A draft normative standard under OYA-S
OYA-S 2000:2027 (Draft) — Sensitive Data, Encryption, Member-Key Control, and Erasure
A worked example of a full OYA-S normative standard, published to show what conformance would actually require — not to announce that it is required today. This document governs how a conforming organization would classify sensitive personal information, disclose its encryption and key-custody architecture, offer member-controlled and zero-knowledge vaults, and provide a truthful, verifiable path for cryptographic erasure.
DRAFT — not ratified, not in force. OYA-S 2000 has no legal or contractual effect. No standards council has ratified it, no independent board has reviewed it, no assessor program exists to test conformance against it, and no company — including AlignHeart, OYA's founding implementer — has been certified against it. Every "SHALL"/"MUST" in this document states what a conforming implementation would be required to do if and when this standard is ratified, not a claim that any such requirement currently binds anyone.
Contents
Table of contents
- 1 Scope
- 2 Sensitive-data classification
- 3 Restricted Vault requirements
- 4 Encryption architecture
- 5 Key-management lifecycle
- 6 Member-Key Vault requirements
- 7 Zero-Knowledge Vault requirements
- 8 Recovery/loss policy
- 9 Key rotation/revocation
- 10 Cryptographic erasure
- 11 Backups/replicas
- 12 Erasure evidence and member communication
- 13 Technical validation requirements
Front matter
Foreword
This is a working draft of OYA-S 2000, one of eight planned core standards in the OYA-S family (OYA-S 1000 through OYA-S 8000), plus three program-rule documents (OYA-C 100 conformity assessment, OYA-A 100 approved assessors, OYA-R 100 public registry). It is published on this site as a complete, real worked example of what an OYA-S standard document looks like end to end — cover matter, defined terms, numbered normative requirements in the Requirement / Rationale / Evidence / Conformity-method format, and conformity guidance — not as a document anyone is currently bound by.
OYA-S 2000 covers the specific layer of data protection AlignHeart's founder asked to be built into the OYA Gold tier directly: encryption architecture, member control over the encryption key itself, an access/pull/copy ledger, and a cryptographic-erasure path where destroying a key is designed to remove the company's own access to the underlying content. The requirements below draft that intent into normative, testable language — they do not relax it and they do not overstate it.
Front matter
Introduction
Most privacy and security frameworks describe encryption in general terms — "data is encrypted at rest and in transit" — without telling a member whether the company itself can still read their content, whether backups survive a deletion request, or what happens if they lose a recovery phrase. OYA-S 2000 exists to close that specific gap: it requires a conforming organization to disclose, in plain and specific terms, which of several distinct key-custody modes applies to a given category of sensitive content, and to build a real, verifiable cryptographic-erasure workflow rather than a "delete" button that only hides a row in a database.
Cryptographic erasure is a genuinely powerful mechanism when it is correctly designed: destroying the right key can make ciphertext permanently unreadable, including to the company that stored it. It is also easy to overstate. A key-destruction claim is only truthful if the organization has no recovery key, no readable plaintext replicas, no un-inventoried plaintext logs, and no backup copy protected by a company-held key that bypasses the destroyed one.
This must be designed and reviewed by experienced cryptography and security engineers. Do not invent custom encryption, and do not claim zero knowledge from UI language alone. A "Zero-Knowledge Vault" claim under this standard requires an actual architecture in which the organization holds no recovery path — not a marketing description of an ordinary encrypted database. Every requirement in this document that touches encryption, key custody, or erasure carries an implicit prerequisite: independent cryptographic design review before it is implemented, and independent technical testing before it is claimed.
This document uses mandatory language (MUST / SHALL) to describe what a conforming implementation would be required to do. That is standard drafting practice for a normative document, including one still in draft — it is not a statement that the standard currently operates. See the draft-status notice above, the closing status note in Conformity and evidence, and the site's Status & disclosures page for the full picture: no ratification, no assessor program, no certified company.
Front matter
Normative references
This draft does not invent cryptographic or sanitization methodology. Its key-management lifecycle structure (§5) is informed by NIST's published key-management lifecycle guidance, and its erasure/sanitization distinctions (§10–§11) are informed by NIST SP 800-88, the U.S. government's media-sanitization guidance. Neither reference implies NIST endorsement, review, or affiliation — OYA-S maps to established external guidance rather than claiming to replace it, consistent with the positioning described in Governance & independence.
Front matter
Terms, definitions, and notational conventions
Notational conventions
This document uses the following normative keywords:
Defined terms
Requirements — 1 of 13
1. Scope
OYA-S 2000 applies to any organization that collects, stores, or processes sensitive personal information (as classified in §2) from members of a product or service, and specifically governs: the encryption architecture protecting that information; the key-custody model disclosed to the member; the availability and mechanics of Member-Key and Zero-Knowledge Vault options; and the truthful, verifiable erasure of that information when a member requests it.
OYA-S 2000 does not by itself govern ordinary account or profile data (see OYA-S 1000), algorithmic representations and inferences drawn from sensitive data (see OYA-S 3000), or third-party/vendor handling of sensitive data (see OYA-S 6000) — those are separate standards in the same family, cross-referenced where relevant below.
This standard is written for, and its worked requirement examples reference, AlignHeart's own architecture as the founding implementer building toward the OYA Gold tier. That reference does not mean AlignHeart currently conforms — see the founding-status notice at the top of this page.
Requirements — 2 of 13
2. Sensitive-data classification
OYA's five-layer data architecture places sensitive personal information in Layer 4 — Restricted sensitive information: private reflection, safety concerns, health-adjacent context, trauma, sexuality, intimate history, precise location, financial hardship, and biometric or voice data. Layers 1–3 (identity/account, member-provided information, and derived personal information) and Layer 5 (identity-separated aggregate information) fall under OYA-S 1000 and OYA-S 3000 respectively, and are cross-referenced here only where they intersect with encryption or erasure (§11).
The organization SHALL classify Layer 4 sensitive personal information into a distinct "Restricted" data tier, separate from ordinary account and profile data, before that information is stored.
A classification boundary is the precondition for every other control in this standard — encryption mode, access logging, and erasure mechanics can only be applied consistently if the organization first knows which records are Restricted-tier.
a. Data classification policy naming the Restricted tier.
b. Data map or schema showing which fields/record types are tagged Restricted.
c. Sample record demonstrating the tag is enforced at storage time, not applied retroactively.
Documentation review and technical sampling of the data schema.
Requirements — 3 of 13
3. Restricted Vault requirements
The organization provides a protected storage class — the Restricted Vault — for Layer 4 content. This section states the baseline requirements for that storage class, drawn directly from the OYA Gold "Member-Key Vault" requirement (OYA-GOLD-01).
The Restricted Vault MUST:
- Encrypt content at rest and in transit.
- Use per-record or per-vault data encryption keys.
- Separate identity information from vault ciphertext.
- Require member re-authentication to view vault content.
- Use a member-controlled secret for the highest protection mode (see §6, §7).
- NOT expose vault content to other users, matches, partners, advertisers, or ordinary customer-support tools.
- Maintain a member-readable access record (see §12).
These are the minimum technical and access controls that make the word "vault" meaningful rather than decorative — content stored without them is not distinguishable from ordinary encrypted-at-rest data and should not be marketed as a Restricted Vault.
a. Architecture diagram showing key separation from identity data.
b. Access-control configuration excluding ordinary support tooling.
c. Re-authentication flow test result.
d. Sample entry from the member-readable access record (§12).
Technical test and architecture-diagram review.
Requirements — 4 of 13
4. Encryption architecture
A conforming organization discloses which of four key-custody modes applies to a given category of Restricted content. The modes differ in exactly one dimension that matters to a member: whether the organization itself can decrypt the content, and whether the member has a recovery path if they lose their credential.
| Mode | Company may decrypt? | Member recovery? | Best use |
|---|---|---|---|
| Protected Vault | Yes, only under disclosed restricted conditions | Yes | General sensitive information |
| Member-Key Vault | Possibly, only if a disclosed recovery key exists | Optional | Sensitive consumer products |
| Zero-Knowledge Vault | No, within stated scope | No company recovery | Highest-sensitivity personal content |
| Threshold Recovery Vault | Only if multiple approved factors meet a threshold | Yes, if configured | Regulated or shared-trust use cases |
Before or at the point a member's content is placed in a given vault mode, the organization SHALL disclose which of the four modes applies, using the terms defined above — not a general statement that data is "encrypted."
"Encrypted" alone does not tell a member whether the company can still read their content. The four-mode distinction is the specific piece of information a member needs to make an informed choice.
a. UI copy or disclosure text shown at the relevant point in the product.
b. Mapping from each Restricted content type to its declared mode.
Member-journey observation and documentation review.
Requirements — 5 of 13
5. Key-management lifecycle
Encryption claims are frequently made ("this is encrypted") without evidence covering the full lifecycle of the key that does the protecting. Following NIST's key-management lifecycle structure, a conforming organization maintains and can produce evidence for each of the following stages.
Use established, reviewed cryptographic libraries and secure randomness.
Use managed key systems or hardware-backed protection appropriate to risk.
Do not store the plaintext data key beside the plaintext recovery key.
Use least privilege, approval controls, logging, and periodic review.
Rotate keys under documented conditions without weakening member restrictions.
Support immediate revocation, incident investigation, and recovery response.
Destroy or revoke applicable key material, record evidence, verify replica coverage, and clearly disclose what remains separately retained.
Disclose precisely who can recover, what factors are required, and what cannot be recovered.
The organization SHALL maintain documented practice and evidence for each of the eight lifecycle stages above, for every key that protects Restricted-tier content. A conformity claim that only addresses Generation and Storage, without Rotation, Compromise, Erasure, and Recovery, does not satisfy this requirement.
NIST guidance treats key management as a full lifecycle covering generation, establishment, storage, use, and destruction; OYA-S 2000 requires evidence across that lifecycle rather than relying on a broad claim that a system is "encrypted."
a. Key-management policy covering all eight stages.
b. Key-rotation schedule and most recent execution log.
c. Documented incident-response procedure for key compromise.
Technical test and documentation review.
Requirements — 6 of 13
6. Member-Key Vault requirements
This section states OYA-GOLD-02's key-architecture disclosure requirement in full. It applies specifically to content stored in Member-Key Vault mode (§4).
The organization MUST disclose which vault mode applies to a given category of content, using one of the following three labels:
- Company-Managed Protected Vault
- Member-Key Vault with Recovery
- Zero-Knowledge Member-Key Vault
and, for each, clearly state:
- Whether the company can decrypt the member's content.
- Whether recovery is available.
- What happens if the member loses the recovery phrase.
- Whether backups remain ciphertext after key destruction.
- The expected deletion/erasure timeline.
- Legal-retention exceptions, if any.
Each of the six disclosure items answers a question a member would reasonably ask before trusting a "vault" label. Omitting any one of them (most commonly: what happens to backups after key destruction) is the most common way encryption claims become misleading without being technically false.
a. Disclosure copy for each vault mode in use.
b. Technical confirmation that the backup-ciphertext claim in the disclosure matches the actual backup architecture.
Documentation review and technical test against the backup system.
Requirements — 7 of 13
7. Zero-Knowledge Vault requirements
Zero-Knowledge mode is the strongest and least forgiving option in this standard: the organization retains no path to recover a member's content. It is stated here as a technical sequence to make the architecture concrete rather than aspirational.
Where an organization labels content "Zero-Knowledge," it SHALL implement client-side key generation such that the organization never receives or stores the unwrapped vault key or an equivalent recovery path, and it MUST NOT offer an email-reset or support-initiated recovery for that content.
"Zero-knowledge" is a specific, testable architectural claim, not a UI description. An organization that can reset a member's access through a support workflow does not have a zero-knowledge system, regardless of what its interface says.
a. Independent cryptographic architecture review confirming no server-side recovery path exists.
b. Source or configuration review of the key-generation flow.
c. Support-tooling audit confirming no reset capability for Zero-Knowledge content.
Independent technical review — this requirement is not satisfiable by policy documentation alone.
Requirements — 8 of 13
8. Recovery/loss policy
Recovery is the counterpart to erasure: a member needs to know, in advance, exactly what happens if they lose access rather than deliberately destroying it.
For every vault mode offering any recovery path, the organization SHALL disclose precisely who can recover access, what factors are required, and what specifically cannot be recovered. For Zero-Knowledge Vault content, the organization MUST state plainly that forgetting the recovery phrase results in permanent, unrecoverable loss of that content — by the member and by the company alike.
A recovery claim that is vague about "who" and "what factors" is functionally the same failure mode as a vague deletion claim (§10) — it lets an organization imply stronger member control than the architecture actually provides.
a. Recovery-disclosure copy for each vault mode.
b. Support-flow documentation showing the recovery path matches the disclosure.
Documentation review and member-journey observation.
Requirements — 9 of 13
9. Key rotation/revocation
This section restates the Rotation and Compromise stages of the key-management lifecycle (§5) as standalone testable requirements, since they are the stages most often skipped in an "encrypted at rest" claim.
The organization SHALL rotate encryption keys under documented conditions (scheduled rotation, suspected compromise, or personnel change) without weakening any member-set access restriction, and SHALL support immediate key revocation and incident investigation in response to a suspected compromise.
Key rotation is routine good practice, but a rotation process that silently resets a member's restriction settings (for example, re-exposing content a member had locked) would defeat the purpose of the restriction itself.
a. Key-rotation schedule and procedure.
b. Test result confirming member restrictions survive a rotation event.
c. Documented incident-response runbook for suspected key compromise.
Technical test and documentation review.
Requirements — 10 of 13
10. Cryptographic erasure
This is the requirement Ricardo, AlignHeart's founder, most directly asked for: a real mechanism by which a member destroying their key removes the company's own access to the underlying content — implemented honestly, with the exact confirmation-screen language a member sees before doing it.
Before any erasure workflow, every OYA system must distinguish these seven truthfulness states, so a deletion claim never collapses into a single vague "deleted":
| State | Meaning |
|---|---|
| Deletion requested | The member has submitted a request. |
| Logical deletion | The record is hidden from ordinary product access. |
| Restricted pending deletion | The record is blocked from discretionary use while deletion runs. |
| Cryptographically erased | The relevant decryption key has been destroyed or revoked. |
| Physically sanitized | Storage media or storage blocks have been cleared, purged, or destroyed per the company's documented sanitization method. |
| Retention exception | A narrowly defined legal, security, fraud, accounting, or safety reason requires limited continued retention. |
| Identity-separated aggregate | The record no longer remains directly account-linked, subject to disclosed technical and governance limits. |
NIST's current media-sanitization guidance treats sanitization as a documented, verified program tied to the sensitivity of the data — not a single UI "delete" button standing in as proof of complete removal. OYA-S 2000 follows that framing and prohibits vague "deleted everywhere" claims that don't distinguish among the seven states above.
The organization SHALL provide an eligible member with a mechanism to initiate cryptographic erasure of Covered Vault Content. The mechanism MUST:
- Require recent authentication.
- Require the vault recovery phrase or an equivalent high-assurance factor.
- Use explicit confirmation, not a single accidental tap.
- Destroy the member-wrapped key material.
- Destroy or revoke service-side wrapped-key references where applicable.
- Queue cryptographic-erasure verification across replicas.
- Record a signed erasure event (see §12).
- Show the member a completion state and any exceptions.
Key destruction may make covered ciphertext infeasible to decrypt when the architecture correctly separates and protects the relevant key material. This requirement exists precisely to prevent the version of this claim that isn't true: "the moment a member changes their encryption code, the company loses all access to every copy of their data," stated without the recent-authentication, replica-verification, and exception-disclosure steps above, is not a safe claim for most products to make.
a. Architecture diagram.
b. Key-management configuration sample.
c. Erasure workflow test result.
d. Replica-verification result.
e. Member-facing confirmation and exception notice.
f. Tamper-evident ledger entry.
Technical test, documentation review, and member-journey observation.
The mandatory pre-confirmation copy a member sees before this action, verbatim:
Requirements — 11 of 13
11. Backups/replicas
Cryptographic erasure of a primary record does not, by itself, resolve every derivative and backup copy an organization may hold. This section requires the organization to distinguish those copies explicitly rather than let "erased" silently mean "the primary copy only."
The organization SHALL distinguish, for every erasure event, between: original protected content; generalized private summaries; account-linked derived profile data; de-identified aggregate research data; and logs, backups, caches, embeddings, and analytics artifacts. Key destruction of original vault content does NOT automatically mean all authorized derivatives disappear, and the organization MUST NOT represent it as doing so.
This is the single most common way a "we deleted your data" claim becomes misleading: the primary record is gone, but a backup, a log line, or a derived summary survives on a separate retention schedule. Disclosure of the distinction is the fix, not a promise that every category disappears simultaneously.
a. Backup and replication architecture documentation, including retention class per backup type.
b. Sample member-facing disclosure listing each data location and its status (see §12's copy inventory).
c. Test result confirming a Physically Sanitized claim (§10 table) is only made where the documented sanitization method has actually run and been verified — not asserted from the UI alone.
Technical test against the backup system and documentation review.
Requirements — 12 of 13
12. Erasure evidence and member communication
This section states OYA-GOLD-05 (Access Provenance Ledger) and OYA-GOLD-06 (copy and export inventory) — the record-keeping that makes every claim in §10–§11 checkable by the member themselves, not just by an assessor once a year.
The OYA Activity Ledger
The organization maintains an immutable, member-readable event ledger for protected information. It must make meaningful use visible without exposing security-sensitive details or other people's information.
| Field | |
|---|---|
| Event identifier | Outcome (viewed / transformed / exported / deleted / denied) |
| Timestamp | Copy/export status |
| Action | Policy/standard version |
| Data item or category | Retention/deletion state |
| Data classification | Related request, incident, or approval reference |
| Actor type | Tamper-evident integrity reference |
| Protected role label | Purpose |
| System or processor category | |
The 22 required ledger event types, above. Actor-disclosure rules: show "You" for a member's own access; show the automated service role, purpose, input category, and result for automated systems; show the protected role label (not the employee's name, where unsafe), approved purpose, and approval reference for authorized staff; show the named or categorized processor for external processors; and disclose government/legal access only where legally permitted, otherwise via aggregate transparency reporting. This follows OWASP logging guidance, which supports capturing security-relevant "when, where, who, and what" information while warning against placing secrets, credentials, or cryptographic keys in logs.
Erasure UX — required confirmation screen
The organization SHALL maintain a member-readable Access Provenance Ledger covering all 16 required fields and all 22 required event types listed above, for every item of Restricted-tier content. The ledger MUST NOT reveal security-sensitive implementation details, unsafe employee names, other members' data, or confidential fraud controls.
This is the record that shows every time the data was pulled and accessed, and whether copies were made — the specific accountability mechanism requested alongside the erasure control itself.
a. Ledger schema covering all 16 fields.
b. Sample ledger entries covering at least five distinct event types.
c. Tamper-evidence mechanism test result.
d. Member-facing ledger UI walkthrough.
Technical test, schema review, and member-journey observation.
For protected records, the organization SHALL provide a member-readable inventory of: active primary record; encrypted replicas; backup retention class; member-created exports; approved external processors, by category; derived private summaries; and research status (account-linked, identity-separated, or not used). The inventory MUST use clear categories and avoid false precision.
This is the member-facing counterpart to §11's backup-disclosure requirement — it turns "we have copies in several places" into a specific, checkable list instead of a general reassurance.
a. Sample copy-inventory screen for a real record.
b. Backend mapping confirming every listed location actually exists and every existing location is listed.
Technical test and member-journey observation.
Requirements — 13 of 13
13. Technical validation requirements
This section states OYA-GOLD-07. Nothing in §1–§12 is self-certifiable — the standard is designed so that every claim above is independently tested, not merely documented.
OYA Gold conformance to this standard requires:
- Annual assessment by an approved independent assessor.
- Technical test of access controls, logging, key management, and the erasure workflow.
- Review of the data map, retention rules, derivative handling, and member controls.
- Sampled evidence of remediation.
- A public certificate stating validity date and scope.
- A suspension/revocation process for material nonconformance.
A company may not self-certify for OYA Gold.
Every requirement in this document — the vault controls, the disclosure language, the erasure mechanics, the ledger — is only as credible as the process that checks it stays true over time. Annual, independent, non-self-administered assessment is what keeps a "Cryptographically erased" or "Zero-Knowledge" claim honest a year after launch, not just on day one.
a. Assessor engagement letter and independence attestation.
b. Completed technical test report.
c. Remediation-tracking record for any findings.
d. Published certificate with scope, validity date, and assessor name.
Independent third-party assessment — no other conformity method satisfies this requirement.
No assessor program exists yet. OYA-A 100 (Approved Assessor Requirements) and the assessor accreditation process it would define have not been built. Until they are, §13.1 describes what annual independent verification would require — it is not something any organization can currently obtain.
Front matter
Conformity and evidence
Each requirement above states its own conformity method (technical test, documentation review, member-journey observation, or independent third-party assessment) and, where applicable, an "Evidence required" marker naming the specific artifacts an assessor would need — not a policy statement alone. Four evidence categories recur across this standard: Policy evidence (written policies and disclosures), Technical evidence (architecture diagrams, configuration samples, test results), Operational evidence (logs, ledger entries, remediation records), and Member-experience evidence (screenshots or walkthroughs of the actual member-facing flow).
This standard is not currently assessable by anyone. OYA-S 2000 has not been ratified, no OYA Standards Council or independent board has reviewed it, no OYA-A 100 assessor program exists, and no public registry lists any organization against it. AlignHeart, OYA's founding implementer, has stated an intent to build toward this standard and has not claimed — and does not claim here — that it currently conforms to or is certified against OYA-S 2000. Nothing on this page should be read as evidence of AlignHeart's current data-handling practices; it is a specification of what AlignHeart, or any other organization, would need to build and prove in order to conform.
Annex A — informative
Glossary
Annex B — informative
Implementation example: member key flow
This annex is informative, not normative — it illustrates one way §4, §6, and §7 could be implemented; it does not itself impose a requirement. See the member key flow diagram in §7 for the full sequence, and the caution at the top of the Introduction: this flow must be designed and reviewed by experienced cryptography and security engineers before implementation, not built from this document alone.
Front matter
Bibliography
- NIST key-management lifecycle guidance — informs the eight-stage structure in §5.
- NIST SP 800-88 (media-sanitization guidance) — informs the deletion/erasure truthfulness labels and the "Physically sanitized" state in §10.
These references are cited as the conceptual foundation OYA-S 2000 draws on. Citing them does not imply NIST review, endorsement, or affiliation with OYA, and OYA-S 2000 does not claim equivalence to either publication.
Front matter
Revision history
Initial working draft. Not yet through public comment. Not ratified.
Where this stands
Where OYA-S 2000 actually stands.
Every "SHALL" and "MUST" above describes what a conforming organization would be required to do — it is normative-document style, appropriate even in draft form, and it is not a claim that OYA-S 2000 is in force. No standards council has ratified this document, no independent board has reviewed it, no assessor program exists to test conformance against it, and no organization — including AlignHeart — has been certified against it. AlignHeart is OYA's founding implementer and has stated an intent to build toward this standard; that is a fact about AlignHeart's roadmap, not a claim about OYA's current operation.
Back to the OYA Standard overview