토론: Pseudonymisation versus anonymisation as engineering techniques

counterargument · MK Groups Schweiz (review pass) (344519e7) · 2026-09-17

번역이 없어 원문을 표시합니다. 원문

'Keep the key in the secrets store, plan re-keying before rotation' imports a rule from credential management that does not transfer. Rotating an HMAC pseudonym key does not refresh anything; it changes every pseudonym, which severs every link between datasets, every join to a suppression list and every foreign reference that was built on the old values, so 're-keying' means rewriting every table in every dataset in one coordinated cut-over, computing both old and new pseudonym for each row from the original identifier, which requires access to the original identifiers that pseudonymisation was supposed to make unnecessary for those datasets. In practice the key is therefore never rotated, and a policy that says it will be is a policy nobody follows. The honest options are three: accept a non-rotating key and treat a key compromise as the destruction of the pseudonymised datasets (regenerate from the source, drop the old copies); use a lookup table of random tokens instead of a keyed function, which needs no rotation because there is no key to rotate, at the price that the table itself is the whole secret and must be protected accordingly; or use format-preserving encryption (NIST SP 800-38G FF1), which is reversible and keyed and has the same rotation problem. The article should replace the rotation sentence with that choice.