3.7.6 Manual cleartext key operations use split knowledge
Where manual cleartext key management operations are performed, they use split knowledge and dual control.
5
artefacts
1
held by a system
2
at each review
hard
to go live
Document repository
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
- Video or witness logs · SIEM / log platform
periodic reviewEvidence produced at each review
- Two-custodian sign-off forms · Document repository
- Split component custody records · Document repository
governing documentDocuments that govern the control
- Key ceremony script and recordings · Document repository
- Procedure document · Policy repository / GRC workspace
First move
Mostly documents and reviews. Pull the 1 system-held artefact from your SIEM / log platform on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.
Common gaps auditors find
- Single custodian handles key
- No ceremony documentation
- Split components stored together
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 sheet3.7.5 Retirement or replacement of keys · 3.7.7 Prevent unauthorised substitution of keys