How to Implement ISO 27001 Annex A 8.24 Use of Cryptography

Stuart Barker - High Table - ISO27001 Director

In this ultimate how to implement guide to ISO 27001 Annex A 8.24 Use of Cryptography, you will learn directly from an ISO 27001 Lead Auditor:

1. Define Approved Cryptographic Algorithms

Control Requirement: Organisation-wide rules must define which cryptographic algorithms are permissible and which are banned.

Required Implementation Step: Create a technical standard document explicitly listing allowed cipher suites (e.g., AES-256, RSA-2048+, Ed25519) and explicitly banning deprecated ones (e.g., DES, MD5, SHA-1). Update your web server (Nginx/Apache) and load balancer configurations to technically reject connections using banned ciphers.

Minimum Requirement: A configuration file exists that blocks TLS 1.0 and 1.1 connections.

2. Implement Centralised Key Management

Control Requirement: Cryptographic keys must be managed securely throughout their lifecycle, from generation to destruction.

Required Implementation Step: Deploy a dedicated Key Management Service (KMS) or Secrets Manager (e.g., HashiCorp Vault, AWS KMS, Azure Key Vault). Move all hardcoded encryption keys out of source code and configuration files and into this secure vault, injecting them only at runtime.

Minimum Requirement: No encryption keys are stored in the application source code repository.

3. Enforce Data at Rest Encryption

Control Requirement: Sensitive data stored on physical media or databases must be encrypted to prevent unauthorised physical access.

Required Implementation Step: Enable Full Disk Encryption (FDE) (e.g., BitLocker, FileVault, dm-crypt) on all company laptops and servers. Configure database engines (SQL/NoSQL) to use Transparent Data Encryption (TDE) for all tables containing PII or financial data.

Minimum Requirement: Stolen laptops or hard drives are unreadable without the decryption key.

4. Secure Data in Transit

Control Requirement: Information transmitted over networks must be protected against interception.

Required Implementation Step: Configure all internal and external endpoints to require HTTPS using TLS 1.2 or 1.3. Implement HSTS (HTTP Strict Transport Security) headers to force browsers to refuse unencrypted HTTP connections.

Minimum Requirement: All web traffic scores an ‘A’ on the Qualys SSL Labs test.

5. Establish Key Rotation Procedures

Control Requirement: Cryptographic keys must be changed regularly to limit the impact of a potential compromise.

Required Implementation Step: Configure automated key rotation schedules within your cloud provider or KMS (e.g., rotate Customer Master Keys every 90 or 365 days). For manual keys (like SSH or GPG), set calendar reminders to regenerate and redistribute keys annually.

Minimum Requirement: Evidence of at least one key rotation event in the last 12 months.

6. Secure Key Generation

Control Requirement: Keys must be generated using strong random number generators to ensure unpredictability.

Required Implementation Step: Ensure that key generation processes use a cryptographically secure pseudo-random number generator (CSPRNG). On Linux servers, ensure applications read from `/dev/urandom` or use a hardware entropy source (HSM/TPM) rather than weak software libraries.

Minimum Requirement: Keys are not generated using predictable seeds like timestamps.

7. Implement Digital Signatures for Integrity

Control Requirement: Cryptography should be used to verify that data has not been tampered with.

Required Implementation Step: Sign all internal software release artifacts and binaries using a private signing key. Configure your deployment servers to verify this signature before executing any update to ensure the code hasn’t been altered in transit.

Minimum Requirement: Software updates fail to install if the digital signature is missing or invalid.

8. Manage Encryption Regulations

Control Requirement: The use of cryptography must comply with relevant country-specific laws and export controls.

Required Implementation Step: Audit your cryptographic usage against the export control laws of your jurisdiction (e.g., Wassenaar Arrangement). If you distribute software globally, ensure you have the necessary classification numbers (ECCN) documented for your encryption modules.

Minimum Requirement: Legal counsel has reviewed the export status of your cryptographic software.

9. Segregate Keys from Data

Control Requirement: Keys used to encrypt data should not be stored alongside the data itself.

Required Implementation Step: Architect your storage solution so that encrypted database backups are stored in a different location (e.g., a separate S3 bucket or physical site) than the keys required to decrypt them. Ensure different Identity and Access Management (IAM) roles control access to the data vs. the keys.

Minimum Requirement: An admin with access to the database backups does not automatically have access to the decryption keys.

10. Plan for Key Compromise

Control Requirement: A process must exist to handle the situation where keys are lost or stolen.

Required Implementation Step: Create a “Key Compromise Protocol” or “Revocation Plan.” This must list the exact CLI commands required to revoke a compromised certificate (CRL/OCSP) or rotate a master key immediately. Test this process in a non-production environment.

Minimum Requirement: A documented “Runbook” exists for immediate key revocation.

About the author

Stuart Barker
🎓 MSc Security 🛡️ Lead Auditor 30+ Years Exp 🏢 Ex-GE Leader

Stuart Barker

ISO 27001 Ninja

Stuart Barker is a veteran practitioner with over 30 years of experience in systems security and risk management. Holding an MSc in Software and Systems Security, he combines academic rigor with extensive operational experience, including a decade leading Data Governance for General Electric (GE).

As a qualified ISO 27001 Lead Auditor, Stuart possesses distinct insight into the specific evidence standards required by certification bodies. His toolkits represent an auditor-verified methodology designed to minimise operational friction while guaranteeing compliance.

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