SOC 2 Control Implementation Guide

Security Architecture

Encryption and Key Management for SOC 2

Sensitive data, telemetry, logs, backups, administrative sessions, secrets, and keys are protected through approved encryption and key-management controls.

Use this guide to put the control into operation, decide what records to retain, and check that an auditor can trace the evidence back to the work your team performed.

Maintained by GreenHat Security · Reviewed August 21, 2026

What this control should accomplish

Sensitive data is encrypted across storage and transmission paths, while access to keys and cryptographic administration remains narrower than access to the protected data.

First SOC 2 program

A credible starting point

Use managed encryption for databases, object stores, disks, logs, and backups; require modern transport encryption at public and administrative boundaries; store secrets separately; and limit key administration to a small group outside ordinary application access.

As the company scales

Make it repeatable

Maintain a cryptographic inventory, use service-specific keys where risk warrants, automate certificate renewal and key rotation, monitor key use and policy changes, and design recovery so key loss does not make protected data permanently unavailable.

How to implement Encryption and Key Management

  1. 1

    Locate sensitive data paths

    Map where sensitive customer and company data is stored, copied, logged, backed up, exported, and transmitted, including internal service and administrator connections.

    You should end up with: A data-to-encryption inventory covering primary stores, replicas, logs, backups, exports, and network paths.

  2. 2

    Choose approved protection mechanisms

    Record the managed encryption, transport, certificate, key, and secret-handling mechanism used for each path, plus the accountable service and security owners.

    You should end up with: A cryptographic decision record with expected settings and ownership by data path.

  3. 3

    Enable storage and transport encryption

    Configure encryption for data stores, object storage, disks, telemetry, logs, and backups, and enforce encrypted connections for public, administrative, and sensitive internal traffic.

    You should end up with: Service configuration exports and connection tests demonstrating protected storage and transmission.

  4. 4

    Separate key use from key administration

    Grant applications only the cryptographic operations they need, restrict policy changes and deletion, log key use, and prevent broad data administrators from automatically becoming key administrators.

    You should end up with: Key policies, administrator memberships, and audit events showing constrained key operations.

  5. 5

    Exercise rotation and recovery

    Rotate keys or certificates according to risk, verify consumers adopted the new material, monitor expiry, and test recovery or restore paths without exposing key material.

    You should end up with: Rotation and renewal events plus a successful recovery or restore result for protected data.

Evidence to keep, and what it should prove

Build the evidence set in three layers: what defines the control, who approved or reviewed it, and what proves it operated. Collect operating records when the work happens so they remain dated, attributable, correctly scoped, and traceable to the underlying activity.

Before sharing, remove unrelated personal or customer data, never expose passwords, tokens, or secret values, preserve enough source context to authenticate the record, and use the secure exchange approved for the engagement.

Operating / technical evidence

Dated proof that the control actually ran, such as tickets, logs, settings, exports, reports, and test results.

Encryption configuration

  • Confirm what the record proves

    The current state of identified databases, object stores, disks, logs, replicas, exports, and backups uses the approved at-rest protection and key reference.

  • Include this context

    Resource ID and data type

  • Include this context

    Environment

  • Include this context

    Encryption status and mechanism

  • Include this context

    Key reference

  • Include this context

    Scope or coverage

  • Include this context

    Generated-at timestamp

Weak evidence to avoid

A provider page saying encryption is available without the production resource ID, enabled state, key reference, backup coverage, or timestamp.

KMS/secrets manager settings

  • Confirm what the record proves

    Current key and secret administration, usage permissions, rotation or expiry settings, deletion safeguards, and logging are restricted for identified production resources.

  • Include this context

    Key or secret ID

  • Include this context

    Purpose and environment

  • Include this context

    Usage policy

  • Include this context

    Administrator policy

  • Include this context

    Rotation or expiry setting

  • Include this context

    Generated-at timestamp

Weak evidence to avoid

A key alias or secret name with no effective policies, administrators, protected-resource link, rotation setting, deletion safeguard, or timestamp.

TLS settings

  • Confirm what the record proves

    The current public, administrative, service, and data-store endpoints enforce approved encrypted protocols and valid certificates for the scoped paths.

  • Include this context

    Endpoint or service

  • Include this context

    Environment

  • Include this context

    Protocol and minimum version

  • Include this context

    Certificate identity and expiry

  • Include this context

    Enforcement mode

  • Include this context

    Test or capture timestamp

Weak evidence to avoid

A browser padlock on one public page with no administrative, internal, or database path coverage and no protocol, certificate, or test detail.

key access/rotation records

  • Confirm what the record proves

    Key use and administration are attributable, and rotations activate the intended replacement, preserve needed access, and retire or constrain prior key material.

  • Include this context

    Key ID

  • Include this context

    Actor or service

  • Include this context

    Access or rotation action

  • Include this context

    Event timestamp

  • Include this context

    Affected resource

  • Include this context

    Outcome and prior-key state

Weak evidence to avoid

A ticket stating ‘key rotated’ without provider events, key ID, affected resources, consumer validation, prior-key state, or completion time.

Which records should you prepare for the audit?

Type 1

Evidence at the as-of date

As of the selected date, retain the current data-to-encryption inventory, current resource, key, secret, and TLS configurations, current administrator assignments, and the latest completed key or certificate rotation or recovery exercise.

Type 2

Evidence across the review period

Include every in-scope sensitive store, log destination, replica, backup, export path, administrative connection, and sensitive service connection at each required review point, plus every encryption-state, key-policy, key-administrator, rotation, certificate, expiry, deletion, and cryptographic exception event during the review period.

Completeness check

Reconcile the data-flow and asset inventories to cloud resources, log destinations, backups, certificate endpoints, and key references, then reconcile configuration and audit histories to all cryptographic changes, rotations, expiry events, and approved exceptions.

Build the record set from

  • Data and asset inventory
  • Cloud resource configuration
  • Key and secrets management services
  • Certificate management and endpoint scanning
  • Cloud IAM and audit logs
  • Change, exception, and recovery records

Keep these fields for each record

  • Resource, path, key, or certificate ID
  • Data type and environment
  • Protection mechanism and current state
  • Key or certificate reference
  • Event or review timestamp
  • Owner, outcome, or exception

How an auditor may test this control

Use this checklist to prepare for procedures an auditor may perform. The exact steps and sample selection depend on your engagement scope and the service auditor's professional judgment.

  • Confirm the intended control outcome

    Determine whether the control is designed to achieve this result: Sensitive data is encrypted across storage and transmission paths, while access to keys and cryptographic administration remains narrower than access to the protected data.

  • Confirm ownership and operating cadence

    Compare the documented owner with the intended role (Infrastructure / Security Operations / IT), then compare dated records with the stated cadence: Continuous/ongoing; periodic review by risk.

  • Establish the complete audit record set

    Reconcile the data-flow and asset inventories to cloud resources, log destinations, backups, certificate endpoints, and key references, then reconcile configuration and audit histories to all cryptographic changes, rotations, expiry events, and approved exceptions.

  • Prepare the as-of-date evidence for a Type 1 engagement

    As of the selected date, retain the current data-to-encryption inventory, current resource, key, secret, and TLS configurations, current administrator assignments, and the latest completed key or certificate rotation or recovery exercise.

  • Prepare period evidence for a Type 2 engagement

    Include every in-scope sensitive store, log destination, replica, backup, export path, administrative connection, and sensitive service connection at each required review point, plus every encryption-state, key-policy, key-administrator, rotation, certificate, expiry, deletion, and cryptographic exception event during the review period.

  • Inspect the operating / technical evidence

    Dated proof that the control actually ran, such as tickets, logs, settings, exports, reports, and test results.

    • Inspect Encryption configuration

      For each selected record, confirm it demonstrates The current state of identified databases, object stores, disks, logs, replicas, exports, and backups uses the approved at-rest protection and key reference.

      • Resource ID and data type
      • Environment
      • Encryption status and mechanism
      • Key reference
      • Scope or coverage
      • Generated-at timestamp
    • Inspect KMS/secrets manager settings

      For each selected record, confirm it demonstrates Current key and secret administration, usage permissions, rotation or expiry settings, deletion safeguards, and logging are restricted for identified production resources.

      • Key or secret ID
      • Purpose and environment
      • Usage policy
      • Administrator policy
      • Rotation or expiry setting
      • Generated-at timestamp
    • Inspect TLS settings

      For each selected record, confirm it demonstrates The current public, administrative, service, and data-store endpoints enforce approved encrypted protocols and valid certificates for the scoped paths.

      • Endpoint or service
      • Environment
      • Protocol and minimum version
      • Certificate identity and expiry
      • Enforcement mode
      • Test or capture timestamp
    • Inspect key access/rotation records

      For each selected record, confirm it demonstrates Key use and administration are attributable, and rotations activate the intended replacement, preserve needed access, and retire or constrain prior key material.

      • Key ID
      • Actor or service
      • Access or rotation action
      • Event timestamp
      • Affected resource
      • Outcome and prior-key state
  • Trace the control from design to operation

    Use the categories that apply to this control: connect any policy or design artifact to its approval or review record, then trace a selected operating record through execution, result, and any exception or remediation.

Common implementation and evidence gaps

  • Primary databases are encrypted, but logs, replicas, exports, caches, or backups are omitted from the data-path review.
  • The same administrators can read sensitive data and freely change or delete the keys protecting it.
  • Public traffic uses encryption while internal service, database, or administrative connections allow plaintext.
  • Certificate or key ownership is unclear, causing expiry, failed rotation, or unsafe emergency changes.
  • Secrets storage is described as encryption even though hard-coded credentials remain in source, logs, or deployment settings.

Before you call this control ready

  • Does the encryption inventory cover logs, backups, exports, replicas, and internal connections as well as primary storage?
  • Can we show the exact setting that protects each sensitive store and transmission path?
  • Are key administrators and key-policy changes more restricted than routine application data access?
  • Would certificate expiry or key deletion be detected before it disrupts service or recovery?
  • Can we demonstrate a completed rotation or recovery exercise without exposing sensitive key material?

Trust Services Criteria references

These identifiers help you navigate related Trust Services Criteria. They do not reproduce the criteria or prove that this control fully addresses them in your environment.

  • CC6.1
  • CC6.7
  • C1.1

Confirm final scope, mappings, and testing expectations with your service auditor. SOC 2® is an AICPA trademark; GreenHat Security is not affiliated with or endorsed by AICPA.