Episode 68 — Cryptography Program Governance at r2

At the r2 level, cryptography expands from technical implementation to strategic program governance. Candidates must understand that HITRUST requires organizations to document cryptographic responsibilities, key management lifecycle, and compliance with recognized standards such as FIPS 140-3. Governance involves formal key rotation schedules, encryption algorithm reviews, and periodic risk assessments to ensure continued adequacy. Evidence includes cryptographic policy documents, key custody logs, and records of encryption algorithm validation or replacement.


In operational environments, cryptography governance means establishing ownership for key management systems and ensuring alignment with data classification schemes. For exam purposes, candidates should connect governance to PRISMA’s “Managed” stage, demonstrating oversight and continual refinement. HITRUST assessors look for centralized control, accountability, and periodic review to verify that cryptography remains effective and compliant. This control area reflects an organization’s maturity in safeguarding confidentiality and integrity through disciplined, sustainable encryption management practices.
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