Requirements
What the regulation expects
Customer-controlled keys under FADP
Art. 8 measures must match risk; external key control supports transparency and proportionate safeguards.
Privacy by design and default
Measures should be embedded early. Key architecture is part of that: default encryption with keys you govern reduces exposure without bolting on afterthoughts.
International disclosure and transfer risk
When data leaves Switzerland or the EEA, technical safeguards matter. Strong cryptography plus key custody in jurisdictions you choose narrows realistic access scenarios.
Processor instructions and accountability
Processors must assist with compliance. When keys are yours, the processor processes ciphertext or uses keys only under contracts and APIs you define—cleaner accountability lines.
Solutions
Relevant DuoKey products
Central KMS with integration to agreed HSM or MPC infrastructure and your IAM.
Learn moreHold root key material for workloads that must not rely on Microsoft administrative access alone.
Learn moreKeep data keys under an endpoint you operate so AWS staff and APIs cannot silently unwrap everything.
Learn moreReplace raw identifiers with tokens governed by your keys and policies.
Learn moreKey themes
Where customer-controlled keys fit
DuoKey supports Swiss controllers in meeting Art. 8 proportionality by ensuring that encryption key operations, access policies and logging are governed by your organisation — strengthening both technical measures and accountability toward data subjects.
Art. 8 — Technical and organisational measures
Demonstrate proportionate security including encryption and access control anchored to your organisation.
Transparency and data subject trust
Clear separation of roles between processor access and your key-controlled access supports honest privacy communications.
Related links
Useful resources