This may lead to irrational results. Systems with large amounts of routinely collected data would be afforded more protection than systems that maintain significantly smaller amounts of extra-ordinarily collected data. Common reasoning suggests that more sensitivity about the extra-ordinary than the routine. The NPRM defines data as merely a sequence of symbols to which meaning is assigned. The regulation proposes authentication mechanisms which have the effect of corroborating the meaning of characters, data elements, records, and messages.
Data authentication relies on large amounts of meta-data containing the corroborating information.
8 Technical Security Services 43254-2,3 List of acceptable authentication mechanisms does not include public key challenge response used in conjunction with digital certificates. What standards will be adopted for digital certificates. The value of Digital Signatures is limited by, among other things, the trustworthiness of the signer's digital certificates. However, the standard does not address how trust in certificate authorities is to be established or what scrutiny should be applied to the operations of CAs. Clarify the role of certificates and certificate authorities in establishing the standard.