CEK Roles and Responsibilities
Specification
Define and implement cryptographic, encryption and key management roles and responsibilities.
Threat coverage
Architectural relevance
Lifecycle
Data curation, Data storage, Team and expertise
Not applicable
Not applicable
Orchestration, AI Services supply chain, AI applications
Maintenance, Continuous monitoring, Continuous improvement
Archiving, Data deletion, Model disposal
Ownership / SSRM
PI
Shared Cloud Service Provider-Model Provider (Shared CSP-MP)
The CSP and MP 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.
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 Orchestrated Service Provider-Application Provider (Shared OSP-AP)
The OSP and AP 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
Auditing guidelines
1. Verify that CSP roles and responsibilities are defined in formal policies and procedures for cryptographic, encryption, and key management operations (e.g., KMS operation, encryption enforcement, incident response). 2. Confirm that AI-specific responsibilities are defined in alignment with the CSP’s role (e.g., managing tenant-specific encryption for AI services, enabling secure LLM API integrations, enforcing cryptographic isolation in multi-tenant environments) and that role assignments are documented and maintained. 3. Review documentation to confirm that responsibilities are mapped to designated roles or teams (e.g., KMS administrators, cloud infrastructure engineering, platform security). 4. Validate that responsibilities related to AI workloads and encryption isolation (e.g., BYOK/HYOK setup, data segregation for GenAI tenants) are assigned to personnel responsible for customer-facing or shared services. 5. Verify that segregation of duties is enforced between teams responsible for key generation, encryption enforcement, and operational support of AI workloads. 6. Confirm that staff assigned to responsibilities have received training on cryptographic best practices, infrastructure-level controls, and AI-specific encryption challenges. 7. Verify that role assignments are reviewed at least annually or upon major changes to cryptographic infrastructure, platform capabilities, or AI service offerings. 8. Confirm that governance structures oversee role assignment and periodically assess alignment with cryptographic risk posture, regulatory expectations, and cloud service architecture. 9. Validate that continuity and succession plans are in place, with alternate personnel trained to perform functions in the event of absence or turnover. 10. Verify that responsibilities include coordination with upstream cryptographic services and downstream tenants (e.g., APs, OSPs, AICs), ensuring that encryption services support secure key provisioning, tenant isolation, and shared control models (e.g., BYOK). From CCM: 1. Obtain cryptographic, encryption policy, and key management procedures. 2. Verify, by interviews or otherwise, that employees and stakeholders are aware of their roles and responsibilities, and obtain supporting documentation evidencing that the responsibilities are being managed in-line with policy and procedures.
Standards mappings
No Mapping for ISO 42001 ISO 27002: 5.2 8.24
Addendum
ISO/IEC 42001:2023 should introduce a control to define and implement roles and responsibilities for cryptography, encryption, and key management in AI systems, specifying duties for policy oversight, key lifecycle management, and incident response. Ensure accountability through documented assignments and annual reviews, enhancing security in AI contexts while aligning with ISO 27002 (5.2, 8.24). This addresses the gap in AI-specific cryptographic governance.
Article 17
Addendum
Cryptographic, encryption, and key management roles and responsibilities.
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 roles and responsibilities in such domain.
CRY-04 CRY-04
Addendum
N/A
AI-CAIQ questions (1)
Are cryptography, encryption, and key management roles and responsibilities defined and implemented?