Phil,

Interesting discussion. But taken another step, wouldn't the same also apply 
then to encrypted physical tape? As well as encrypted virtual tape? I believe 
that all physical tape encryption is done in a fashion similar; if you have 
authority to the data the volume will be decrypted for you. Would it follow 
that tape encryption should also follow and require unique encryption keys that 
are only available to authorized users in order to read the data?

Russell Witt

-----Original Message-----
From: IBM Mainframe Discussion List [mailto:[email protected]] On Behalf 
Of Phil Smith
Sent: Sunday, May 17, 2015 1:39 PM
To: [email protected]
Subject: Re: PCI DSS compliance for z/OS

Warning: long post ahead, and of course it’s pushing the hammer that we sell, 
but (I believe) there are universal truths included.

Frank,

You’re asking the right questions. The  basic followup question I’d ask is, “Do 
you want to pass an audit, or do you want to be secure?” Because those answers 
are different—as Target, Sony, Neiman Marcus, and a host of other companies who 
were PCI compliant and had passed audits can testify.

Industry opinion agrees with Peter Farley’s post: we do not believe that 
disk-level encryption satisfies PCI DSS, in part because it does not meet the 
Separation of Duties (SoD) requirements: if you read the DASD, you get the 
data. That’s not SoD. In the “lattice of coincidence” department, I *just* read 
the following:
https://pciguru.wordpress.com/2015/05/15/whole-disk-encryption-explained/

I know you said you didn’t like the idea of application-level encryption, but 
that’s the only real way to get security. If you think of a stack:

·         Applications

·         Middleware

·         Database

·         OS/filesystem

·         Hardware
...snip....

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