A retail company is migrating its e-commerce platform to a public cloud. The security team must decide how to handle encryption keys for data at rest in the cloud provider's object storage. The compliance officer requires that the company retain full control over key lifecycle management, including rotation and revocation, without the cloud provider being able to access the keys. Which approach BEST meets these requirements?
Customer-managed keys give the company exclusive control over key generation, rotation, and revocation. When stored in an HSM or customer-controlled KMS, the provider cannot access the plaintext keys, satisfying the requirement that the provider be unable to decrypt data. This approach aligns with compliance mandates for data sovereignty and key custody.
Why this answer
Customer-managed keys in an HSM or customer-controlled KMS ensure the company retains exclusive control over key lifecycle, including rotation and revocation, and prevents the cloud provider from accessing the keys. Provider-managed or default encryption gives control to the provider, while static passphrases lack proper lifecycle management. Thus, only customer-managed keys satisfy the compliance requirement.
Exam trap
The trap here is assuming that default encryption at rest with provider-managed keys provides the same level of control as customer-managed keys, when in fact it does not meet strict key custody requirements.