Overview

Security Requirements for 03.13.10 Key Management

Cryptographic key management and establishment can be performed using manual procedures or mechanisms supported by manual procedures. Organizations define key management requirements in accordance with applicable federal laws, Executive Orders, policies, directives, regulations, and standards specifying appropriate options, levels, and parameters.[SP 800-56A] and [SP 800-57-1] provide guidance on cryptographic key management and key establishment.

Assessment GuidanceExamine 0/8

How an assessor determines this requirement is met. Source: CMMC Assessment Guide – Level 2, Version 2.13 (NIST SP 800-171 Rev. 2).

Discussion

Develop processes and technical mechanisms to protect the cryptographic keys’ confidentiality, authenticity, and authorized use in accordance with industry standards and

regulations. Key management systems provide oversight, assurance, and the capability to demonstrate the cryptographic keys are created in a secure manner and protected from loss or misuse throughout their lifecycle (e.g., active, expired, revoked). For a small number of keys, this can be accomplished with manual procedures and mechanisms. As the number of keys and cryptographic units increase, automation and tool support will be required.

The first intent of this requirement is to ensure cryptographic keys are properly created in a secure manner that prevents them from being reproduced by an adversary. The second intent of this requirement is to ensure cryptographic keys are managed in a secure manner that prevents them from being stolen by an adversary. Key establishment involves the creation of keys and coordination among parties that will use the keys of the methodology for generating the final keying material. This is discussed in detail in SP 800-56A, B, and C.

Key management involves protecting keys when they are distributed, when they are stored, when they are being used, and when they are being recovered.

Key establishment best practices are identified in NIST SP 800-56A, B, and C. Key management best practices are identified in NIST SP 800-57 Parts 1, 2, and 3.

This requirement, SC.L2-3.13.10, complements AC.L2-3.1.19 by specifying that any cryptographic keys in use must be protected.

Examples

  1. Example 1

    You are a system administrator responsible for providing key management. You have generated a public-private key pair to exchange CUI [a]. You require all system administrators to read the key management policy before you allow them to install the private key on their machines [b]. No one else is allowed to know or have a copy of the private key per the policy. You provide the public key to the other parties who will be sending you CUI and test the Public Key Infrastructure (PKI) to ensure the encryption is working [a]. You set a revocation period of one year on all your certificates per organizational policy [b].

  2. Example 2

    You encrypt all of your company’s computers using the disk encryption utility built into the operating system. As you configure encryption on each device, it generates a cryptographic key. You associate each key with the correct computer in your inventory spreadsheet and restrict access to the spreadsheet to the system administrators whose work role requires them to manage the computers [b].

Assessment Methods

Examine
The process of reviewing, inspecting, observing, studying, or analyzing assessment objects (e.g., policies, procedures, plans, system designs, mechanisms) to facilitate understanding, achieve clarification, or obtain evidence.Example: An assessor reads the access control policy and inspects system configuration settings to confirm they match.

Not all of the evidence listed is required to meet this requirement — check the items your organization has collected.

Interview
The process of holding discussions with individuals or groups within an organization to facilitate understanding, achieve clarification, or identify the location of evidence.Example: An assessor asks a system administrator to describe how user accounts are approved, reviewed, and disabled.
  • System or network administrators
  • Personnel with information security responsibilities
  • Personnel with responsibilities for cryptographic key establishment and management
Test
The process of exercising assessment objects (e.g., activities, mechanisms) under specified conditions to compare actual behavior with expected behavior.Example: An assessor attempts to sign in with a disabled account to confirm that access is denied.
  • Mechanisms supporting or implementing cryptographic key establishment and management

Potential Assessment Considerations

  • Are cryptographic keys established whenever cryptography is employed (e.g., digital signatures, authentication, authorization, transport, or other cryptographic mechanisms) [a]?
  • Are cryptographic keys maintained whenever cryptography is employed (e.g., key storage, backup, recovery, revocation, destruction, etc.) [b]?

Key References

NIST SP 800-171 Rev. 2 3.13.10

Evidence

  1. 03.13.10.a

    Cryptographic keys are established whenever cryptography is employed

  1. 03.13.10.b

    Cryptographic keys are managed whenever cryptography is employed