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5.1.1.2 - Definition of "stored separately" #2011

@KenWhitesell

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@KenWhitesell

What constitutes "stored separately" for satisfying the intent of this paragraph?

Stored separately could mean many different things -

  • Files
  • Databases
  • Internal APIs
  • Virtual Machines
  • Physical Machines
    • (Requiring a Hardware Security Module?)
  • Physical Locations

I can see where each one of these provide different degrees of separation - and therefore protection, and that the degree of separation should be based upon a risk-analysis of the data being protected.

But at some point, I would expect that there be some minimal degree of separation to be able to be considered compliant with this recommendation.

I can understand that in the general case, "anything is better than nothing", but we would appreciated some guidance or clarification on the intent.

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