| Encryption and
CISP, GLBA, HIPAA, etc.
While this
section was originally written for VISA online credit card merchants, it is relevant to
anyone who is concerned about data security. This includes anyone who is trying
to come into compliance with many other current and coming guidelines such as
HIPAA, GLBA, SDP, etc.
VISA has been in the forefront
of data protection and information security with their 12-point Cardholder Information Security Program
guidelines (CISP). (PDF)
We believe that Encryptionizer will be an important tool for
merchants trying to come into compliance with the Cardholder Information
Security Program. This is because of its stong encryption, ease-of-use and low
administrative overhead.
The Cardholder Information Security Program guidelines include requirements that data is
encrypted while stored and when sent across open networks. We have created this document to discuss
and illustrate how NetLib Encryptionizer can address CISP Requirement 3 and
Requirement 4 in those guidelines.
CISP Requirement 3: Encrypt Stored Data.
This CISP requirement may be among the most difficult for
merchants to comply with. While there are hundreds of products that can
generally be described as encryption software, most lack one or more of the
requirements outlined in CISP Requirement #3. Most require that the user decrypt the
files
before they are used, making the products unsuitable for large files, and
leaving files unprotected when in use or after a sudden program crash. Many
require that the user memorize and enter a file password (in addition to their
login password), further compromising security and making the product
suitable only for a single user. Other products require extensive program
modifications which is a problem if the merchant doesn’t have source code or
if the developers are long gone. Still others require such elaborate
administration that they end up going unused, or even worse, not maintained
as people come and go in the organization.
We believe that NetLib Encryptionizer provides the best
fit for merchants running applications on Microsoft platforms who are looking
to become compliant with VISA CISP Requirement #3.
Cryptographic systems must not
rely upon any one particular approach.
It might seem curious to list as one of the advantages
of Encryptionizer that it does not stop the merchant from using other
techniques at the same time. However, NetLib Encryptionizer is completely
seamless, requires very little administration, and requires no changes to the
merchant applications. Most other
techniques require extensive modification of programs and/or extensive
administration. NetLib’s design allows merchant's to use it on its own, or in
combination with any other techniques they choose to employ. The fact that it
requires no program changes and little or no administration, makes it an
attractive addition to a merchant's security arsenal regardless of the level
of their expertise.
In addition, Encryptionizer allows the administrator the
flexibility to change they keys on any or all of the encrypted files. So, for
example, company policy might dictate that keys be changed every month during
a standard maintenance cycle.
Cryptographic processing
isolation must ensure that no secret data can be disclosed.
There are a number of points in cryptographic
processing that keys or encrypted data can be unintentionally disclosed. The
weakness of most conventional file encryption products, other than
Encryptionizer, is that files must be decrypted on the media before they are
used. While this may be suitable for
very small files or single-user systems, this is not suitable for a large
database application with many users, as files are unprotected whenever they
are in use. (Some encryption products
try to mask this by decrypting files into a "hidden" directory.) With NetLib
Encryptionizer, files are always encrypted on physical media (e.g., hard
drive, CD, tape, etc.) NetLib decrypts data only in RAM and only data that the
application (*) requests. Data is
reencrypted if and when it is written back to media. Thus, data is always protected and
degradation in performance is negligible.
Another source of accidental disclosure of data is
through "temporary" or "work" files created when generating reports, running
queries, etc. Even if the original
data files are encrypted, these temporary files are almost always cleartext,
and often are not deleted, especially if the application terminates
unexpectedly. NetLib Encryptionizer
allows you to specify that all such temporary files are automatically
encrypted. This way, even if the application crashes or neglects to delete the files, data is still protected.
Finally, NetLib always encrypts keys on disk, and
immediately garbles or erases keys in RAM.
Use Triple-DES encryption or
other strong cryptography.
Encryptionizer currently uses AES, DES or Triple DES with a
key length of up to 256 bits. These are industry standard algorithms used by banks and other financial
institutions.
Use only approved devices to
process cryptographic material, such as keys.
Encryptionizer is very flexible as to the method of key
delivery. It is currently a
software-only mechanism that stores keys in a strongly encrypted file, or in
an encrypted registry entry. The design of Encryptionizer easily allows the
integration of new key delivery methods, such as PKI or "smart cards". If you are interested in these
alternate key delivery methods please contact us.
Don't store keys in a public
place.
One of the most important features of NetLib
Encryptionizer is that it does not require users to know or enter the data
keys. Only the administrator
originally encrypting the files needs to know the key (or administrators
in the case of "dual control"). Therefore, there are no keys to lose or compromise.
Ensure all cryptographic
systems conform to applicable international and national standards.
Currently, Encryptionizer is a software solution
using industry-standard encryption algorithms and techniques. However, the
design of Encryptionizer easily allows the integration of new key-delivery
and encryption methods, including through hardware such as smart cards.
Best Practice – Use "Split
Knowledge" or "dual control" to preserve system security.
Encryptionizer includes an optional SSP feature (secret
sharing protocol) for maximum password protection. Two different
administrators can choose half of a file's encryption key without letting the
other know their half.
(*)
The "application" is SQL Server, in the case of Encryptionizer for SQL
Server, or the desktop application, such as MS Access, in the case of
Encryptionizer DE.) |