3.5.1.3 Disk-level encryption key management
If disk-level or partition-level encryption is used, cryptographic keys are managed in accordance with Requirements 3.6 and 3.7.
5
artefacts
0
held by a system
2
at each review
hard
to go live
Policy repository / GRC workspace
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- HSM or KMS evidence · Key management / PKI
- Audit log review · Key management / PKI
governing documentDocuments that govern the control
- Key custodian assignments · Policy repository / GRC workspace
- Key storage and rotation procedures · Policy repository / GRC workspace
- Access control to keys · Policy repository / GRC workspace
First move
This control is evidenced by people and documents, not systems. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date. Do not try to automate it.
Common gaps auditors find
- Keys stored alongside data
- No documented custody
- Missing rotation evidence
Do this for your whole sheet
Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.
Build my evidence sheet3.5.1.2 Disk-level encryption with logical access controls · 3.6.1 Procedures are defined and implemented to protect cryptographic keys used to protect stored account data against disclosure and misuse that include: • Access to keys is restricted to the fewest number of custodians necessary.