Encryption and Key Management Policy (OP-POL-001)

1. Objective

The objective of this policy is to establish practical requirements for implementing encryption and key management using cloud-native services and automated tools at [Company Name]. This policy ensures that sensitive information, particularly electronic Protected Health Information (ePHI), is protected through appropriate cloud-managed encryption technologies while maintaining compliance with HIPAA, HITECH, and SOC 2 requirements in a cost-effective manner.

2. Scope

This policy applies to all [Company Name] workforce members, contractors, and third parties who handle, process, store, or transmit encrypted information. It encompasses all cloud-based information systems, applications, and data storage containing sensitive data. This policy covers cloud-native encryption services, automated key management, and data protection across cloud platforms including AWS, Azure, and Google Cloud Platform.

3. Policy

  • [Company Name] shall implement cloud-native encryption controls to protect the confidentiality, integrity, and authenticity of sensitive information using automated, managed services that reduce operational complexity while maintaining security and compliance.

3.1 Cloud-Native Encryption Requirements

Encryption shall be implemented using cloud provider managed services for all sensitive information based on data classification levels and regulatory requirements.

3.1.1 Mandatory Encryption Implementations

The following data types and scenarios require encryption using cloud-managed services:

3.1.1.1 Electronic Protected Health Information (ePHI) Encryption

At Rest: AWS S3 Server-Side Encryption, Azure Storage Service Encryption, or GCP encryption at rest using AES-256 shall be implemented for all ePHI storage. In Transit: TLS 1.2 or higher automatically managed by cloud load balancers and API gateways shall be implemented for all ePHI transmission. Database: AWS RDS/Aurora encryption, Azure SQL Database Transparent Data Encryption, or GCP Cloud SQL encryption shall be implemented for all databases containing ePHI.

3.1.1.2 Application and System Data Encryption

Application Secrets: AWS Secrets Manager, Azure Key Vault, or GCP Secret Manager shall be used for API keys, passwords, and connection strings. Configuration Data: Cloud-native parameter stores with automatic encryption (AWS Systems Manager Parameter Store, Azure App Configuration) shall be implemented. File Storage: Automatic encryption for cloud file storage (AWS EFS, Azure Files, GCP Filestore) shall be enabled. Backup and Archives: Cloud backup services with automatic encryption (AWS Backup, Azure Backup, GCP Cloud Storage) shall be implemented.

3.1.2 Cloud-Native Encryption Standards

Only cloud provider default encryption implementations and approved algorithms shall be used:

3.1.2.1 Approved Cloud Encryption Services

AWS: KMS-managed keys, S3 encryption, RDS encryption, EBS encryption shall be implemented. Azure: Key Vault, Storage Service Encryption, SQL Database TDE, Disk Encryption shall be implemented. GCP: Cloud KMS, default encryption at rest, Cloud SQL encryption shall be implemented.

3.1.2.2 Approved Algorithms

AES-256 for symmetric encryption (cloud provider default) shall be used. RSA-3072 or ECC-256 for asymmetric encryption (cloud provider managed) shall be implemented. SHA-256 for hashing and digital signatures (cloud provider managed) shall be used.

3.1.2.3 Prohibited Implementations

Custom encryption implementations without Security Officer approval shall be prohibited. Encryption using deprecated algorithms (DES, 3DES, MD5, SHA-1) shall be prohibited. Unmanaged encryption keys or self-implemented key management shall be prohibited. SSL/TLS versions below 1.2 shall be prohibited.

3.2 Cloud-Managed Key Management

Cryptographic keys shall be managed using cloud provider key management services with automated lifecycle management and minimal manual intervention.

3.2.1 Key Management Principles
3.2.1.1 Cloud-Native Implementation

Cloud provider key management services (AWS KMS, Azure Key Vault, GCP Cloud KMS) shall be used as the primary key management solution.

3.2.1.2 Customer-Managed Encryption Keys

Customer-Managed Encryption Keys (CMEK) shall be implemented for ePHI and sensitive data to maintain control over encryption keys.

3.2.1.3 Automated Lifecycle Management

Automatic key rotation, backup, and lifecycle management provided by cloud services shall be leveraged.

3.2.1.4 Access Control

Key access shall be restricted using cloud IAM policies and service-specific permissions according to least privilege principles.

3.2.2 Cloud Key Management Implementation
3.2.2.1 AWS Key Management Service Implementation

AWS-managed keys shall be used for standard encryption requirements. Customer-Managed Keys (CMK) shall be implemented for ePHI and sensitive data. Automatic key rotation shall be enabled where supported. Cross-region key replication shall be configured for disaster recovery.

3.2.2.2 Azure Key Vault Implementation

Azure-managed keys shall be used for standard encryption requirements. Customer-managed keys shall be implemented for ePHI and sensitive data. Key auto-rotation and versioning shall be enabled. Geo-redundant backup shall be configured for key availability.

3.2.2.3 Google Cloud Key Management Service Implementation

Google-managed encryption keys shall be used for standard requirements. Customer-managed encryption keys (CMEK) shall be implemented for sensitive data. Automatic key rotation and version management shall be enabled. Multi-region key replication shall be configured for availability.

3.2.3 Access Control and Monitoring
3.2.3.1 IAM Integration

Key access shall be controlled through cloud IAM roles and policies.

3.2.3.2 Multi-Factor Authentication

Multi-factor authentication shall be required for key management console access.

3.2.3.3 Automated Monitoring

Cloud-native monitoring and alerting for key usage, access, and lifecycle events shall be implemented.

3.2.3.4 Audit Logging

Automatic audit trail through cloud logging services (CloudTrail, Azure Monitor, Cloud Audit Logs) shall be maintained.

3.2.4 Cloud-Native Key Management Implementation
  • Cloud Key Management Service Setup:
    • AWS KMS shall be configured for primary cloud environment with customer-managed keys (CMK) for ePHI and sensitive data encryption with automatic key rotation enabled
    • Azure Key Vault shall be configured for multi-cloud environments with customer-managed keys, appropriate access policies, and soft-delete protection enabled
    • GCP Cloud KMS shall be configured for GCP workloads with customer-managed encryption keys (CMEK), appropriate IAM bindings, and automatic rotation schedules
    • Key usage policies, access controls, and rotation schedules shall be defined and approved to meet HIPAA and HITRUST requirements
  • Automated Key Generation and Management:
    • Infrastructure as Code (IaC) shall define key management resources using Terraform, CloudFormation, or ARM templates including key policies, rotation schedules, and access controls in version-controlled infrastructure code
    • Applications shall be configured to use cloud key management APIs for encryption operations with proper error handling and fallback mechanisms for service unavailability
    • Cross-region key replication shall be configured for disaster recovery ensuring replicated keys maintain the same access policies and rotation schedules as primary keys
    • Automatic key rotation shall be enabled for supported key types with application logic implemented to handle key rotation events without service interruption
  • Application-Level Encryption Integration:
    • Cloud provider SDKs and APIs shall be integrated for encryption operations within applications using envelope encryption patterns for large data objects and direct encryption for smaller data elements
    • Database systems shall be configured to use cloud-managed transparent data encryption (TDE) with customer-managed keys ensuring ePHI database fields use appropriate encryption methods
    • Cloud storage services shall be configured to use customer-managed keys for automatic encryption at rest including all storage tiers for backup and archive storage
    • Applications shall retrieve encryption keys and secrets from cloud secret management services rather than embedded credentials
  • Monitoring and Compliance Automation:
    • Comprehensive audit logging shall be enabled for all key management operations using cloud provider audit services with log retention according to compliance requirements
    • Automated monitoring and alerting shall be configured for key usage anomalies, failed encryption operations, and unauthorized access attempts with integration to existing security monitoring systems
    • Automated compliance reporting shall be established for key management activities with monthly reports on key usage, rotation status, and access patterns for audit and compliance purposes
    • Key management service performance and latency impact shall be monitored with automated scaling and failover mechanisms for high-availability operations
  • Key Recovery and Disaster Response:
    • Automated backup of key metadata and access policies shall be configured to secure storage with cross-region replication for disaster recovery scenarios
    • Key recovery procedures shall be documented and tested for disaster scenarios ensuring recovery procedures can restore key access within [Timeframe, e.g., 4 hours] to meet business continuity requirements
    • Emergency access procedures shall be configured for key management services during outages with break-glass access controls that maintain audit trails and security controls
    • Quarterly testing of key management service failover and recovery procedures shall be conducted with documented results and procedure updates based on findings
  • Cost Optimization and Management:
    • Key management service usage and costs shall be monitored through cloud billing and cost management tools with identification of cost optimization opportunities through efficient key usage patterns
    • Appropriate caching strategies shall be implemented for key operations to reduce API call costs while maintaining security including data encryption keys (DEK) caching for high-volume operations
    • Key management service tiers and features shall be reviewed and optimized based on actual usage patterns and security requirements eliminating unused or redundant features
    • Automated lifecycle management shall be implemented for unused or expired keys with automatic deletion schedules for development and testing environments while preserving production keys according to retention policies

3.3 Application and Development Encryption

Encryption shall be integrated into application development using cloud-native services and secure coding practices.

3.3.1 Application-Level Encryption
3.3.1.1 Secrets Management

Cloud secrets management services (AWS Secrets Manager, Azure Key Vault, GCP Secret Manager) shall be used for application credentials.

3.3.1.2 API Security

TLS termination at cloud load balancers with automatic certificate management shall be implemented.

3.3.1.3 Data Processing

Cloud encryption APIs shall be used for data processing and storage operations.

3.3.1.4 Container Security

Encryption for container orchestration platforms (EKS, AKS, GKE) using cloud-managed keys shall be enabled.

3.3.2 Development and Deployment
3.3.2.1 Infrastructure as Code

Encryption configurations shall be defined in infrastructure code (Terraform, CloudFormation, ARM templates).

3.3.2.2 CI/CD Integration

Encryption validation and configuration checks shall be implemented in automated deployment pipelines.

3.3.2.3 Environment Parity

Encryption configurations shall be consistent across development, staging, and production environments.

3.3.2.4 Security Scanning

Cloud security scanning tools shall be used to validate encryption implementations.

3.4 Performance and Cost Optimization

Cloud-native encryption implementations shall be optimized for performance and cost-effectiveness.

3.4.1 Performance Optimization
3.4.1.1 Default Encryption

Cloud provider default encryption that provides minimal performance impact shall be leveraged.

3.4.1.2 Regional Deployment

Encryption services shall be deployed in regions close to data and applications to minimize latency.

3.4.1.3 Caching

Appropriate caching strategies for encrypted data and key operations shall be implemented.

3.4.1.4 Auto-Scaling

Cloud auto-scaling features shall be used to handle encryption processing loads.

3.4.2 Cost Management
3.4.2.1 Service Tier Selection

Appropriate cloud encryption service tiers shall be chosen based on usage requirements.

3.4.2.2 Key Usage Optimization

Key usage patterns shall be optimized to minimize cloud KMS API charges.

3.4.2.3 Storage Class Selection

Appropriate cloud storage classes for encrypted backup and archive data shall be used.

3.4.2.4 Regular Review

Quarterly reviews of encryption service costs and optimization opportunities shall be conducted.

4. Standards Compliance

See Annex: Control Mapping

5. Definitions

See Annex: Glossary

6. Responsibilities

Role Responsibility
Security Officer Develop cloud encryption strategies, approve service configurations, and ensure compliance with cryptographic standards.
Cloud Engineering Team Configure and deploy cloud-native encryption services according to approved standards and security requirements.
DevOps Team Integrate encryption validation into CI/CD pipelines and maintain secure application secret management.
Development Team Implement encryption requirements in application code using cloud encryption APIs and best practices.
IT Operations Team Manage cloud encryption service accounts, access controls, and cost optimization strategies.
Compliance Team Provide audit support and ensure encryption practices meet regulatory requirements.