FAQ #1084 Diff

For PCI DSS requirement 3.4.1 for disk encryption, what is the intent of requiring that logical access must be managed independently of native operating access control mechanisms?

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The intent of this requirement is to address the acceptability of disk encryption for rendering cardholder data unreadable. Disk encryption encrypts data stored on a computer’s mass storage and automatically decrypts the information when an authorized user requests it. Disk-encryption systems intercept operating system read and write operations and carry out the appropriate cryptographic transformations without any special action by the user other than supplying a password or pass phrase at the beginning of a session. Based on these characteristics of disk encryption, to be compliant with this requirement, the disk-encryption method cannot:
 
1.

 

Use the same user account authenticator as the operating system, or
2.

Use a decryption key that is associated with or derived from the system’s local user account database or general network login credentials.

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