CF05-S13: AI Encryption Key Archival

AI Control Library / CF-05: Data Governance & Privacy

Designation: Supplemental | Control types represented: Operational and Technical

Control requirement

Archive only cryptographic keys and supporting metadata justified by authorized retention or recovery needs, protecting them against disclosure, alteration and uncontrolled reuse. Maintain the ability to interpret retained ciphertext and its key dependencies.

Why this matters

An archive may preserve data but lose the keys or metadata needed to read it. Conversely, unnecessary retention of sensitive keys can extend compromise exposure after their operational purpose has ended.

How the control types work together

Operational controls define scope, authority and the actions required when conditions are not met. Technical controls produce evidence or enforce the relevant boundaries. Both must apply to the same deployment and operating conditions.

When it applies

Historical AI data requiring future authorized decryption or verification, with archival decisions tailored to key type and purpose.

Define the assessed boundary, dependencies and evidence limitations. Tailor depth and review frequency to potential impact, and document why a particular safeguard or exclusion is appropriate to the actual deployment.

Ownership

The data and key owners approve archival needs; custodians maintain protected storage and controlled retrieval.

Implementation guidance

Determine which key types and versions need archival, distinguishing decryption or verification needs from unnecessary retention of secret signing or operational material.
Preserve required identifiers, algorithms, protected-data relationships and service dependencies with the archived material.
Use approved protected storage and restricted retrieval, maintaining custody and availability over the required retention period.
Exercise authorized retrieval and eventual disposal, reassessing archives when services, protection assumptions or retention duties change.

How to verify it

Use representative records and authorized controlled tests. Identify the relevant version, operating conditions and expected result before testing, and retain enough evidence to support the conclusion.

Test	Expected result
Retrieve an authorized historical item	The required key, metadata and compatible processing path are available.
Attempt unrelated archive access	Authorization and logging prevent unapproved use.
Review expired archival need	Disposition follows approved retention and destruction decisions.

Record a finding when required results cannot be demonstrated or practice differs materially from the approved conditions. Missing evidence limits the conclusion; it should not be treated as a successful test.

Evidence to retain

Archival justification and inventory
Protection and custody configuration
Retrieval and compatibility tests
Retention and disposal records

Protect evidence according to its sensitivity, access needs and retention rules. Avoid unnecessary copies of personal information, secrets or confidential material, while preserving the records needed for authorized review.

If the control fails

Escalate unavailable or exposed archives to security and data owners. Restrict affected reliance and establish an approved recovery, migration or disposal decision.

Example in practice

Hypothetical example: An organization retains encrypted evaluation records after changing providers. The archive plan preserves the required key metadata and tests access without relying on an active account that is about to be closed.

Related controls

Framework mappings

CSA AICM (CEK-18)
NIST AI RMF (MAP 1.1)
ISO 42001 (Cl. 8.2)

Review and maintenance

Review at the interval approved by the control owner and after relevant changes, incidents or failed assessments. Update affected procedures and configuration, address evidence gaps and verify corrective action before closing findings.

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