Template draft. Replace everything in [square brackets] with your own decision,
delete what does not describe what you really do, and approve it through your own document control. It is not legal
advice and does not make an organisation compliant or certified.
1. Purpose
This procedure explains how to apply the Cryptography Policy. It sets out how a team decides whether and how to use cryptography for a given system or data flow, how products and algorithms are chosen and approved, who does what, and how cryptographic keys are created, stored, changed, recovered and destroyed so that encrypted information stays protected and also remains recoverable by the Organisation.
2. Scope
- In scope: encryption of data at rest, in transit and in backups; digital signatures; certificates and public key infrastructure; hashing of passwords and integrity values; secrets used by applications; and any cryptographic function embedded in products or developed in-house.
- In scope: all systems, devices, cloud services and suppliers that handle Organisation or customer information, and all staff who request, operate or use cryptography.
- Out of scope: the details of the key custody roles and ceremonies, which are covered in the Key Management Process, and the choice of network design, covered in the Network Security Procedure.
3. Terms and Definitions
| Term | Meaning |
|---|
| Symmetric encryption | Encryption in which the same key encrypts and decrypts the data. |
| Asymmetric encryption | Encryption or signing using a public and private key pair. |
| Key | A secret value, or the private half of a key pair, that controls a cryptographic operation. |
| Data encryption key (DEK) | A key that encrypts data directly. |
| Key encryption key (KEK) | A key that protects other keys; usually held in a hardware security module or a managed key service. |
| Certificate | A signed document that binds a public key to an identity and a validity period. |
| Key custodian | A named person who holds part of, or is responsible for, a key or its recovery material. |
| Cryptoperiod | The time span during which a key may be used for a stated purpose. |
| Compromise | Loss, theft, exposure or suspected misuse of a key or secret. |
4. Roles and Responsibilities for Encryption
| Role | Responsibilities |
|---|
| Document owner (Head of IT Security) | Maintains the approved algorithm list, approves exceptions, reviews the key register [quarterly], and reports compromises to the incident manager. |
| Information owner | States the classification and legal needs of the data and accepts the residual risk if a stronger control is not applied. |
| System owner | Applies this procedure to the system, requests keys and certificates, and keeps the key register entries current. |
| Key custodians | Hold key components or recovery credentials under dual control, take part in key ceremonies, and sign custody records. |
| IT operations and platform engineers | Implement encryption settings, rotate keys, renew certificates before expiry, and monitor failures. |
| Developers | Use approved libraries and the central secret store; never write their own algorithms or place keys in source code. |
| Procurement and supplier managers | Make sure contracts require the supplier's cryptography to meet this procedure and that exit includes key return or destruction. |
| Data protection officer | Confirms that encryption supports the safeguards required for personal data. |
| Activity | Responsible | Accountable | Consulted | Informed |
|---|
| Assess encryption requirements | System owner | Information owner | Head of IT Security | Data protection officer |
| Approve algorithms and products | Head of IT Security | Chief Information Security Officer | IT architecture | System owners |
| Generate and install keys | IT operations | System owner | Key custodians | Head of IT Security |
| Rotate keys and renew certificates | IT operations | System owner | Head of IT Security | Service desk |
| Revoke and destroy keys | Key custodians | Head of IT Security | System owner | Internal audit |
| Handle a key compromise | Head of IT Security | Chief Information Security Officer | System owner, legal | Senior management |
5. Cryptographic Controls
The Organisation uses only widely reviewed, standards-based algorithms and protocols. Proprietary or home-made schemes are not allowed. The table sets the default minimum; the Head of IT Security updates it at least [annually] and when a weakness is published.
| Use | Minimum approved standard | Not permitted |
|---|
| Symmetric encryption of data | [AES with 256-bit keys] | DES, triple DES, RC4, any scheme with keys under [128 bits] |
| Asymmetric encryption and signatures | [RSA at least 3072 bits, or elliptic curve at least 256 bits] | RSA under [2048 bits], DSA, weak or custom curves |
| Hashing for integrity | [SHA-256 or stronger] | MD5, SHA-1 for new uses |
| Password storage | [A salted, slow, memory-hard password hashing function] | Plain hashes, reversible storage, unsalted values |
| Transport security | [TLS 1.2 or higher with forward secrecy] | SSL, TLS 1.0 and 1.1, anonymous or export ciphers |
| Remote administration | [SSH protocol 2 with key or certificate authentication] | Telnet, plain file transfer, shared keys |
| Email and file exchange | [Approved encrypted transfer tool, or S/MIME or OpenPGP-based encryption] | Unencrypted attachments for Confidential or Restricted data |
| Random numbers | Cryptographically secure generator supplied by the platform | Pseudo-random functions not designed for security |
5.1 Principles
- Encrypt by default for Confidential and Restricted data wherever it is stored or travels; encryption for other levels follows the risk assessment.
- Use well-tested libraries and platform services; do not combine primitives in new ways without review by the Head of IT Security.
- Keys are separated from the data they protect, and from the administrators of that data where practicable.
- Every key and certificate has an owner, purpose, cryptoperiod and recovery plan before it enters use.
- Cryptography must be agile: systems must allow algorithms and keys to be changed without redesign.
- Use of cryptography must respect applicable law in each jurisdiction where the Organisation operates, including import, export and use restrictions; legal is consulted before cross-border deployment.
6. Determination of Encryption Requirements
A requirement assessment is done for every new system, major change, new supplier and new data flow involving Confidential or Restricted information. It is recorded on the cryptographic requirement assessment form (Annexure A) and kept with the design record.
- Describe the data and flowsThe system owner lists the data, its classification, where it is stored, and every path it travels, including backups, logs and third parties. Input: data flow diagram and classification register.
- Identify driversRecord legal, contractual and customer requirements and the findings of the latest risk assessment. For personal data, include the safeguards expected in the Data Protection and Privacy Procedure.
- Select the controlsUsing the table below, choose the encryption layer for each data location and flow. Where a layer is skipped, record the compensating control.
- Review and approveThe Head of IT Security reviews within [5 working days]. The information owner signs acceptance of any residual risk.
- Implement and verifyIT operations configure the controls; a second person checks the configuration and evidence is attached to the change record.
- Re-assessRepeat when the data, hosting, supplier or threat picture changes, and at least [annually] for Class 1 systems.
| Data location or flow | Public | Internal | Confidential | Restricted |
|---|
| Data in transit over untrusted networks | Recommended | Required | Required | Required, with mutual authentication |
| Data in transit on internal networks | No | Recommended | Required | Required |
| Databases and file stores | No | Risk based | Encryption at rest required | Encryption at rest and field-level for the most sensitive items |
| Laptops and mobile devices | Required | Required | Required | Required |
| Removable media | Risk based | Required | Required | Not permitted without approval |
| Backups and archives | Risk based | Required | Required | Required, with separate keys |
| Application secrets and credentials | n/a | Required | Required | Required, in a hardware-backed store |
| Messages and email | No | Opportunistic transport encryption | Required for external | Required end to end |
7. Product Selection
Products and services that provide cryptography must be chosen from the approved list kept by IT security. A new product is added only after the following checks.
- Define needsState the use, data classification, performance, integration, and recovery needs.
- EvaluateCheck that the product uses approved algorithms and protocols, is actively maintained, has had independent review or validation, and allows key export or escrow under Organisation control. Consider supplier viability and exit terms.
- Assess securityReview the supplier's security evidence and test the product in a lab, including failure modes such as expired certificates and lost keys.
- ApproveThe Head of IT Security approves for a stated purpose and period of [3 years]; the decision goes into the approved product list.
- ReviewRe-evaluate at renewal or when a vulnerability or end-of-support notice is received.
8. Key Management
Every key follows a lifecycle from generation to destruction. The table gives default cryptoperiods; shorter periods apply where the risk assessment demands. The Key Management Process describes custody ceremonies in detail.
| Key type | Cryptoperiod | Protection | Rotation trigger |
|---|
| Data encryption keys (databases, volumes) | [12 months] | Wrapped by a key encryption key | Schedule, suspected exposure, staff change |
| Key encryption keys and master keys | [24 months] | Hardware security module or managed key service | Schedule, custodian change, compromise |
| TLS certificates (public-facing) | [12 months or shorter as the issuer allows] | Private key on the server or load balancer, access limited | Before expiry, compromise |
| Internal certificates and code signing keys | [24 months] | Protected key store; signing by approved pipeline only | Before expiry, compromise, staff change |
| SSH keys for administrators | [12 months] | Passphrase protected, stored on a hardware token where possible | Schedule, departure, compromise |
| API keys and application secrets | [90 days] | Central secret store; not in code | Schedule, developer departure, exposure |
8.1 Key generation and distribution
- Generate keys in the protected environment of the target store, using an approved random generator; do not generate keys on personal devices.
- Never email, chat or write down keys in clear text. Distribute through the secret store, a key wrapping method, or split components delivered by separate channels.
- For master keys use a ceremony with at least [two] key custodians, witnessed and recorded in the key ceremony record (Annexure C).
- Register each key in the key register (Annexure B) at generation with owner, purpose, location, algorithm, creation and expiry dates.
8.2 Storage and change
- Store keys in hardware security modules, managed key services or dedicated encrypted vaults, separate from the data they protect.
- Access to key stores is by named role, approved in the access request tool, protected with multi-factor authentication and logged. Review membership [quarterly].
- Change keys at the end of their cryptoperiod and immediately on suspected compromise, on departure of a custodian with access, or when an algorithm is withdrawn.
- Re-encrypt data under a new key within [30 days] of rotation unless envelope encryption means only the wrapping key changes.
- Track certificate expiry; renew at least [30 days] before it ends and alert at [60 days].
8.3 Archival and recovery
- Keep retired keys in an archive, restricted to decryption, for as long as data encrypted under them must be readable, plus [1 year].
- Back up keys and recovery material to a separate, protected location under dual control. A test restore of a key and the data it protects is performed [annually].
- Recovery of a key requires approval from the system owner and the Head of IT Security, a ticket, and two custodians. Record the reason, who took part and the time.
- Where a customer or law requires access to encrypted data, the information owner and legal approve release and the decryption is performed by authorised staff only.
8.4 Revocation and destruction
- TriggerA key is revoked on compromise, suspected exposure, loss of custody, algorithm withdrawal, end of use or end of contract.
- RevokeRevoke the certificate with the issuer, remove the key from active use, and publish the revocation where applicable. Target: [4 hours] for a compromise.
- ReplaceIssue replacement keys, re-encrypt or re-sign affected data, and update dependent systems.
- DestroyWhen the archive period ends, destroy every copy using secure deletion or hardware zeroisation, witnessed by two custodians. Destruction of a key is irreversible, so confirm no data still depends on it.
- RecordUpdate the key register and file the destruction record. Evidence: signed record and system output.
9. Data Encryption Methodology
9.1 Data at rest
- Laptops and desktops: full-disk encryption with recovery keys held centrally by IT.
- Servers and virtual machines: volume encryption using keys from the key service; databases with transparent encryption plus field-level encryption for Restricted attributes such as identifiers and authentication data.
- Cloud storage: provider encryption with customer-managed keys for Confidential and Restricted data.
- Backups: encrypted before they leave the source or at the backup platform, with keys stored separately from the media.
- Mobile devices: device encryption enforced through the mobile device management tool.
9.2 Data in transit
- External connections use the approved transport protocol and certificates from a trusted issuer; certificate validation must never be turned off in code.
- Remote access, administration and file transfer between systems use encrypted protocols only.
- Where customer-facing platforms exchange Confidential data with partners, use mutual authentication or signed and encrypted payloads.
- Email gateways enforce transport encryption wherever the receiving side supports it, and block or quarantine messages that match data loss rules.
9.3 Applications and development
- Developers call approved libraries and the central secret store; keys, passwords and tokens are never stored in source code, configuration files in repositories or build logs.
- Secret scanning runs on every commit; a detected secret is treated as compromised and rotated within [24 hours].
- Tokens and sessions use signed and time-limited values. Passwords are hashed with the approved function and a unique salt.
9.4 Testing and monitoring
- Scan externally exposed services [monthly] for weak protocols, ciphers and certificates; fix findings by the severity rules in the Patch Management Procedure.
- Alert on key store access outside a change, failed decryption spikes and certificate expiry, using the Logging and Monitoring Procedure.
- Review the approved algorithm list [annually] against current guidance and plan migrations at least [12 months] before an algorithm is withdrawn.
10. Certificate Lifecycle and Key Compromise
10.1 Certificate lifecycle
- RequestThe system owner raises a request naming the host names, purpose, key type and validity. Only certificates from approved issuers are used; self-signed certificates are limited to test environments.
- IssueIT operations generates the key pair on the target system or key store and sends only the signing request to the issuer. Private keys are never emailed.
- InstallInstall, restrict access to the private key, test chain validation, and add the certificate to the inventory with its expiry date.
- MonitorExpiry is watched by an automated check. Alerts go to the owner at [60, 30 and 14 days] before expiry.
- Renew or retireRenew at least [30 days] before expiry; remove certificates for decommissioned services and revoke them.
10.2 Response to key compromise
| Step | Action | Time target |
|---|
| Report | Anyone who suspects exposure of a key, token or secret reports it to the service desk and the Head of IT Security. | [Immediately] |
| Contain | Revoke or disable the key, certificate or token; block use where it cannot be revoked at once. | [Within 4 hours] |
| Assess | Establish what the key protected, whether it was used by an unauthorised party and what data may be exposed. Open an incident if there is evidence of misuse. | [Within 1 working day] |
| Replace | Generate new keys, re-encrypt or re-sign data, and update dependent systems. | [Within 3 working days] |
| Learn | Record the cause, fix the weakness and update the key register and this procedure. | [Within 10 working days] |
11. Measures
| Measure | Target | How measured |
|---|
| Systems with a completed requirement assessment | [100 percent of Class 1] | Assessment forms against the asset register. |
| Certificates renewed before expiry | [100 percent] | Expiry report and incident tickets. |
| Keys with an owner, purpose and expiry in the register | [100 percent] | Key register audit [quarterly]. |
| Keys rotated within cryptoperiod | [95 percent] | Register compared with rotation records. |
| Public services with weak protocols or ciphers | [0] | External scan results. |
| Secrets found in code repositories | [0 open over 24 hours] | Secret scanning tool report. |
| Successful test restore of keys and encrypted backups | [Once a year] | Test record. |
12. Records and Evidence
| Record | Kept in | Retention |
|---|
| Cryptographic requirement assessments | Document management system with the design record | [Life of system plus 3 years] |
| Key register | Key management tool | [Life of key plus 3 years] |
| Key ceremony, recovery and destruction records | Evidence store | [7 years] |
| Approved algorithm and product list | Document management system | [Current plus 3 years of versions] |
| Certificate inventory and renewal tickets | Ticketing tool | [3 years] |
Annexure A: Cryptographic requirement assessment
| Field | Entry |
|---|
| System, owner and date | |
| Data and classification | |
| Legal and customer drivers | |
| Data locations and flows | |
| Encryption chosen for each | |
| Algorithm, key length and product | |
| Key owner and custodians | |
| Residual risk and accepted by | |
| Reviewed by IT security on | |
Annexure B: Key register
| Key or certificate ID | Purpose | Algorithm and length | Owner | Location | Created | Expires | Status |
|---|
| | | | | | | |
| | | | | | | |
Annexure C: Key ceremony and destruction record
| Date and time | Activity (generation, recovery, destruction) | Key ID | Custodian 1 | Custodian 2 | Witness | Outcome | Evidence reference |
|---|
| | | | | | | |
| | | | | | | |
13. Exception
Exceptions to this document are allowed only where compliance is not practicable and the risk has been assessed. A request must state what is to be excepted, why, the risk it creates, the compensating controls, and an end date no later than [6 months]. It is approved in writing by the document owner and the risk owner, recorded in the exceptions register, and reviewed at the end date. An exception does not change the document.
14. Enforcement
Compliance is monitored through internal audits, management review and routine checks by the document owner. Non-compliance is reported through the incident or non-conformity process and handled under the organisation's disciplinary procedure, and under the terms of any contract for people who are not employees. Serious or repeated non-compliance may lead to loss of access and, where the law is broken, to referral to the authorities.
15. Review
This document is reviewed at least every [12 months], and when there is a significant change to the organisation, its systems, its risks or the law, or after an incident that shows it was not effective. Each review is recorded in the revision history.
ISO/IEC 27001:2022 references
| Reference | Title |
|---|
| A.8.24 | Use of cryptography |
| A.5.14 | Information transfer |
| A.8.5 | Secure authentication |
| A.5.31 | Legal, statutory, regulatory and contractual requirements |
| A.8.12 | Data leakage prevention |