CIPT practice question 5 of 30

SCENARIO Looking back at your first two years as the Director of Personal Information Protection and Compliance for the St. Anne’s Regional Medical…

Full set: 220 questions
SCENARIO Looking back at your first two years as the Director of Personal Information Protection and Compliance for the St. Anne’s Regional Medical Center in Thorn Bay, Ontario, Canada, you see a parade of accomplishments, from developing state-of-the-art simulation based training for employees on privacy protection to establishing an interactive medical records system that is accessible by patients as well as by the medical personnel. Now, however, a question you have put off looms large: how do we manage all the data-not only records produced recently, but those still on-hand from years ago? A data flow diagram generated last year shows multiple servers, databases, and work stations, many of which hold files that have not yet been incorporated into the new records system. While most of this data is encrypted, its persistence may pose security and compliance concerns. The situation is further complicated by several long-term studies being conducted by the medical staff using patient information. Having recently reviewed the major Canadian privacy regulations, you want to make certain that the medical center is observing them. You recall a recent visit to the Records Storage Section in the basement of the old hospital next to the modern facility, where you noticed paper records sitting in crates labeled by years, medical condition or alphabetically by patient name, while others were in undifferentiated bundles on shelves and on the floor. On the back shelves of the section sat data tapes and old hard drives that were often unlabeled but appeared to be years old. On your way out of the records storage section, you noticed a man leaving whom you did not recognize. He carried a batch of folders under his arm, apparently records he had removed from storage. You quickly realize that you need a plan of action on the maintenance, secure storage and disposal of data. Which cryptographic standard would be most appropriate for protecting patient credit card information in the records system at St. Anne’s Regional Medical Center?
Answer options
A: Symmetric Encryption
B: Tokenization Correct answer
C: Obfuscation
D: Certificates
Correct Answer:
B. Tokenization
Explanation

Tokenization is the most appropriate standard for protecting credit card information in this scenario. It is a process recommended by the Payment Card Industry Data Security Standard (PCI DSS) where the primary account number (PAN) is replaced with a unique, non-sensitive equivalent value called a "token." This token has no extrinsic or exploitable meaning or value. The actual sensitive cardholder data is stored securely in a centralized vault. By using tokens, the medical center's systems can process payments without storing or transmitting the actual PAN, significantly reducing the scope of PCI DSS compliance and minimizing the risk of a data breach.

Why Incorrect

A. Symmetric encryption is a valid method for protecting data at rest, but tokenization is a more specialized and often preferred control for payment card data to reduce compliance scope.
C. Obfuscation is a general term for making data difficult to understand. It is not a formal cryptographic standard and lacks the security assurances of tokenization for financial data.
D. Certificates are used for authentication and securing data in transit (e.g., TLS), not for protecting sensitive data like credit card numbers stored at rest in a database.

References

1. PCI Security Standards Council. (2018, August). PCI DSS Tokenization Guidelines, Version 2.0. Page 5, Section 3.0: "Tokenization can be used to reduce the scope of the cardholder data environment (CDE)."

2. PCI Security Standards Council. (2022, March). Payment Card Industry Data Security Standard (PCI DSS) v4.0. Requirement 3.3: "Mask PAN when displayed (the first six and last four digits are the maximum number of digits to be displayed)." Tokenization is a method to achieve this and protect the full PAN.

3. National Institute of Standards and Technology (NIST). (2014). NISTIR 8008, Interagency Report on Status of International Cybersecurity Standardization. Section 4.1.1 discusses PCI DSS and its controls for protecting cardholder data.

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