Policy on the Use of Cryptographic Controls

HITRUST CSF v11 10.f requires you to develop and implement a formal policy that governs how your organization uses cryptography to protect information, including when encryption is required, which cryptographic standards are approved, and how cryptographic keys are managed. Operationalize it by publishing enforceable requirements for data at rest/in transit, standard selections, and key lifecycle controls, then proving adoption through system configurations and evidence. ¹

Key takeaways:

• Your “policy on the use of cryptographic controls” must specify when to use cryptography, which standards are approved, and key management requirements. ¹
• Auditors will look for implementation, not just a PDF: configuration baselines, key custody, exceptions, and monitoring evidence.
• Treat cryptography as a governance control: it must bind engineering choices, third-party requirements, and procurement decisions.

A policy on the use of cryptographic controls is the document that turns “we encrypt sensitive data” into testable rules engineers can implement and auditors can verify. HITRUST CSF v11 10.f is explicit about the minimum content: define the conditions under which cryptography must be used, define the cryptographic standards you approve, and define your key management requirements. ¹

For a Compliance Officer, CCO, or GRC lead, the practical challenge is rarely choosing a cipher. It’s making sure the organization uses cryptography consistently across endpoints, applications, databases, cloud services, and third parties, while keeping keys controlled, rotated, recoverable, and auditable. Weak policy language (“should encrypt where appropriate”) fails because it can’t be enforced and it creates gaps between security intent and engineering reality.

This page gives requirement-level implementation guidance: who must follow the policy, how to write it so it drives configuration, how to embed it in SDLC and procurement, what evidence to retain, and where audits get stuck. It’s written so you can move from requirement to execution without a multi-month rewrite of your security program.

Regulatory text

Requirement (HITRUST CSF v11 10.f): “A policy on the use of cryptographic controls for protection of information shall be developed and implemented. The policy shall define the conditions under which cryptography shall be used, which cryptographic standards are approved, and key management requirements.” ¹

What the operator must do: publish a cryptographic controls policy that (1) sets decision rules for when encryption and related cryptographic mechanisms are mandatory, (2) lists approved algorithms/protocols and where they are allowed, and (3) defines key management rules across the full key lifecycle. Then make it real by implementing it through standards, configuration baselines, and enforcement points you can evidence. ¹

Plain-English interpretation (what this means in practice)

You need a written, approved set of rules that answers these questions in a way engineering and IT operations can follow:

1. When do we have to use cryptography? For example: data in transit, data at rest, backups, portable media, secrets in CI/CD, and administrative access sessions.
2. What cryptography is allowed? A controlled list of approved protocols, algorithms, modes, minimum key sizes, certificate requirements, and approved libraries/modules.
3. How do we manage keys? Who can create, store, rotate, revoke, recover, and audit keys; where keys are stored; separation of duties; and how exceptions are handled.

If you cannot point to a rule and show where it is implemented (cloud policy, DB settings, TLS configs, KMS/HSM controls, secrets manager, MDM), you will struggle to show the policy is “implemented,” even if the policy exists.

Who it applies to (entity and operational context)

Entity scope: all organizations seeking alignment with HITRUST CSF that store, process, transmit, or have administrative access to information requiring protection. ¹

Operational scope (who must follow it):

• Security and GRC (policy ownership, exceptions governance, assurance)
• Infrastructure/IT operations (endpoint encryption, backups, network encryption, certificates)
• Engineering/application teams (service-to-service TLS, storage encryption, secrets handling)
• Identity and access administration (credential storage, MFA token/seed protection)
• Procurement and third-party management (contractual crypto requirements; validation evidence)
• Incident response (crypto key compromise response and revocation actions)

Technology scope (where it shows up):

• Cloud services (KMS, storage encryption, managed databases, load balancers, service meshes)
• On-prem systems (database TDE, SAN encryption, backup appliances, HSMs)
• End-user devices (full disk encryption, removable media controls)
• CI/CD and secrets (vaults, environment variables, build pipelines, signing keys)
• Data interchange (APIs, SFTP, message queues)

What you actually need to do (step-by-step)

1) Define the policy structure so it is enforceable

Include these sections at minimum, written as “must” requirements:

• Purpose and scope: data types/systems covered; inclusion of third parties that handle your data.
• Conditions requiring cryptography: tie to your data classification and use cases (in transit, at rest, backups, portable media, admin sessions, inter-service calls, mobile).
• Approved cryptographic standards: specify approved protocols/algorithms and disallowed/legacy ones; require use of approved crypto libraries.
• Key management requirements: key ownership, storage, access control, rotation, revocation, recovery, logging, and cryptoperiod expectations (even if defined in a separate standard).
• Certificate management: issuance, validity, renewal, private key protection, certificate authority controls.
• Exceptions: risk acceptance process, compensating controls, expiration and re-validation.

Deliverable: a board/management-approved policy with a named owner and review cadence, plus linked standards/procedures that teams can implement.

2) Translate policy into crypto standards + configuration baselines

A policy is too high-level to configure systems. Create at least:

• Cryptographic Standard (technical): approved TLS versions, cipher suites posture, storage encryption requirements, hashing and signing rules, approved KMS/HSM patterns, secrets storage rules.
• Key Management Standard (technical/operational): KMS/HSM usage, IAM roles, separation of duties, break-glass access, audit logging expectations, key backup/escrow approach.
• System baselines: hardening guides for OS, database, Kubernetes, cloud services; minimum TLS for ingress/egress; encryption defaults in templates (IaC modules).

Make each standard map back to the policy section it satisfies so you can show traceability during assessment.

3) Implement enforcement points (where audits get won)

Pick enforcement points that reduce reliance on “people remembering”:

• Cloud policies: require encryption at rest on storage services; block unencrypted resources through policy-as-code or cloud governance controls.
• Certificate automation: central issuance/renewal and inventory, with ownership and alerts.
• Secrets management: prohibit secrets in source control; require a secrets manager; log access.
• Endpoint controls: enforce full disk encryption and screen lock via MDM; control removable media encryption.
• CI/CD controls: signing keys stored in KMS/HSM; pipeline checks for insecure TLS or weak crypto in dependencies.

4) Build a key management operating model

Your policy must be backed by an operating model people can follow:

• Key ownership model: application/service owners vs. platform owners; who approves key creation.
• Access model: least privilege to use keys; strict controls for key admin actions; separation of duties where feasible.
• Lifecycle procedures: how keys are generated, rotated, retired, and destroyed; how you respond to suspected compromise (revocation and re-encryption plan).
• Logging and review: ensure KMS/HSM/admin actions are logged and reviewed as part of security monitoring.

5) Extend requirements to third parties

If a third party processes or stores your data, you need contract and due diligence hooks:

• Contract clauses requiring encryption at rest/in transit, key custody expectations, and notification obligations for key compromise.
• A due diligence question set: where keys live, who controls them, whether customer-managed keys are supported, and evidence of crypto implementation.
• A documented decision on shared responsibility for encryption in SaaS/PaaS.

Daydream can help here by standardizing crypto-control evidence requests across your third-party inventory, tracking exceptions, and keeping policy-to-evidence mapping ready for audits without chasing teams by email.

6) Stand up an exceptions process that doesn’t become a loophole

Auditors look for exceptions that never expire. Require:

• written justification tied to a system and data type
• compensating controls
• a business owner sign-off and security approval
• an expiration date and re-validation trigger (for example, on major version upgrades or architecture changes)

Required evidence and artifacts to retain

Keep evidence that proves both design (the rule exists) and operating effectiveness (the rule is followed):

Policy and governance

• Approved cryptographic controls policy with version history and approver
• Linked cryptographic and key management standards
• Exception register with approvals and expirations

Inventory and implementation

• System inventory tagged for encryption requirements (or data classification mapping to systems)
• Configuration evidence: screenshots/exports showing encryption enabled (storage, DB, backups)
• TLS posture evidence: configuration files, load balancer settings, service mesh policies
• Certificate inventory and renewal records

Key management

• KMS/HSM configuration, key inventory, and IAM permissions
• Key rotation/revocation records (tickets, change logs)
• Logs for key administrative actions and evidence of review

Third-party

• Contract templates or executed clauses addressing encryption and key management
• Third-party due diligence responses and any exception approvals

Common exam/audit questions and hangups

Expect these lines of questioning:

• “Show me the policy section that requires encryption for this dataset, and show me the system setting that enforces it.”
• “Which cryptographic standards are approved, and how do teams know what to implement?” (policy vs. standard confusion is common)
• “Who can administer keys versus who can use keys?” (separation of duties and IAM clarity)
• “How do you know certificates are current and private keys are protected?”
• “How do you handle exceptions, and how many are open?”

Common hangup: the policy exists, but standards are missing, or teams use inconsistent defaults across cloud accounts and environments.

Frequent implementation mistakes (and how to avoid them)

1. Policy language that can’t be tested. Replace “where appropriate” with defined conditions tied to data classification and system types.
2. Approved standards list that’s aspirational. If engineering cannot implement it with existing platforms, you’ll create shadow exceptions. Align policy with deployable patterns (KMS, managed certs, IaC modules).
3. Key management treated as a footnote. The requirement explicitly calls out key management. Make key custody, rotation, revocation, and logging first-class.
4. No crypto asset inventory. Without a key/cert inventory, you cannot prove control or respond to compromise quickly.
5. Third-party crypto left to assumptions. Put encryption and key custody into contracts and due diligence, then retain evidence.

Enforcement context and risk implications

No public enforcement cases are provided in the source material for this requirement, so treat this as an assurance and risk control requirement rather than a case-driven mandate.

Operational risk is still direct:

• Weak or inconsistent encryption increases exposure in a breach, device loss, or backup compromise.
• Poor key management can negate encryption controls if keys are accessible, unmanaged, or unmonitored.
• Uncontrolled certificates and TLS settings increase the chance of misconfiguration and insecure connectivity.

Practical 30/60/90-day execution plan

First 30 days: establish governable requirements

• Assign policy owner, approvers, and scope (systems, data types, third parties).
• Publish the cryptographic controls policy with the three required elements: conditions, approved standards, key management requirements. ¹
• Create or refresh the exception process and register.
• Identify your enforcement points (KMS, secrets manager, certificate automation, cloud policy).

By 60 days: convert policy into enforceable standards

• Publish cryptographic and key management standards with implementable patterns.
• Build minimum configuration baselines for common platforms (cloud storage, managed DBs, endpoint encryption, ingress TLS).
• Stand up certificate inventory and ownership mapping.
• Start third-party contract addenda and due diligence questions for encryption and key custody.

By 90 days: prove implementation and close gaps

• Collect evidence for a representative set of in-scope systems: encryption at rest/in transit configs, key access controls, logging, and exception approvals.
• Remediate high-risk gaps: unencrypted backups, unmanaged keys, expired certificates, plaintext secrets.
• Operationalize ongoing monitoring: alerts for encryption drift, key admin actions, certificate expiration, and new exceptions.

Frequently Asked Questions

Do we need a separate “cryptographic standard,” or is the policy enough?

The requirement is for a policy, but audits often fail when the policy does not translate into implementable technical rules. Write the policy at the “what/when” level and publish a standard for the “how,” then show configurations that match. ¹

What counts as “conditions under which cryptography shall be used”?

Define specific scenarios tied to your data and architecture, such as encryption for data at rest in databases and object storage, encryption in transit for external and internal connections, and encryption for backups and portable media. The key is that an engineer can read it and know what to implement. ¹

How detailed should “approved cryptographic standards” be?

Detailed enough to prevent ad hoc crypto choices: name approved protocols and implementation patterns (for example, organization-approved TLS configurations and approved key storage services). Put the precise configurations in standards/baselines so teams don’t negotiate them per project. ¹

Do we need to control keys if we use a SaaS provider?

You still need key management requirements, but the implementation may be contractual and evidence-based rather than technical control. Document who controls keys (provider-managed vs. customer-managed), assess the risk, and retain due diligence and contract artifacts.

How do we handle legacy systems that can’t meet the approved standards?

Use a time-bounded exception with compensating controls, documented risk acceptance, and a remediation plan tied to a decommission or upgrade path. Auditors typically focus on whether exceptions are controlled and expiring, not whether legacy exists.

What evidence is most persuasive in a HITRUST-style assessment?

Assessors respond well to traceability: policy → standard → baseline → system configuration evidence → logs/tickets showing operations (rotation, renewals, approvals). Keep an exception register that ties each deviation to a system, owner, and expiration.

Footnotes

1. HITRUST CSF v11 Control Reference