If you use encryption, you need a real process for creating, storing, rotating, and retiring the keys.
What it actually means
Encryption is only as strong as its key management. Establish and manage cryptographic keys: generate them properly, store them securely, control who can access them, and rotate or retire them. For small shops this often means leaning on managed services — your cloud KMS, BitLocker or FileVault recovery-key escrow — and documenting how keys are handled.
Pass or fail — an assessor needs a "yes" to each
- Do you have a documented process for generating, storing, and rotating keys?
- Is access to keys restricted to authorized admins?
What to have ready
- Key-management procedure, or your KMS configuration
- Evidence of key storage protection and access restriction
Where teams trip up
- Encryption keys or recovery keys stored in plaintext next to the data
- No rotation or ownership defined
See where this control puts your score
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More in System & Communications Protection (3.13)
3.13.1 — Protect your boundaries3.13.2 — Build security in by design3.13.3 — Separate user and admin functions3.13.4 — Stop data leaking through shared resources3.13.5 — Wall off your public-facing systems3.13.6 — Deny all, permit by exception3.13.7 — Block split tunneling on VPNs3.13.8 — Encrypt CUI in transit3.13.9 — Drop idle network sessions3.13.11 — FIPS-validated cryptography3.13.12 — Control cameras and microphones3.13.13 — Control mobile code3.13.14 — Control and monitor VoIP3.13.15 — Protect session authenticity3.13.16 — Encrypt CUI at rest