Warning: long post ahead, and of course it’s pushing the hammer that we sell, 
but (I believe) there are universal truths included.

Frank,

You’re asking the right questions. The  basic followup question I’d ask is, “Do 
you want to pass an audit, or do you want to be secure?” Because those answers 
are different—as Target, Sony, Neiman Marcus, and a host of other companies who 
were PCI compliant and had passed audits can testify.

Industry opinion agrees with Peter Farley’s post: we do not believe that 
disk-level encryption satisfies PCI DSS, in part because it does not meet the 
Separation of Duties (SoD) requirements: if you read the DASD, you get the 
data. That’s not SoD. In the “lattice of coincidence” department, I *just* read 
the following:
https://pciguru.wordpress.com/2015/05/15/whole-disk-encryption-explained/

I know you said you didn’t like the idea of application-level encryption, but 
that’s the only real way to get security. If you think of a stack:

·         Applications

·         Middleware

·         Database

·         OS/filesystem

·         Hardware

(and we could quibble about whether there are more layers in there or not, but 
close enough), then anything “above” the layer where you protect the data is 
not protected. So DASD-level encryption only protects against someone stealing 
the RVA (or backup tapes—it’s useful there for sure). OS/filesystem-level (not 
really relevant to z/OS, but to other platforms) doesn’t help with attacks 
against the databases, middleware, or applications. And so on.

The best security is thus at the application level. But of course you say “I 
don’t want to do that, that’s too hard”. It need not be.

Format-preserving data protection methods achieve PCI DSS compliance while 
enabling persistent, data-centric security. “Format-preserving” means that the 
encrypted/tokenized values look and feel like plaintext: same length, same 
character set. This allows you to protect the data as soon as possible when it 
enters your security perimeter (or before, in some cases!) and it stays 
protected throughout the system, being accessed (decrypted) only when 
absolutely necessary.

The simplest example of this is actually credit card numbers, at least for 
non-banks: if you have customer credit card numbers, you mostly don’t care what 
they are, just that you have them and that they appear consistently throughout 
your systems. So if you protect the PAN when it’s entered by the phone rep, or 
on the web page, or at least as soon as it gets to the outermost system of 
yours that touches it, then it can traverse the rest of the systems in its 
protected state. The only time you’ll need to decrypt/detokenize it is when you 
pass it to the bank for settlement, or perhaps in very specific fraud analysis 
cases.

Since the data protection is character set-transparent, the data can come in as 
ASCII and get translated to EBCDIC in its protected form without requiring 
changes, too. So we’ve found that well over 90% of applications require NO 
changes at all, since they don’t know or care that the data is now 
protected—but they’re instantly out of audit scope.

This is a different way of looking at data protection, but we believe it 
provides the most security with the least impact. No, it’s not 100% 
transparent, like encrypting DASD—but those approaches also don’t add much real 
security. We have many very large, Fortune 50 customers happily using HP 
SecureData to protect data in this manner. Our data protection methods are 
standards-based (our Format-Preserving Encryption technology is a draft 
standard with NIST, as FFX-mode AES), and we have independent security proofs 
available.

The other hard part—indeed, many folks find it the hardest part—of any data 
protection project is key management. HP SecureData includes a pretty 
interesting approach to solving this problem, too.

Of course I’d be happy to discuss this in far more detail with you or your 
management!
--
…phsiii

Phil Smith III
Senior Architect & Product Manager, Mainframe & Enterprise
HP Security Voltage

[email protected]<mailto:[email protected]>
T 703-476-4511
M 703-568-6662
Hewlett-Packard Company
Herndon, VA
---------- Forwarded message ----------
From: Frank Swarbrick 
<[email protected]<mailto:[email protected]>>
Date: Fri, May 15, 2015 at 1:35 PM
Subject: PCI DSS compliance for z/OS
To: [email protected]<mailto:[email protected]>

There has been a lot of discussion back and forth at my company as to what it 
means to meet the PCI DSS (Payment Card Industry Data Security Standard) 
requirement for data at rest, which I believe refers to the following from the 
PCI DSS v3.0:

3.4 Render PAN unreadable anywhere it is stored (including on portable digital 
media, backup media, and in logs) by using any of the following approaches:
-  One-way hashes based on strong cryptography, (hash must be of the entire PAN)
-  Truncation (hashing cannot be used to replace the truncated segment of PAN)
-  Index tokens and pads (pads must be securely stored)
-  Strong cryptography with associated key-management processes and procedures.

The argument is whether or not hardware disc encryption of mainframe DASD meets 
this requirement.

On non-mainframe platforms it is my understanding that "encrypted file systems" 
are what is used for PANs in "non-database" repositories.  Basically, flat 
files.  For databases I believe there are things done at the database level 
that encrypt the data prior to it being stored within the databases file 
system.  (Or maybe they do both?)

Anyway, other than maybe z/OS Unix files, I don't think that z/OS really has 
anything similar to non-mainframe files systems.  So does encryption just at 
the disc/DASD level comply with the requirement?  IBM would love to sell us 
their IBM InfoSphere Guardium Data Security product, but that only supports DB2 
and IMS databases.  This does not address VSAM files or simply sequential 
datasets (flat files).  Our card system stores all of its data in VSAM (for 
"master files") and uses flat files for "work files" during batch reporting.  
So if encrypted disc doesn't comply, what are our options?  I argue that 
encrypted disc does comply, but I seem to be losing that battle.

One thing I am absolutely against is changing applications that handle card 
data to do encryption/decryption at the application level, calling some sort of 
encryption API.  There needs to be a "system level" answer.

I know there must be others out there that deal/struggle with this.  What do 
you do?

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