DCTR-16

Does your cloud solution provider have access to your encryption keys?

Explanation

This question is asking whether your cloud service provider (CSP) has access to the encryption keys that protect your data stored in their cloud environment. Encryption keys are digital credentials that control the ability to decrypt encrypted data. If your CSP has access to these keys, they could potentially decrypt and access your data. This is being asked in a security assessment because key management is a critical aspect of data protection. When a CSP has access to your encryption keys, it introduces additional security considerations: 1. Increased access risk: If the CSP can access your keys, their employees might potentially access your sensitive data. 2. Legal/compliance implications: In some regulated industries, allowing third-party access to encryption keys may violate compliance requirements (like HIPAA for healthcare or PCI DSS for payment data). 3. Government requests: If a CSP has your keys, they could be compelled by legal orders to decrypt your data without your knowledge. The best way to answer this question is to be transparent about your key management approach. If your CSP does have access to your keys, explain what controls are in place to protect them. If they don't have access, explain how you manage the keys independently. Consider mentioning: - Whether you use CSP-managed keys or customer-managed keys - If you employ a Bring Your Own Key (BYOK) or Hold Your Own Key (HYOK) model - What key management system you use - Any additional safeguards in place to protect keys

Example Responses

Example Response 1

No, our cloud solution provider does not have access to our encryption keys We implement a Hold Your Own Key (HYOK) model where all encryption keys are generated and managed within our on-premises Hardware Security Module (HSM) The cloud provider only receives encrypted data and cannot decrypt it without the keys that remain solely in our control We use a dedicated key management service that integrates with our cloud environment but keeps the actual keys segregated from the cloud provider's infrastructure.

Example Response 2

Yes, our cloud solution provider does have access to our encryption keys, but with significant controls in place We use the provider's Key Management Service (KMS) for convenience and operational efficiency However, we've implemented strict access controls including multi-party authorization for key operations, comprehensive audit logging of all key access events, and regular key rotation Additionally, our contract with the provider includes specific clauses about key protection, confidentiality, and non-disclosure We've assessed this approach against our risk profile and determined it acceptable for our non-regulated data.

Example Response 3

No, we do not currently implement encryption for data stored in our cloud provider's environment While we recognize this represents a security gap that we're working to address, our current architecture was designed before encryption was a standard practice We're in the process of implementing a comprehensive encryption strategy using the cloud provider's native encryption services, but with customer-managed keys that will be controlled through our own key management infrastructure This project is scheduled for completion within the next quarter, at which point the cloud provider will not have access to our encryption keys.

Context

Tab: Infrastructure
Category: Datacenter