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Tokenization vs. Encryption: Personal Information Security

In my last post I discussed how tokenization is being deployed to solve payment data security issues. It is a niche technology used almost exclusively to solve a single problem: protecting credit card data. As a technology, data tokenization has yet to cross the chasm, but our research indicates it is being used to protect personal information. In this post I will talk about using tokens to protect PII – Social Security numbers, driver’s license numbers, and other sensitive personal information. Data tokenization has value beyond simple credit card substitution – protecting other Personally Identifiable Information (PII) is its next frontier. The problem is that thousands of major corporations built systems around Social Security numbers, driver’s license numbers, or other information that represents a person’s identity. These data were engineered into the foundational layers of myriad applications and business processes which organizations still rely on. The ID (record number) literally tied all their systems together. For example, you could not open a new telephone account or get an insurance policy without supplying a Social Security number. Not because they needed the number legally or technically, but because their IT systems required the number to function. SSNs provided secondary benefits for business analysis, a common index for 3rd party data services, and useful information for fraud detection. But the hard requirement to provide SSN (or driver’s license number, etc.) was that their application infrastructures were designed to require these standard identifiers. PII was intrinsically woven into database and application functions, making it very hard to remove or replace without negative impact on stability and performance. Every access to customer information – billing, order status, dispute resolution, and customer service – required an SSN. Even public web portals and phone systems use SSN to identify customers. Unfortunately, this both exposed sensitive information to employees with no valid reason to access customer SSNs and contributed to data leakage and fraud. Many state and local government organizations still use SSNs this way, despite the risks. Organizations have implemented a form of tokenization – albeit unwittingly – by substituting SSN and driver’s license numbers with arbitrary customer ID numbers. Social Security numbers are then moved into secure databases and only exposed to select employees under controlled circumstances. These ad hoc home-grown tokenization implementations are no less tokenization than the systems offered by payment processors. A handful of organizations have taken this one step further, used third-party solutions to manage token creation, substitution, data security, and management. But there are still thousands of organizations with sensitive data in files and databases to identify (index) clients and customers. PII remains a huge potential market for off-the-shelf tokenization products. While this is conceptually simple, and simply a good idea for security, not every company uses tokenization for PII – either commercial or ad hoc – because they lack sufficient incentive. Most companies lack strong motivation to protect your personal information. If it’s lost or stolen, you will need to clean up the mess. There are many state regulations that require companies to protect PII and alert customers in the event of a data breach. But these laws are not adequately enforced, and provide too many loopholes, so very few companies ever face fines. For example, most laws are designed to excuse breaches if data encryption was in use. So if a company encrypts network communications, or encrypts data archives, or encrypts your database, they may be exempt from disclosure. The practical upshot is that companies encrypt data in one context – and escape legal penalties such as fines – while leaving it exposed in other contexts. The fact that so many data breaches continue to expose customer data clearly demonstrates the lack of effective data security. Properly deployed, encryption is a perfectly suitable tool for protecting PII. It can be set up to protect archived data or data residing on file systems without modification to business processes. Of course you need to install encryption and key management services to protect the data, understanding this only protects data from access that circumvents applications. You can add application layer encryption to protect data in use – but this requires changing applications and databases to support this additional protection, paying the cost and accepting the performance impact. In cases like PII – which really is not needed for the vast majority of application functions – tokenizing personal information reduces the risk of loss or theft without impacting operations. Risk is reduced because you can’t steal what’s not there. This makes tokenization superior to encryption for security: If encryption is deployed insecurely, if administrative accounts are hijacked, or if encryption keys are compromised, the data is exposed. Tokenization simplifies operations – PII is stored in a single database, and you don’t need to install key management or encryption systems. Setup and maintenance are both reduced, and the number of servers which require extensive security is also reduced. Tokenization of PII is often the best strategy as it’s cheaper, faster, and more secure than alternatives. Share:

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How to Encrypt or Tokenize for SaaS (and Some PaaS)

A few weeks ago I posted on different methods for encrypting IaaS volumes, which tends to be one of the top questions I get about data security in the cloud. Also high on that list is encrypting (or tokenizing) for SaaS and (some) PaaS. I call this the “Salesforce.com Problem”, because more often than not I’m talking to someone on the larger side, specifically about Salesforce.com. Before I go into options, I need to explain why I’m only talking about some PaaS. PaaS covers a very wide range of technologies – from Database as a Service, to things like Google APIs, to full-on application environments like CloudFoundry and Elastic Beanstalk. For this post I’m mostly restricting myself to SaaS-related PaaS like Force.com. In other words, API interfaces to things you can also run completely via a web interface. I know this is a grey line, and in some future post I’ll go more into detail on encrypting for the rest of PaaS. Just recognize that the core architecture described here works for cases beyond this scope, but some of the issues & details may not apply. There are only two options for SaaS encryption: Encrypt it at the SaaS provider. Encrypt it before you send it. To review quickly, when analyzing encryption systems we look at the locations of three components: the data, the encryption engine, and key management. If your SaaS provider handles the encryption on their side, they hold all three components, so this option requires trust in your provider. Yes, there are many subtleties and options that dramatically affect security, but at the core the provider needs the key and the data at some point. The advantage (for you) is simplicity and flexibility. But if you don’t trust your SaaS provider, you’ll need to encrypt on your side… which means increased cost and complexity. If you encrypt it before you send it, there are two options: Encrypt in a client application before uploading the data. Proxy connections and encrypt at the proxy. The first option is common for things like backup applications, but as I mentioned that’s more PaaS – the part we aren’t talking about here. Espcially because the vast majority of the apps I am talking about today are web-based. So most organizations I know which are looking to do this are evaluating proxy-based solutions such as CipherCloud, PerspecSys (maybe – their website sucks and doesn’t mention how they work), and Navajo Systems. These are application-aware web proxies that intercept browser calls to the SaaS provider and replace sensitive data with encrypted or tokenized values. Instead of connecting directly to the SaaS provider, users go through the proxy. You configure it to encrypt or tokenize sensitive data, although instead of defining every field on every form you should be able to say “account number” and have the product automagically replace it everywhere. In some future post I’ll delve into this architecture in more depth, but there are three main challenges to this approach: The product needs to stay totally up to date with any changes with the SaaS provider UI/application. When you are intercepting and rewriting HTML fields on the fly, you really need to know exactly where they are. Users need to connect back through your enterprise, or a trusted web-based host (e.g., running the proxy at Rackspace). For your internal network, this means you’re back to running VPNs. If you host on the outside, you have another party to trust but can handle it with bookmarks or such. If you use a cloud-based web proxy for URL filtering and content security, you might be able to map it up there. You might break application functionality/usefulness. This requires a lot of translation, which affects SaaS features that rely on the protected data. This becomes more of an issue as you protect more fields and data types – the more you obfuscate, the less your SaaS app can process. (It can still process the un-tokenized data). Because of these challenges I tend to regard this proxy approach as a band-aid for SaaS. It’s definitely not ideal, and a heck of a lot of work for the vendor to keep up and running. I believe it makes more sense for PaaS, where you rely more on APIs than HTML interfaces. In all cases I think the web proxy approach is best used for very discrete and limited data – otherwise there is too much potential loss of core application functionality, at which point you might as well stick to internal systems. Share:

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Friction and Security

Every company I have worked for has had some degree of friction between sales and marketing teams. While their organizational charters are to support one another, sales always has some disagreement about how products are positioned, the quality of competitive intelligence, the quality of leads, and the lack of <insert object here> to grease the customer skids. Marketing complains that sales does not follow the product sales scripts, doesn’t call leads in a timely fashion, and don’t do a good job of collecting customer intelligence. Friction is a natural part of the relationship between the two organizations, so careful balancing is necessary. I was reading George Hulme’s interview David Litchfield on securing the data castle this morning, which provides basic security steps every organization should take. There’s also a list of intermediate Oracle security controls (PDF). But the real challenge was not performing Litchfield’s steps – it’s managing the resulting friction. The issue is that problems arising between database administrators and everybody else. Litchfield says: Beyond patch updates and good password management, what else can organizations be doing that they’re not? Use the principle of least privilege within their applications. This is a very important one. People are pressured into getting their applications running as quickly as they can. However, when they try to manage permissions properly, that good practice can delay deployment slightly. So they say, “Oh look, let’s just give users all the permissions. The application seems to work with these settings. Let’s shove that into production.” Not a great approach. If you don’t want a breach, it’s really worth spending the extra time to design an application that operates on least privilege. Which is all true, but only one side of the coin. For example, setting permissions is easy. Managing and maintaining good permissions over time is more work and creates friction between organizations. Most DBAs face user calls on a daily basis, asking for added permissions to complete some task. Users look at permissions – or their lack – as impediments to getting their jobs done. Worse, should the DBA decline the request, the DBA takes the blame for lost time. DBAs need to add the permissions and then – at some prearranged time – revoke them. But most DBAs, looking to avoid future calls to add privileges, never revoke them. It’s easier and less hassle, and users are happier. Face it – a few minutes of wasted time for both parties, especially with hundreds or even thousands of users, adds up to a lot of time. Who’s going to notice? Patching is the same – upgrade an application or database revision and stuff breaks. Or just as bad, the application works differently than before. New features and functions create complaints like “What happened to X?” and “It used to do Y, but now it doesn’t!”, so for several weeks the help desk is swamped with calls. And password rotation and long password requirements both generate help desk calls by the dozen. So what’s the result? User complaints. Systems are not reliable, which results in the poor DBA getting a poor ‘performance’ rating. Which is sad because the friction between user demands for everything and DBAs holding the line for security is a sign that DBAs are doing their jobs. But doing their jobs gets them dinged on performance, so they don’t get raises, so they leave for other jobs. Any good DBA understands that there is a correct degree of friction in their role for security. It’s not just planning for the security measures you want to put in place, but understanding how to mitigate their impact on the organization. Plan ahead and don’t let security be “your fault”. Share:

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