Cryptographic Key Lifecycle Management Procedure (OP-PROC-001)

1. Purpose

To provide the technical steps for the secure generation, distribution, storage, rotation, and destruction of cryptographic keys.

2. Scope

This procedure applies to all cryptographic keys used to protect company and customer data, including keys used for data at rest and data in transit encryption. It applies to all personnel involved in the management of cryptographic keys.

3. Overview

This procedure outlines the secure lifecycle management of cryptographic keys, from generation to destruction. It ensures that all cryptographic keys are handled in a secure manner, using approved hardware security modules (HSMs) and secure channels, with all actions logged for audit purposes.

4. Procedure

4.1 Key Generation

Step	Who	What
1	Security Engineering Team	Generate cryptographic keys using the company’s approved Hardware Security Module (HSM) to ensure randomness and security.
2	Security Engineering Team	Ensure key strength meets the requirements defined in the Encryption and Key Management Policy (e.g., AES-256 or stronger).
3	Security Engineering Team	Log the generation event in the key management system, including the key identifier, generation time, and responsible personnel.

4.2 Key Distribution

Step	Who	What
1	Security Engineering Team	Distribute keys to systems or services requiring them using secure, encrypted channels (e.g., TLS-protected connections).
2	Security Engineering Team	Never transmit keys in plaintext or through insecure methods like email.
3	Security Engineering Team	Log the distribution event, noting the recipient system/service and timestamp.

4.3 Key Storage

Step	Who	What
1	Security Engineering Team	Store all cryptographic keys in the approved Hardware Security Module (HSM) or a secure, encrypted key vault.
2	Security Engineering Team	Implement strict access controls to the key storage system, limiting access to authorized personnel only.
3	Security Engineering Team	Ensure that key storage systems are physically and logically secured and monitored.

4.4 Key Rotation

Step	Who	What
1	Security Engineering Team	Rotate cryptographic keys at least annually, or more frequently if mandated by policy or regulation.
2	Security Engineering Team	Generate a new key and securely distribute it to all relevant systems.
3	Security Engineering Team	Deactivate the old key but retain it in a secure state for a defined period to decrypt previously encrypted data if required.
4	Security Engineering Team	Log the rotation event, including the identifiers for both the old and new keys.

4.5 Key Destruction

Step	Who	What
1	Security Engineering Team	When a key is no longer required and its retention period has expired, securely destroy it using the key management system’s functions.
2	Security Engineering Team	Ensure the destruction process is irreversible (e.g., cryptographic erasure).
3	Security Engineering Team	Log the destruction event, including the key identifier and destruction timestamp.

5. Standards Compliance

This section maps the procedure steps to specific controls from relevant information security standards.

Procedure Step(s)	Standard/Framework	Control Reference
4.1-4.5	SOC 2	CC6.1, CC6.8
4.1-4.5	HIPAA Security Rule	45 CFR § 164.312(a)(2)(iv)
4.1-4.5	HIPAA Security Rule	45 CFR § 164.312(e)(2)(ii)

6. Artifact(s)

An auditable log entry in the key management system for every lifecycle action (generation, distribution, storage, rotation, destruction).

7. Definitions

HSM (Hardware Security Module): A physical computing device that safeguards and manages digital keys for strong authentication and provides cryptoprocessing.

Key Lifecycle: The complete process of managing a cryptographic key from its creation through to its eventual destruction.

8. Responsibilities

Role	Responsibility
Security Engineering Team	Responsible for executing all phases of the key lifecycle management procedure.
Security Officer	Responsible for overseeing the key management program and ensuring compliance.