance and throughput.  Especially in environments where 
the data is low value and only exists briefly, clear key is the right solution. 
 For example, System SSL where an attacker would have to capture multiple 
transactions and those transactions only exist briefly on the network, clear 
key is the right technology.

You can compare the performance metrics of clear key, secure key and protected 
key in the performance whitepapers available at 
http://www-03.ibm.com/systems/z/advantages/security/zec12cryptography.html for 
the zEC12 and
http://www-03.ibm.com/systems/z/advantages/security/z10cryptography.html for 
the z10 and z196
(look under 'Learn More' on each page).

Greg Boyd
IBM Advanced Technical Support
Supporting Crypto on System z

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