It's not enough to just encrypt at the DASD level.  The exposure is not just 
the systems, but also (or even mainly) insider malfeasance.

Application programmers need access to (some form of) production data to 
perform valid regression testing at each change cycle.  This argues for 
security-product-protected production PAN files (no access at all except by 
production jobs submitted from the scheduling system and 
production-emergency-only authorized userid's) and duplicate masked or hashed 
PAN files where no programmer (or any other employees with file-viewing 
privileges) can view the real data.  How to mask or hash the copied data so 
that production code still operates correctly during unit and regression 
testing is an application-dependent issue.

None of this is easy.  It requires management buy-in for the additional DASD 
and processes to hash or mask the data, the effort required to determine how to 
do the hash or mask for each application and then to implement those processes, 
and then the additional CPU and DASD usage required by those processes forever 
afterwards.

And then there are report files produced for clients.  Do they have PAN data 
too?  How do your customer service personnel help the client if they can't see 
the real data the client sees?

Peter

-----Original Message-----
From: IBM Mainframe Discussion List [mailto:[email protected]] On Behalf 
Of Frank Swarbrick
Sent: Friday, May 15, 2015 1:36 PM
To: [email protected]
Subject: PCI DSS compliance for z/OS



There has been a lot of discussion back and forth at my company as to what it 
means to meet the PCI DSS (Payment Card Industry Data Security Standard) 
requirement for data at rest, which I believe refers to the following from the 
PCI DSS v3.0:

3.4 Render PAN unreadable anywhere it is stored (including on portable digital 
media, backup media, and in logs) by using any of the following approaches: 
-  One-way hashes based on strong cryptography, (hash must be of the entire 
PAN) 
-  Truncation (hashing cannot be used to replace the truncated segment of PAN) 
-  Index tokens and pads (pads must be securely stored) 
-  Strong cryptography with associated key-management processes and procedures. 

The argument is whether or not hardware disc encryption of mainframe DASD meets 
this requirement.

On non-mainframe platforms it is my understanding that "encrypted file systems" 
are what is used for PANs in "non-database" repositories.  Basically, flat 
files.  For databases I believe there are things done at the database level 
that encrypt the data prior to it being stored within the databases file 
system.  (Or maybe they do both?)

Anyway, other than maybe z/OS Unix files, I don't think that z/OS really has 
anything similar to non-mainframe files systems.  So does encryption just at 
the disc/DASD level comply with the requirement?  IBM would love to sell us 
their IBM InfoSphere Guardium Data Security product, but that only supports DB2 
and IMS databases.  This does not address VSAM files or simply sequential 
datasets (flat files).  Our card system stores all of its data in VSAM (for 
"master files") and uses flat files for "work files" during batch reporting.  
So if encrypted disc doesn't comply, what are our options?  I argue that 
encrypted disc does comply, but I seem to be losing that battle.

One thing I am absolutely against is changing applications that handle card 
data to do encryption/decryption at the application level, calling some sort of 
encryption API.  There needs to be a "system level" answer.

I know there must be others out there that deal/struggle with this.  What do 
you do?

Frank
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