There are a lot of security professionals and lay people that seem to believe that encryption is encryption and that is simply not the case. Worse yet, vendors play into this misconception and obfuscate the issue with lots of words and phrases discussing seemingly complicated encryption key management procedures and the like that are actually meaningless when it comes to protecting data on running systems. As a result, it is time to clarify all of this misunderstanding.
First things first, we need to discuss how whole disk encryption works. As its name implies, whole disk encryption encrypts an entire disk drive. When a file on the whole disk encrypted drive is accessed, the encryption solution decrypts the file necessary using the decryption key provided at system startup and the rest of the drive remains encrypted. That way if a system failure occurs or the system is shutdown deliberately, the drive is always protected.
That is the key concept of whole disk encryption. The drive is technically only encrypted when the system is shutdown. If the system is running, the encryption is technically not in place because the operating system has the decryption key to access the disk at will. This is why whole disk encryption is great for devices like notebooks and the like that are shutdown at some point.
This is also why whole disk encryption is meaningless when applied to a server. When is a server shut down? Never. When using whole disk encryption on a running server, the only control that protects data is access controls, not encryption.
So using this definition, let us examine requirement 3.4.1 in the PCI DSS. That requirement states:
“If disk encryption is used (rather than file- or column-level database encryption), logical access must be managed separately and independently of native operating system authentication and access control mechanisms (for example, by not using local user account databases or general network login credentials). Decryption keys must not be associated with user accounts.”
The first statement that throws people is “logical access must be managed separately and independently of native operating system authentication and access control mechanisms”. In short, whole disk encryption cannot rely only on the operating system’s authentication process.
The best example of this is Microsoft BitLocker. BitLocker has a number of modes under which it can operate. It can integrate with Active Directory (AD), it can rely on a trusted platform module (TPM) chip in the computer or it can operate stand-alone.
In stand-alone mode, BitLocker requires the user to provide the BitLocker key by either manually keying it in or providing it on a USB device that stores the BitLocker key in order to boot the system. If that key is not provided, the system will not even offer the user to logon. This form of BitLocker meets the requirements set forth in requirement 3.4.1.
But then the requirement goes on and say, “Decryption keys must not be associated with user accounts”.
In stand-alone mode, the BitLocker key is not associated with the user’s credentials so it also meets this part of 3.4.1.
However, in the AD or TPM modes, BitLocker operates behind the scenes and the end user never knows that their disk is encrypted and the user still logs onto the system as always using their Windows credentials. These modes do not meet the independence requirement in 3.4.1 because all that is protecting the data is the user’s Windows credentials. And in the case of AD mode, BitLocker also does not meet the user credential disassociation requirement because the BitLocker decryption key is tied to the user’s Windows credentials.
But if people would fully read the Guidance column for requirement 3.4.1 they would read the following at the end of the guidance for 3.4.1 where the Council states:
“Full disk encryption helps to protect data in the event of physical loss of a disk and therefore may be appropriate for portable devices that store cardholder data.”
Whole disk encryption helps protect data in the event of physical loss of a disk. Period.
So with a server that never shuts down, if a drive in a SAN or NAS fails, the failed disk with whole disk encryption will be encrypted when it is pulled from the array. But if things are running just fine, whole disk encryption does nothing to protect the data.
So do not be baffled by the statements from those vendors trying to convince you that whole disk encryption on your server is going to protect your data while the server is running. That is not true.
Now you know.