CRY-09: Cryptographic Key Management

There is no evidence of a capability to facilitate cryptographic key management controls to protect the confidentiality, integrity and availability of keys.

C|P-CMM1 is N/A, since a structured process is required to facilitate cryptographic key management controls to protect the confidentiality, integrity and availability of keys.

Cryptographic Protections (CRY) efforts are requirements-driven and governed at a local/regional level, but are not consistent across the organization. CMM Level 2 control maturity would reasonably expect all, or at least most, the following criteria to exist:

• Cryptographic management is decentralized (e.g., a localized/regionalized function) and uses non-standardized methods to implement secure, resilient and compliant practices.
• IT/cybersecurity personnel identify cybersecurity and data protection controls that are appropriate to address applicable statutory, regulatory and contractual requirements for cryptographic management.
• Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage.
• Decentralized technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage.
• Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards.
• The IT infrastructure team provides customers with appropriate key management guidance whenever cryptographic keys are shared.

Cryptographic Protections (CRY) efforts are standardized across the organization and centrally managed, where technically feasible, to ensure consistency. CMM Level 3 control maturity would reasonably expect all, or at least most, the following criteria to exist: o Implements Public Key Infrastructure (PKI) key management controls to protect the confidentiality, integrity and availability of keys. o Implements and maintains an internal PKI infrastructure or obtains PKI services from a reputable PKI service provider.

• The Chief Information Security Officer (CISO), or similar function with technical competence to address cybersecurity concerns, analyzes the organization's business strategy to determine prioritized and authoritative guidance for cryptographic protections.
• The CISO, or similar function, develops a security-focused Concept of Operations (CONOPS) that documents management, operational and technical measures for cryptographic protections.
• A Governance, Risk & Compliance (GRC) function, or similar function, provides governance oversight for the implementation of applicable statutory, regulatory and contractual cybersecurity and data protection controls to protect the confidentiality, integrity, availability and safety of the organization's applications, systems, services and data using cryptographic protections.
• A steering committee is formally established to provide executive oversight of the cybersecurity and data privacy program, including cryptographic protections.
• Data classification and handling criteria govern requirements to encrypt sensitive/regulated data during transmission and in storage.
• Centrally-managed technologies implement cryptographic mechanisms on endpoints to control how sensitive/regulated data is encrypted during transmission and in storage.
• Certificate management is centrally-managed and the use of certificates is monitored.
• Cryptographic keys are proactively managed to protect the Confidentiality, Integrity and Availability (CIA) of cryptographic capabilities.
• Systems, applications and services that store, process or transmit sensitive/regulated data use cryptographic mechanisms to prevent unauthorized disclosure of information as an alternate to physical safeguards.
• An IT infrastructure team, or similar function:
• IT/cybersecurity personnel perform an annual review of deployed cryptographic cipher suites and protocols to identify and replace weak cryptographic cipher suites and protocols.

Cryptographic Protections (CRY) efforts are metrics driven and provide sufficient management insight (based on a quantitative understanding of process capabilities) to predict optimal performance, ensure continued operations and identify areas for improvement. In addition to CMM Level 3 criteria, CMM Level 4 control maturity would reasonably expect all, or at least most, the following criteria to exist:

• Metrics reporting includes quantitative analysis of Key Performance Indicators (KPIs).
• Metrics reporting includes quantitative analysis of Key Risk Indicators (KRIs).
• Scope of metrics, KPIs and KRIs covers organization-wide cybersecurity and data protection controls, including functions performed by third-parties.
• Organizational leadership maintains a formal process to objectively review and respond to metrics, KPIs and KRIs (e.g., monthly or quarterly review).
• Based on metrics analysis, process improvement recommendations are submitted for review and are handled in accordance with change control processes.
• Both business and technical stakeholders are involved in reviewing and approving proposed changes.

See C|P-CMM4. There are no defined C|P-CMM5 criteria, since it is reasonable to assume a continuously-improving process is not necessary to facilitate cryptographic key management controls to protect the confidentiality, integrity and availability of keys.