DATA-23

Do you have a cryptographic key management process (generation, exchange, storage, safeguards, use, vetting, and replacement) that is documented and currently implemented, for all system components (e.g., database, system, web, etc.)?

Explanation

This question is asking whether your organization has a formal, documented process for managing cryptographic keys throughout their entire lifecycle. Cryptographic keys are the secret values used in encryption algorithms to secure data. The question specifically wants to know if you have processes for: 1. Generation: How keys are created securely 2. Exchange: How keys are shared between systems or parties 3. Storage: How keys are securely stored 4. Safeguards: What protections exist for the keys 5. Use: How keys are properly utilized 6. Vetting: How keys are verified as secure 7. Replacement: How and when keys are rotated or changed This question is asked in security assessments because poor key management can completely undermine otherwise strong encryption. Even if you use the strongest encryption algorithms, if your keys are improperly generated, stored insecurely, never rotated, or shared inappropriately, your encrypted data remains vulnerable. The question specifically mentions 'all system components' because different systems (databases, web servers, etc.) may use different encryption mechanisms and keys. To best answer this question, you should: 1. Confirm whether you have a documented key management process 2. Briefly describe your key management lifecycle 3. Mention specific standards or frameworks you follow (like NIST SP 800-57) 4. Note any automation tools used for key management 5. Explain how you handle different types of keys across different systems 6. Mention key rotation schedules and policies If you don't have a formal process, be honest but explain what controls you do have in place and any plans for improvement.

Guidance

Summarize your cryptographic key management process.

Example Responses

Example Response 1

Yes, we maintain a comprehensive cryptographic key management process that is fully documented and implemented across all system components Our process follows NIST SP 800-57 guidelines and covers the complete key lifecycle Keys are generated using FIPS 140-2 validated hardware security modules (HSMs) with sufficient entropy Key exchange occurs through secure channels with proper authentication All keys are stored in our enterprise key management system (HashiCorp Vault) with access limited to authorized personnel using multi-factor authentication We implement separation of duties for key management operations Keys are categorized by sensitivity and usage, with different rotation schedules: TLS certificates every 90 days, database encryption keys annually, and master keys every two years We maintain key version history and have automated processes for key rotation that minimize service disruption Our security team conducts quarterly reviews of key access logs and our key management procedures are tested during annual disaster recovery exercises.

Example Response 2

Yes, our organization has implemented a documented cryptographic key management process across all production systems For key generation, we use AWS KMS for cloud-based applications and dedicated HSMs for on-premises systems, ensuring keys meet NIST standards for length and randomness Key exchange is handled via secure API calls with TLS 1.3 and mutual authentication Keys are stored in segregated environments based on their classification level, with master keys in offline storage We employ a dual-control mechanism requiring two authorized administrators to approve key operations for critical systems Our key rotation policy enforces automatic rotation of encryption keys every 6 months for customer data and annually for internal systems We use automated monitoring to detect and alert on unauthorized key access attempts Our key management procedures are documented in our security policy repository, reviewed semi-annually, and all key management personnel receive specialized training We maintain an inventory of all cryptographic keys with their purpose, owners, and expiration dates.

Example Response 3

No, we currently do not have a comprehensive documented cryptographic key management process implemented across all system components While we do generate encryption keys for our primary database using the database's built-in key generation functionality, and we store TLS certificates securely, we lack a formal process that addresses all aspects of key management We do not have consistent procedures for key rotation, and some legacy systems still use hardcoded encryption keys in configuration files We recognize this as a security gap and have initiated a project to implement a proper key management solution In the interim, we have implemented quarterly manual key rotations for our most critical systems and restricted access to encryption keys to only senior IT staff We expect to have a complete key management process documented and implemented within the next 6 months, including the deployment of a centralized key management system and formalized procedures for the entire key lifecycle.

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Neil Cameron