CP-9(8): Cryptographic Protection

To meet the cp-9(8): cryptographic protection requirement, you must encrypt the information your backup program is protecting so that backups cannot be read or altered by unauthorized parties, even if the backup media, backup files, or replication channel are exposed. Operationalize this by defining what backup data is in scope, enforcing strong encryption for backup-at-rest and in-transit, and retaining proof that encryption is continuously enabled and managed.

Key takeaways:

• CP-9(8) is a backup-specific crypto requirement: protect backup data from disclosure and modification.
• Scope first: identify which backup sets, snapshots, and replicas contain sensitive data and where they live.
• Audits are won with evidence: configs, KMS/HSM settings, key rotation logs, and restore-test records showing encrypted restores.

CP-9(8) sits in the Contingency Planning family and strengthens your backup control (CP-9) by adding a clear expectation: your backups need cryptographic protection against both confidentiality and integrity failures. For operators, that means you treat backups as a high-value target, not “cold storage.” Attackers frequently go after backups to exfiltrate data, destroy evidence, or corrupt restore points to block recovery.

This page translates the requirement into a practical build plan a Compliance Officer, CCO, or GRC lead can drive with IT/Security. You’ll define scope (what backup information is covered), set encryption standards (at rest and in transit), decide where keys live (KMS/HSM vs vendor-managed), harden access paths (service accounts, immutable backups, separation of duties), and produce the evidence an assessor expects. The goal is simple: if someone steals backup media, gains access to your backup bucket, or intercepts replication traffic, they still cannot read or tamper with backup content.

Regulatory text

Requirement (verbatim): “Implement cryptographic mechanisms to prevent unauthorized disclosure and modification of {{ insert: param, cp-09.08_odp }}.” ¹

How to read the placeholder: The “{{ insert: param, cp-09.08_odp }}” is an organization-defined parameter. In practice, you must define which “information” within your backup process is in scope (for example: backup files, snapshots, database dumps, VM images, backup catalogs/indices, replication streams, and backup metadata that can expose sensitive content).

Operator obligation: You must (1) name the backup information to protect, (2) implement encryption and integrity protections appropriate to that information, and (3) be able to prove it is enforced and managed over time. ²

Plain-English interpretation

CP-9(8) requires cryptography that stops two specific outcomes for backup information:

1. Unauthorized disclosure (someone can read backup content or infer sensitive data from it).
2. Unauthorized modification (someone can alter backups, inject corrupted data, or tamper with restore points and metadata).

“Cryptographic mechanisms” typically means encryption plus integrity protection (for example, authenticated encryption modes, cryptographic checksums, or digital signatures depending on your architecture). The control is outcome-based: auditors will care less about the brand of tool and more about whether backup data is unreadable and tamper-resistant without authorized keys and permissions. ²

Who it applies to (entity and operational context)

CP-9(8) applies in environments using NIST SP 800-53 controls, including:

• Federal information systems
• Contractor systems handling federal data ¹

Operationally, it applies to teams and systems that create, move, store, or restore backups:

• Infrastructure/IT Ops running backup platforms
• Cloud platform teams managing object storage, snapshots, and replication
• Security teams owning cryptographic standards and key management
• Application owners responsible for database dumps and app-level exports
• Third parties that store or process backups (backup SaaS, managed service providers, offsite vaulting)

A practical rule: if the system is part of your backup chain (source → backup job → transport → storage → replication → restore), CP-9(8) is in play.

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

Step 1: Define the organization-defined parameter (scope statement)

Write a short scope statement that names the “information” to be protected under CP-9(8). Most teams include:

• Backup files/archives (full/incremental)
• VM/container images used for recovery
• Storage snapshots
• Replicated backup copies across regions/accounts
• Backup catalogs, indices, and job logs if they reveal file paths, filenames, database names, or secrets

Deliverable: CP-9(8) scope definition owned by the control owner and approved by Security/GRC. ¹

Step 2: Establish crypto requirements for backups at rest

Set technical requirements that engineers can implement consistently:

• Encrypt backup storage locations (object storage, backup appliances, disks, tapes, snapshot repositories).
• Prefer centrally managed keys (KMS/HSM) with access control, logging, and lifecycle management.
• Require encryption for offsite/portable media and exported backups (common audit gap).

Implementation pattern examples:

• Cloud backups: enforce bucket-level encryption and disallow unencrypted object puts via policy.
• Appliance backups: enable device encryption and restrict local key export.
• Database dumps: encrypt dumps before transfer if the pipeline might store them temporarily outside encrypted storage.

Step 3: Protect backups in transit (including replication)

Backups commonly traverse networks during:

• Backup ingestion from production to backup server
• Replication to secondary sites/regions
• Copy to immutable storage tiers
• Restore operations

Require encrypted transport (for example, TLS) for backup agents, APIs, and replication links, and verify certificate validation is not disabled.

Step 4: Address integrity and tamper resistance (modification risk)

Encryption alone may not stop destructive tampering if an attacker can delete or replace backups. CP-9(8) calls out “modification,” so include measures that make unauthorized changes detectable or preventable:

• Enable authenticated encryption or integrity checks supported by the backup product.
• Turn on immutability features where available (WORM/immutability modes) to block alteration of restore points through normal admin paths.
• Separate duties: backup admins should not be the same identities that manage encryption keys.

Your implementation should clearly explain which control(s) address “modification” in your environment and where integrity checks are validated (backup verification jobs, restore tests, hash verification, or product-native integrity validation). ²

Step 5: Lock down key management (the part auditors probe)

Document and implement:

• Key ownership (Security/KMS administrators)
• Key access model (which service accounts can decrypt backups)
• Rotation and revocation approach
• Logging and monitoring for key use

Avoid single points of failure: if a backup operator can both access encrypted backups and control keys without oversight, you have a weak story for “unauthorized disclosure.”

Step 6: Apply to third parties (backup processors and storage providers)

If a third party stores backups or runs backup infrastructure:

• Contractually require encryption at rest and in transit for your backup data.
• Confirm who holds keys (customer-managed keys are easier to defend in audits).
• Obtain evidence (attestations, configurations, or audit reports) that matches your CP-9(8) scope statement.

Step 7: Make it assessable (map owner, procedure, and recurring evidence)

Turn CP-9(8) into an operational control record:

• Control owner
• Implementation procedure
• Recurring evidence artifacts (what you collect and how often) This is specifically called out as recommended practice in your provided guidance. ¹

Practical tip: Daydream-style control mapping reduces “tribal knowledge” risk. Your assessor should see a single page that ties scope → technical enforcement → evidence.

Required evidence and artifacts to retain

Keep artifacts that prove design and ongoing operation:

Design / configuration evidence

• CP-9(8) scope definition (what backup information is protected)
• Backup architecture diagram with data flows and encryption points
• Backup tool configuration exports/screenshots showing:
  • Encryption enabled for repositories
  • Encryption settings for agents/jobs
  • Transport security settings for replication
• KMS/HSM configuration evidence:
  • Key policies (who can decrypt)
  • Key lifecycle settings (rotation/revocation approach)
  • Audit logging enabled for key access

Operational evidence

• Periodic job reports showing backups completed with encryption enabled (product-dependent)
• Storage policies that block unencrypted uploads (where applicable)
• Access logs showing who accessed backup repositories and who accessed keys
• Restore test records that demonstrate you can restore from encrypted backups (include date, system, and outcome)
• Third-party evidence (SOC reports or contract clauses) tied to backup services, if applicable

Common exam/audit questions and hangups

Expect these lines of questioning:

• “What exactly is the ‘information’ in CP-9(8) for your environment?” If you can’t answer crisply, you’ll lose time.
• “Show me where encryption is enforced, not just documented.”
• “Who can decrypt backups? How do you prevent a backup admin from self-authorizing decryption?”
• “Do you encrypt backup metadata and catalogs? If not, why is the residual risk acceptable?”
• “Do restore tests validate integrity, or only availability?”

Hangup pattern: teams say “the storage account is encrypted,” but backup exports, replication caches, or temporary staging locations are not.

Frequent implementation mistakes (and how to avoid them)

1. Undefined scope (placeholder never resolved).
   Fix: publish a CP-9(8) scope statement and align it to your backup inventory.

2. Relying on “default encryption” without enforcement controls.
   Fix: add preventive policies (for example, deny unencrypted writes) and evidence screenshots/exports.

3. Keys stored with backups or controlled by the same admins.
   Fix: separate KMS administration, restrict decrypt permissions to restore workflows, and log all key use.

4. Ignoring integrity/tamper concerns.
   Fix: enable immutability where feasible and document integrity verification steps.

5. Third-party blind spot.
   Fix: require encryption commitments in contracts and collect periodic evidence.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so treat CP-9(8) as an assessment-driven control rather than a case-law-driven one. The risk is still concrete: backup data often contains the most concentrated set of sensitive information in the environment, and attackers who can read or modify backups can force breach notification scenarios or block recovery efforts. ²

A practical 30/60/90-day execution plan

First 30 days (stabilize scope and visibility)

• Assign a CP-9(8) control owner (Security or Backup Platform owner).
• Define the CP-9(8) scope statement (resolve the placeholder).
• Inventory backup locations, replication paths, and third parties involved.
• Identify gaps: any unencrypted repositories, exports, staging servers, or replication links.
• Start an evidence register: list the screenshots/log exports you will collect and store.

Days 31–60 (implement enforcement and key controls)

• Turn on encryption at rest for all in-scope repositories, including offsite copies.
• Enforce encryption-in-transit for backup agents and replication endpoints.
• Implement key access separation: narrow decrypt permissions and require approvals for restores where feasible.
• Enable logging for backup repository access and key use; route to your central log platform.

Days 61–90 (prove operation and harden for audits)

• Run restore tests from encrypted backups and retain records.
• Validate integrity controls (immutability or verification jobs) and document outcomes.
• Close third-party evidence gaps (contract addenda, SOC evidence, config attestations).
• Finalize the control mapping: owner, procedure, recurring evidence artifacts, and review cadence. ¹

Frequently Asked Questions

What counts as “backup information” for CP-9(8)?

Define it explicitly. Common scope includes backup files, snapshots, replicas, and backup catalogs/metadata where exposure could disclose sensitive data or enable tampering. ¹

Is encryption at rest enough to satisfy “prevent modification”?

Usually not by itself. Pair encryption with integrity features such as authenticated encryption/integrity checks and operational controls like immutability and restricted admin actions to reduce unauthorized changes. ²

Do I need customer-managed keys for compliance?

CP-9(8) does not mandate a specific key ownership model in the provided text. Auditors will focus on whether key access is controlled, logged, and separated from backup admin privileges.

How do we show evidence without dumping sensitive configs into the audit package?

Export configurations with sensitive fields redacted, and supplement with screenshots showing encryption toggles, policy enforcement, and KMS key policy structure. Keep unredacted evidence in a restricted repository for on-demand review.

What about third parties that store our backups?

Treat them as part of your backup chain. Require contractual encryption at rest and in transit, confirm key management responsibilities, and retain third-party evidence that maps to your CP-9(8) scope.

Our backup tool says “encryption enabled,” but we can’t prove it historically. What will an auditor accept?

Combine current-state configuration exports with system logs (repository access, key usage logs, and job logs showing encryption status) and restore-test records that demonstrate encrypted restore operations over time.

Footnotes

1. NIST SP 800-53 Rev. 5 OSCAL JSON

2. NIST SP 800-53 Rev. 5