Securing Your Journey to the Cloud

Dave Asprey, VP Cloud Security

@daveasprey

Where to Store Cloud Encryption Keys

1104/08/2023 Copyright 2012 Trend Micro Inc.

Focus

• State of encryption deployment

• Key management details of COBIT, PCI, HIPAA and SOX

• Best practices for cloud encryption key management

• Where to maintain encryption keys

# of Americans who are victims of reported data breaches

30

million

90% of enterprises encrypt in the

public cloud

• Increased amount of sensitive data in the cloud

• Risk of data loss caused by employees mishandling data

• More sharing of authorized data with external users

• Emerging marketplaces for stolen data

• New (crazy) regulatory requirements

Why key management matters now

Higher Risks

• Reputation and profitability

• Brand damage and potential loss of customers

• Litigation expenses and large fines

Breach notification is a

• Allowances if data was encrypted

• 44 states have independent data breach laws

• Nevada and Minnesota use PCI

disaster

The following need keys:

• Tokenization or data anonymization schemes

• Mounted storage volume encryption

• File encryption

• Native database encryption (transparent data encryption)

Key issues in key management

• Security of key management infrastructure Compromised key means compromised data

• Separation of dutiesACL so admins can backup files but not view sensitive data

• Availability If your key is lost, your data is cryptographically destroyed

• Legal issuesHidden law enforcement requests for keys and data

is an IT governance framework and supporting toolset

that allows managers to bridge the gap between

control requirements, technical issues and business risks.

-ISACA

“COBIT

”

COBIT Encryption Key Management Requirements

• transporting

• storage

• recovery

• retirement/destruction

• theft

• frequency of required use

*Included with these procedures should be requirements over securing the key and controlling the elevation of the key

“Keys should be maintained on a computer that is not

accessible by any programmers or users, such as router

controls for logical access and strong physical controls

with an air gap in a secured area/room.”

PCI

“Encryption keys used for encryption

Of cardholder data must be protected

against both disclosure and misuse.”

PCI Requirement

3.6

Fully document and implement all key-management processes and procedures for cryptographic keys used for encryption of cardholder data

PCI Requirement

3.6.4

Mandates that encryption keys be rotated at least annually or vendor best practice (every 3 years)

Hardware security module (HSM) easily encrypts database columns and rotate keys on a per record basis, but won’t work for flat files or logs (extract-decrypt-re-encrypt)

PCI Requirement

3.6.8

Mandates documentation with formal key custodian forms & sign-off procedures

PCI Requirement

3.6.b

Service providers should provide key management guidance to customers covering transmission, storage, and update of customer keys (not just storage)

Split knowledge and dual control applies only for manual key management processesNotify customers of a data breach regardless of whether the data was encrypted or not.

HIPAA

Protected health information (PHI) is rendered unusable, unreadable, or indecipherable to unauthorized individuals if one or more of the following applies:

To avoid a breach of the confidential process or key, decryption tools should be stored on a device or at a location separate from the data they are used to encrypt or decrypt.

The encryption processes should have been tested by the National Institute of Standards and Technology (NIST) and judged to meet this standard.

Electronic PHI has been encrypted as specified in the HIPAA Security

SOX

• Sarbanes Oxley adheres to COBIT in section DS 5.7

“Accepted frameworks for use with SOX are COSO and COBIT“

• Section DS 5.8

“Dedicated key storage devices and application”-A separation of duties

COBIT, PCI, HIPAA, and SOX store encryption keys:

1. Securely

2. Separately from data

3.Under the control of the cloud consumer

Three Key Options

1. Enterprise data center

2. SaaS Key Management

3. laaS Key Management

Enterprise Datacenter

• Maximum control

• Potentially higher security and availability (DR possible)

• No risk of external party breach compromising your data • Virtual appliance vs. hardware appliance vs. software

SaaS Key Management

• SaaS vendor takes responsibility for the keys

• Cloud economics

• Availability of SaaS vendor is based on your data availability level

• Potential Security risks if SaaS vendor loses key

• Legal issues under Patriot Act

IaaS Key Management

• Use tokenization or encryption services from IaaS vendor

• Same security and availability problem as SaaS

• Effectively makes IaaS provider custodian of keys and data

• Some providers offer encryption so you can manage the keys yourself

• Enterprises must assess their risk tolerance and audit requirements before they can select a solution that best meets their encryption key management needs.

Which Secure Cloud Deployment Option?

Requirement

Download at: cloud.trendmicro.com

Dave Asprey, VP Cloud Security

@daveasprey

Thank you

262604/08/2023 Copyright 2012 Trend Micro Inc.