In The Security Vs. Compliance Battle Of The Mind, Security Is Winning
Written by Walter ConwayA 403 Labs QSA, PCI Columnist Walt Conway has worked in payments and technology for more than 30 years, 10 of them with Visa.
If ever there was an argument where security trumped compliance, the debate about tokenization versus encryption is it. Readers have made that point abundantly clear following a recent column describing the PCI scope reduction benefits of tokenization versus encryption. The shift in emphasis from compliance to being secure is not new, but I was struck by how pronounced a perspective change retailers are experiencing.
Andrew Jamieson’s comment emphasized security over scope reduction. He described how he would put more faith in the security of a tested and proven technology like encryption than he would in tokenization. I know Andrew as a PCI and crypto pro, and although we have never met, we have exchanged ideas and thoughts on PCI-related issues remotely for a couple of years.
Where we differ is that, based on my experience, not every merchant has the expertise to implement an encryption system as well as Andrew might. He works for a security firm. A retailer’s IT department has a lot of other things to manage, and encryption may not be a core strength internally. Properly deployed, strong encryption can protect cardholder data and be PCI compliant. But compliance alone is not my focus. I look at minimizing PCI scope.
Where a merchant has the expertise (internally or through a partner), encryption can protect cardholder data. I believe the PCI scope will be broader than a similar implementation with tokenization. I agree with Andrew that if it is properly done, the encryption solution could be secure. I also believe we both would agree that either choice, properly implemented, would be more secure than the other if that one is poorly implemented.
Jeff Man got readers thinking about the process, drawing parallels between tokenization and encryption and pointing out that tokenization, too, is ultimately reversible. I know Jeff as a respected QSA and a crypto expert with impressive experience. He made the point that both processes are subject to compromise: Either the encryption keys or the token vault could be inadequately protected.
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February 1st, 2012 at 9:24 pm
Nice update post Walt, and thanks for the kind words :) I agree with pretty much all of what you have to say, and I think the implementation point is exactly why PCI is currently beavering away on the Point to Point Encryption (P2PE) program.
One of the major goals of this program is to place the burden of implementation back to the hands of the vendor(s), so that the merchant can rest assured that as long as they use the system provided for payments, everything else is taken care of.
I think that this has the potential to provide a terrific win for the merchants in scope for these sorts of systems, and also to the security posture of payments as a whole – exactly because it should ensure that people who know what they are doing are the only ones involved in the details.