CEK · Cryptography, Encryption & Key Management

CEK-01Cloud & AI Related

Encryption and Key Management Policy and Procedures

Specification

Establish, document, approve, communicate, apply, evaluate and maintain policies and procedures for Cryptography, Encryption and Key Management. Review and update the policies and procedures at least annually or upon significant changes.

Threat coverage

Model manipulation

Data poisoning

Sensitive data disclosure

Model theft

Model/Service Failure

Insecure supply chain

Insecure apps/plugins

Denial of Service

Loss of governance

Architectural relevance

Physical infrastructure

Network

Compute

Storage

Application

Data

Lifecycle

Preparation

Data storage

Development

Not applicable

Evaluation

Not applicable

Deployment

Orchestration, AI Services supply chain, AI applications

Delivery

Operations, Maintenance, Continuous monitoring

Retirement

Archiving, Data deletion, Model disposal

Ownership / SSRM

Shared across the supply chain

Shared control ownership refers to responsibilities and activities related to LLM security that are distributed across multiple stakeholders within the AI supply chain, including the Cloud Service Provider (CSP), Model Provider (MP), Orchestrated Service Provider (OSP), Application Provider (AP), and Customer (AIC). These controls require coordinated actions, communication, and governance across all involved parties to ensure their effectiveness.

Model

Owned by the Model Provider (MP)

The model provider (MP) designs, develops, and implements the control as part of their services or products to mitigate security, privacy, or compliance risks associated with the Large Language Model (LLM). Model Providers are entities that develop, train, and distribute foundational and fine-tuned AI models for various applications. They create the underlying AI capabilities that other actors build upon. Model Providers are responsible for model architecture, training methodologies, performance characteristics, and documentation of capabilities and limitations. They operate at the foundation layer of the AI stack and may provide direct API access to their models. Examples: OpenAI (GPT, DALL-E, Whisper), Anthropic(Claude), Google(Gemini), Meta(Llama), as well as any customized model.

Orchestrated

Shared Model Provider-Orchestrated Service Provider (Shared MP-OSP)

The MP and OSP are jointly responsible and accountable for the design, development, implementation, and enforcement of the control to mitigate security, privacy, or compliance risks associated with Large Language Model (LLM)/GenAI technologies in the context of the services or products they develop and offer.

Application

Owned by the Application Provider (AP)

The Application Provider (AP) is responsible for the design, development, implementation, and enforcement of the control to mitigate security, privacy, or compliance risks associated with Large Language Model (LLM)/GenAI technologies in the context of the services or products they develop and offer. The AP is responsible and accountable for the implementation of the control within its own infrastructure/environment. If the control has downstream implications on the users/customers, the AP is responsible for enabling the customer and/or upstream partner in the implementation/configuration of the control within their risk management approach. The AP is accountable for carrying out the due diligence on its upstream providers (e.g MPs, Orchestrated Services) to verify that they implement the control as it relates to the service/product develop and offered by the AP. These providers build and offer end-user applications that leverage generative AI models for specific tasks such as content creation, chatbots, code generation, and enterprise automation. These applications are often delivered as software-as-a-service (SaaS) solutions. These providers focus on user interfaces, application logic, domain-specific functionality, and overall user experience rather than underlying model development. Example: OpenAI (GPTs,Assistants), Zapier, CustomGPT, Microsoft Copilot (integrated into Office products), Jasper (AI-driven content generation), Notion AI (AI-enhanced productivity tools), Adobe Firefly (AI-generated media), and AI-powered customer service solutions like Amazon Rufus, as well as any organization that develops its AI-based application internally.

Implementation guidelines

[All actors]
Roles/Controls/Guidelines (Baseline) before application of role context:
1. Establish and document policies and procedures for Cryptography, Encryption, and Key Management.

2. Approve the policies and procedures through formal governance processes (e.g., security committee, CISO).

3. Communicate the policies and procedures to all relevant stakeholders.

4. Apply the approved policies and procedures to all systems, services, and processes under the role’s control.

5. Evaluate the effectiveness of policy implementation using internal audits, technical reviews, and encryption control validations.

6. Review and update the policies and procedures at least annually, or when significant system, model, or regulatory changes occur.

Auditing guidelines

1. Policy Examination: Verify that the CSP has established and documented a comprehensive Cryptography, Encryption, and Key Management (CEK) policy that addresses cryptographic functions across the cloud infrastructure and service layers. Confirm that the policy covers key management systems (KMS), hardware security modules (HSMs), encryption of storage and networking layers, and tenant-specific key isolation where applicable.

2. Governance: Confirm that the CEK policy is formally approved by senior leadership and that approval records are maintained, such as entries in a policy registry, minutes from change control boards, or executive-level sign-off documents. Verify that a designated policy owner is assigned and that the CEK policy is reviewed and updated at least annually or after significant events such as the release of a new key management service, deprecation of encryption algorithms, or changes in regulatory or industry requirements.

3. Communication: Review evidence that the CEK policy has been communicated to internal operational teams such as security engineering, cloud platform operations, DevOps, and compliance. Acceptable evidence may include internal bulletins, training session records, policy acknowledgments, or documentation updates distributed across engineering teams.

4. Implementation Validation: Validate enforcement of the CEK policy by inspecting infrastructure configuration baselines, service-level encryption defaults, KMS or HSM configuration states, and CI/CD pipeline integrations. Confirm that these technical controls align with the policy’s stated objectives and reflect current implementation across services.

5. Role Assignment: Review the policy and related documentation to confirm that specific CEK responsibilities are assigned to appropriate cloud infrastructure teams, cryptographic service owners, platform security architects, and compliance leads. Ensure that each role has clearly defined accountability for key lifecycle operations and cryptographic oversight.

6. Training and Awareness: Inspect training records, knowledge base materials, and onboarding documentation to ensure that personnel responsible for CEK implementation and operations have received adequate training. Confirm that awareness programs include guidance on secure key generation, encryption management, and incident response.

7. Compliance Monitoring: Evaluate how the CSP monitors adherence to its CEK policy. Confirm the presence of automated key usage auditing, anomaly detection for unauthorized access, periodic control reviews, and policy enforcement verification through internal audits or security tooling.

8. Upstream and Downstream Dependencies: Confirm that the CSP’s CEK policy includes explicit support for downstream entities such as Application Providers (APs), Orchestrated Service Providers (OSPs), Model Providers (MPs), and AI Customers (AICs). Verify that the policy enables secure cryptographic operations by offering capabilities such as Bring Your Own Key (BYOK), Hold Your Own Key (HYOK), key separation for tenants, and support for contractual encryption guarantees when required.

From CCM:

1. Review cryptography, encryption, and key management policy and procedures and confirm that these have been approved by appropriate management.
2. Confirm that the policy and procedures are reviewed at least annually.

Standards mappings

ISO 42001Partial Gap

No Mapping for ISO 42001
27001: Annex A Control A.8.24
27001: A.8.24

Addendum

ISO/IEC 42001:2023 should introduce a new control for cryptography, encryption, and key management in AI systems, mandating policy lifecycle (establish, document, approve, communicate, apply, evaluate, maintain) and annual reviews, aligning with ISO 27001 & ISO 27002

EU AI ActPartial Gap

Article 17

Addendum

Policies and procedures specific to cryptography, encryption and key management. Frequency of review and update of policies and procedures.

NIST AI 600-1Full Gap

No Mapping

Addendum

No (implicit/explicit) reference to cryptography, encryption, or key management is made in the NIST AI 600-1 standard, let alone to the definition and implementation of policies and procedures in such domain.

BSI AIC4No Gap

CRY-01
CRY-04

Addendum

N/A

AI-CAIQ questions (2)

CEK-01.1

Are cryptography, encryption, and key management policies and procedures established, documented, approved, communicated, applied, evaluated, and maintained?

CEK-01.2

Are cryptography, encryption, and key management policies and procedures reviewed and updated at least annually or upon significant changes?