Dave Asprey's presentation on "Where to Store the Cloud Encryption Keys" from InterOp 2012.

1. Where to Store Cloud Encryption Keys
Securing Your Journey to the Cloud
Dave Asprey, VP Cloud Security
@daveasprey
1
10/30/2012 Copyright 2012 Trend Micro Inc. 1

2. 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

3. 30
million
# of Americans who are victims of reported data breaches

4. 90%
of enterprises encrypt in the public cloud

5. Why key management matters now
• 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

6. Higher Risks
• Reputation and profitability
• Brand damage and potential loss of customers
• Litigation expenses and large fines

7. Breach notification is a disaster
• Allowances if data was encrypted
• 44 states have independent data breach laws
• Nevada and Minnesota use PCI

8. The following need keys:
• Tokenization or data anonymization schemes
• Mounted storage volume encryption
• File encryption
• Native database encryption (transparent data encryption)

9. Key issues in key management
• Security of key management infrastructure
Compromised key means compromised data
• Separation of duties
ACL so admins can backup files but not view sensitive data
• Availability
If your key is lost, your data is cryptographically destroyed
• Legal issues
Hidden law enforcement requests for keys and data

10. “COBIT
is an IT governance framework and supporting toolset
that allows managers to bridge the gap between
control requirements, technical issues and business risks.
”
-ISACA

11. 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

12. “ 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. ”

13. PCI
“Encryption keys used for encryption
Of cardholder data must be protected
”
against both disclosure and misuse.

14. PCI Requirement
3.6
 Fully document and implement all key-management processes and procedures for
cryptographic keys used for encryption of cardholder data

15. 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)

16. PCI Requirement
3.6.8
 Mandates documentation with formal key custodian forms & sign-off procedures

17. 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 processes
Notify customers of a data breach regardless of whether the data was encrypted or not.

18. 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

19. 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

20. COBIT, PCI, HIPAA, and SOX store encryption keys:
1. Securely
2. Separately from data
3.Under the control of the cloud consumer

21. Three Key Options
1. Enterprise data center
2. SaaS Key Management
3. laaS Key Management

22. 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

23. 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

24. 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.

25. Which Secure Cloud Deployment Option?
Requirement
Download at: cloud.trendmicro.com

26. Thank you
Dave Asprey, VP Cloud Security
@daveasprey
26
10/30/2012 Copyright 2012 Trend Micro Inc. 26