Extreme logging or Too Much of a Good Thing

Strict interpretations of compliance policy standards can lead you up the creek without a paddle. Consider two examples:

  1. From PCI-DSS comes the prescription to “Track & monitor all access to network resources and cardholder data”. Extreme logging is when you decide this means a db audit log larger than the db itself plus a keylogger to log “all” access.
  2. From HIPAA 164.316(b)(2) comes the Security Rule prescription to “Retain … for 6 years from the date of its creation or the date when it last was in effect, whichever is later.” Sounds like a boon for disk vendors and a nightmare for providers.

Before you assault your hair follicles, consider:
1) In clarification, Visa explains “The intent of these logging requirements is twofold: a) logs, when properly implemented and reviewed, are a widely accepted control to detect unauthorized access, and b) adequate logs provide good forensic evidence in the event of a compromise. It is not necessary to log all application access to cardholder data if the following is true (and verified by assessors):
– Applications that provide access to cardholder data do so only after making sure the users are authorized
– Such access is authenticated via requirements 7.1 and 7.2, with user IDs set up in accordance with requirement 8, and
– Application logs exist to provide evidence in the event of a compromise.

2) The Office of the Secretary of HHS waffles when asked about retaining system logs- this can be reasonably interpreted to mean the six year standard need not be taken literally for all system and network logs.

Shakespeare seems to have it right as far back as the 15th century.

Obviously I am not a lawyer and this blog is clearly no substitute for legal advice.