Below is a comprehensive draft of the Encryption & Key Management Policy. Please review and let me know if you need any additional details or modifications.

Encryption & Key Management Policy

Document Version & Control

  • Version: 1.0
  • Last Review Date: 6 Jan 2025
  • Next Review Date: [12 months from last review or upon significant changes]
  • Approver: CTO, DPO

Purpose & Scope
The Encryption & Key Management Policy defines the requirements for encrypting data at rest and in transit, as well as the secure generation, distribution, storage, rotation, and retirement of cryptographic keys. It applies to all systems, applications, and services where encryption is required, including AWS, Digital Ocean, and any integrated third-party services.

This policy ensures protection of sensitive client and applicant data, maintains confidentiality and integrity, and supports compliance with applicable regulations (e.g., PDPA, GDPR) and industry standards (ISO 27001, SOC 2).

Compliance & References

  • Standards & Frameworks:
    • ISO 27001: A.10 (Cryptography), A.8 (Asset management), A.12 (Operations security)
    • NIST SP 800-57 (Key Management), NIST SP 800-52 (Transport Layer Security)
    • SOC 2 (Security, Confidentiality)
  • Regulations: PDPA (Singapore), GDPR (if applicable)
  • Related Internal Policies:
    • Information Security Policy
    • Data Management & Database Policies
    • Authentication & Access Control Policy
    • Incident Response & Breach Notification Policy

Roles & Responsibilities

  • CTO: Ensures appropriate technical controls are in place, oversees implementation of key management solutions.
  • DPO: Ensures compliance with regulatory standards and alignment with overall security strategy.
  • Head of Engineering / DevOps Team: Implements and maintains encryption solutions, manages key material according to policy.
  • Database Administrators / System Administrators: Handle day-to-day key use within applications, adhere to rotation and storage guidelines.
  • Internal Audit / Compliance Team: Periodically reviews compliance with encryption and key management requirements.

Encryption Requirements

  1. Data Classification & Encryption:
    • All sensitive or confidential data must be encrypted at rest and in transit.
    • Classification of data (as defined in the Information Security Policy) determines the required encryption strength and methods.
    • Public or non-sensitive data may be exempted from encryption requirements if documented and approved by the DPO.
  2. Encryption At Rest:
    • Store production data using industry-standard encryption algorithms (e.g., AES-256) on AWS, Digital Ocean, and on-premise storage (if applicable).
    • Leverage AWS Key Management Service (KMS) or equivalent managed encryption solutions for centralized key management and auditability.
    • Encryption must be enabled at the database, filesystem, or storage volume level, depending on the use case.
  3. Encryption In Transit:
    • Enforce TLS 1.2 or higher for all external and internal data transmissions.
    • Use robust cipher suites and disable weak or deprecated ciphers.
    • Ensure API calls, third-party integrations, and user interfaces (e.g., web portals) use HTTPS/TLS by default.

Key Management Requirements

  1. Key Generation & Quality:
    • Generate cryptographic keys using NIST-approved algorithms and secure random number generators.
    • Never use default, vendor-supplied, or weak keys.
    • Document and track all generated keys in a secure key inventory.
  2. Key Storage & Protection:
    • Store encryption keys in a secure, access-controlled environment (e.g., AWS KMS, Hardware Security Module (HSM), or a secure key vault solution).
    • Restrict key access to authorized personnel and services based on the principle of least privilege, as outlined in the Authentication & Access Control Policy.
    • Keys must never be stored in source code repositories, configuration files, or logged in plaintext.
  3. Key Distribution & Access Control:
    • Distribute keys only through secured and authenticated channels.
    • Implement strict role-based access controls for key access, granting permissions only to roles that require encryption/decryption capabilities.
    • Log and audit all key access events (refer to Logging & Monitoring Policies).
  4. Key Rotation & Lifecycle Management:
    • Rotate encryption keys at least annually or more frequently if required by regulations, risk assessments, or client contracts.
    • Keys suspected of compromise must be replaced immediately.
    • Retire and securely destroy old keys once new keys are fully deployed and all encrypted data is re-keyed or no longer needed.
  5. Key Backup & Recovery:
    • Maintain secure, encrypted backups of master keys to ensure continuity in the event of system failure.
    • Store key backups separately from operational keys and restrict access using multi-factor authentication.
    • Test key recovery procedures annually as part of business continuity and disaster recovery drills.

Monitoring, Auditing & Incident Response

  1. Logging & Auditing of Key Events:
    • Monitor and log all key lifecycle events (generation, rotation, distribution, revocation, and destruction).
    • Maintain audit trails for at least the retention period specified in Logging & Audit Trail Policies.
    • Periodically review logs to detect suspicious activity (unauthorized key access, unexpected decryption attempts, etc.).
  2. Non-Repudiation & Accountability:
    • Ensure that any key management actions are attributable to specific individuals or processes.
    • Regularly review access control lists and remove unauthorized or unnecessary key access.
  3. Incident Response:
    • In the event of a suspected key compromise (e.g., leaked key, malicious use, unauthorized access), follow the Incident Response & Breach Notification Policy.
    • Contain the incident by revoking and rotating compromised keys.
    • Notify affected clients and regulatory authorities as required by applicable laws and contractual obligations.

Compliance & Audit

  • Regulatory Compliance:
    • Adhere to PDPA (Singapore) and GDPR (where applicable).
    • Stay informed about evolving encryption and privacy standards and update the policy as needed.
  • Internal & External Audits:
    • Cooperate with auditors to verify that encryption and key management controls meet industry and regulatory standards.
    • Remediate audit findings promptly.
  • Exception Management:
    • Any exceptions to this policy (e.g., use of non-standard encryption methods) must be documented, reviewed, and approved by the DPO and CTO through a formal exception request process.

Training & Awareness

  • Employee Training:
    • Provide periodic training for relevant personnel (DevOps, DBAs, Security Team) on proper key handling procedures.
    • Include encryption basics in general security awareness training so all employees understand why encryption is critical.

Policy Review & Maintenance

  • Review Cycle:
    • Review this policy at least annually or after major regulatory, business, or technological changes.
    • Update processes, tools, and controls based on lessons learned from incidents, audits, and emerging best practices.

End of Document

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