The Problem With Disk Encryption
Full disk encryption provides incredible data protection for personal devices. If you haven’t enabled FileVault on your Mac, Windows Device Encryption on your PC, or Android Device Encryption on your phone, please go do it now (iOS encrypts storage by default). It’s easy, efficient, and secure. You will likely never notice the difference in usage or performance. Seriously. This is a no-brainer.
Once enabled, device encryption prevents just about anyone from accessing device data. Unless a malefactor possesses both device and authentication credentials, the data is secure.
Periodically, vulnerabilities arise that allow circumvention of device encryption, usually by exploiting a bug in a background service. OS vendors tend to fix such issues quickly, so keep your system up to date. And if you work in IT, enable full disk encryption on all of your users’ devices and drives. Doing so greatly reduces the risk of sensitive data exposure via lost or stolen personal devices.
Servers, however, are another matter.
The point of disk encryption is to prevent data compromise by entities with physical access to a device. If a governmental or criminal organization takes possession encrypted storage devices, gaining access to an of the data presents an immense challenge. Their best bet is to power up the devices and scan their ports for potentially-vulnerable services to exploit. The OS allows such services transparent access the file system via automatic decryption. Exploiting such a service allows access to any data the service can access.
But, law enforcement investigations aside,1 who bothers with physical possession? Organizations increasingly rely on cloud providers with data distributed across multiple servers, perhaps hundreds or thousands, rendering the idea of physical confiscation nearly meaningless. Besides, when exfiltration typically relies on service vulnerabilities, why bother taking possession hardware at all? Just exploit vulnerabilities remotely and leave the hardware alone.
Which brings me to the issue of compliance. I often hear IT professionals assert that simply encrypting all data at rest2 satisfies the responsibility to the security of processing (GDPR Article 32). This interpretation may be legally correct3 and relatively straight-forward to achieve: simply enable [disk encryption], protect the keys via an appropriate and closely-monitored key management system, and migrate data to the encrypted file systems.4
This level of protection against physical access is absolutely necessary for protecting sensitive data.
Necessary, but not sufficient.
When was the last time a breach stemmed from physical access to a server? Sure, some reports in the list of data breaches identify “lost/stolen media” as the beach method. But we’re talking lost (and unencrypted) laptops and drives. Hacks (service vulnerability exploits), accidental publishing,5 and “poor security” account for the vast majority of breaches. Encryption of server data at rest addresses none of these issues.
By all means, encrypt data at rest, and for the love of Pete please keep your systems and services up-to-date with the latest patches. Taking these steps, along with full network encryption, is essential for protecting sensitive data. But don’t assume that such steps adequately protect sensitive data, or that doing so will achieve compliance with GDPR Article 32.
Don’t simply encrypt your disks or databases, declare victory, and go home.
Bear in mind that data protection comes in layers, and those layers correspond to levels of exploitable vulnerability. Simply addressing the lowest-level requirements at the data layer does nothing to prevent exposure at higher levels. Start disk encryption, but then think through how best to protect data at the application layer, the API layer, and, yes, the human layer, too.
Presumably, a legitimate law enforcement investigation will compel a target to provide the necessary credentials to allow access by legal means, such as a court order, without needing to exploit the system. Such an investigation might confiscate systems to prevent a suspect from deleting or modifying data until such access can be compelled — or, if such access is impossible (e.g., the suspect is unknown, deceased, or incapacitated) — until the data can be forensically extracted. ↩︎
Yes, and in transit. ↩︎
Although currently no precedent-setting case law exists. Falling back on PCI standards may drive this interpretation. ↩︎
Or databases. The fundamentals are the same: encrypted data at rest with transparent access provided to services. ↩︎
I plan to write about accidental exposure of data in a future post. ↩︎