TTP · Key Escrow · Data Custodianship

Trusted Third Party (TTP)

As a trusted third party, we manage cryptographic keys and pseudonymisation keys, so that system providers, platforms or research partners do not gain uncontrolled access to the data of their customers or study participants. Typical use cases: medical/HealthTech, HR analytics, clinical trials, M&A escrow.

Project-specific FINMA · ISO 27001 Professional secrecy
Trusted Third Party - key escrow and data trusteeship
Mandate under Art. 321 SCC Professional secrecy

Working for regulated industries and SMEs

CIPP/E · CIPM IAPP certified
ISO 27001 Lead Auditor (BSI)
Aligned with the FDPIC Revised FADP · Art. 10
HQ Baar, ZG Swiss brand
CH · EU · UK · US Mandates worldwide
Dr. Dominic Staiger

Responsible for this mandate

Dr. Dominic Staiger

LL.M., Dr. iur., CIPP/E · Attorney at Law (New York) · Solicitor (UK)

Responsible for TTP mandates in which SIDD holds keys and pseudonymisation tables in confidence for regulated clients, with a documented release process and ISO 27001-certified infrastructure.

LinkedIn profile

What is a Trusted Third Party (TTP)?

Brief definition

A Trusted Third Party (TTP) is an independent, contractual third party that securely holds cryptographic keys or pseudonymisation mappings and releases them only under clearly defined conditions, typically to separate the data provider from the data processor in order to reduce re-identification risks.

The main tasks of a TTP:

  • Key management, generation, storage, renewal and destruction of cryptographic keys.
  • Key exchange, secure exchange between communication partners (asymmetric or via key distribution).
  • Certification & authentication, issuance and management of certificates for identity verification.

Typical use cases

Where a TTP makes the decisive difference today.

  • Medical service providers, pseudonymisation of medical data for research and analytics.
  • HealthTech apps, analysis of health data without direct reference to patients.
  • HR analytics, transfer of HR data to external analytics providers.
  • Clinical trials, pseudonymisation custodianship between sponsor, CRO and research site.
  • Pseudonymised telephone survey, market research with re-identification protection.
  • Traffic/mobility data, sharing sensitive GPS data with research.
  • M&A source code escrow, escrow of keys/code for buyer/seller trust arrangements.
  • Cloud KMS escrow, external custodian of wrapping keys for cloud encryption (hyperscaler-independent).

What services does SIDD provide as a TTP?

Comprehensive escrow for data keys and pseudonymisation tables, on ISO 27001-certified infrastructure.

  • Creation of pseudonymisation keys according to your specifications and security policies.
  • Secure storage and safekeeping of keys with robust encryption and controlled access.
  • Acting as trustee for private keys used for encryption and/or pseudonymisation.
  • Technical advisory on encryption algorithms, key management and security architecture.
  • Coordination of stakeholder communication between client, service provider, research body and, where applicable, the supervisory authority.
  • Development of pseudonymisation solutions by our privacy engineers and developers, tailor-made on request.

Governance & audit attestation

A TTP is only as trustworthy as its governance. At SIDD:

  • ISO 27001-certified infrastructure (BSI Lead Auditor)
  • Compatible with the FINMA outsourcing circular
  • Duty of confidentiality under Art. 321 SCC
  • Documented release process (four-eyes principle)
  • Audit trail of all key accesses
  • Annual external audit report (available on request)

How do we launch a TTP project?

After a free initial consultation, you will receive a quote. Six phases then follow.

Project planning & stakeholder onboarding

Joint project plan, where applicable involving customers and other stakeholders.

Kick-off

Finalise the project plan and define communication channels.

Technology & process

Choice of KMS solution, taking over existing systems or building on SIDD infrastructure.

Implementation

Set up systems, with custom development by our privacy engineers where required.

Testing & UAT

Test phase with you or specialised testing providers.

Handover & go-live

Productive operation of key generation and safekeeping.

Why SIDD?

A Trusted Third Party is only as credible as its independence, its confidentiality and its technical diligence, and at SIDD, all three come from a single source.

Keys under professional secrecy

Where Dr Dominic Staiger acts as a lawyer, the deposited keys and mandate information are subject to professional secrecy under Art. 321 SCC. This is confidentiality protection backed by criminal law that a pure IT service provider cannot offer.

Neutral, no data access

We manage solely keys and pseudonymisation keys and are neither the system provider nor the platform operator in your use case. Release occurs only under the contractually defined conditions, never on the unilateral request of a single party.

Contract and custody combined

Lawyers holding doctorates draft the escrow and release agreement, while our own information-security and software-engineering team under CTO Oliver Stutz operates the key custody. Otherwise, key escrow fails precisely at the gap between contract text and secure implementation.

Logged operations

Every release, access and rotation operation is logged and available via our Priverion Platform as a maintained, auditable record. This allows the escrow to be demonstrated to the supervisory authority, auditors and study participants.

Escrow across jurisdictions

With mandates in CH, EU, UK and US, we position the escrow across multiple jurisdictions, relevant for cross-border clinical trials, HR-analytics group structures or an M&A escrow with parties in different countries.

Permanently responsible point of contact

SIDD has operated as an independent third party since 2017, with a high mandate-renewal rate and an initial response within 24 hours. In an escrow event, such as an escrow trigger or a release request, you reach a named, permanently responsible point of contact.

Our tool: LexCommand

Why we work with LexCommand, our own Swiss legal AI

LexCommand is our in-house, citation-backed legal AI for the law of Switzerland, Germany, Austria and the EU. Developed and run sovereignly in Switzerland by Priverion GmbH, the company behind SIDD. We do not just preach data sovereignty and provability, we built them into our own tool, alongside the Priverion Platform.

Sovereign in Switzerland

The AI runs self-hosted on Swiss infrastructure, with no external cloud LLMs. As an independent Swiss company with no foreign parent, we process your documents in an environment we control.

No citation, no claim

Every legal statement traces back to a retrievable primary source, or it does not appear at all. That makes our recommendations auditable and verifiable, instead of merely sounding plausible.

From effort to judgement

LexCommand takes over searching, cross-checking and sourcing. That shortens turnaround times and frees our senior advisors for judgement and client dialogue, with no loss of diligence.

Three disciplines, one picture

We look at data protection, information security and AI security on a shared source base with a framework crosswalk. So you see overlapping obligations in one consolidated picture, instead of three isolated analyses.

For your TTP mandate, concretely: LexCommand backs the custody and release agreement and its four-eyes release process with cited sources from the FADP, GDPR, the FINMA outsourcing circular and ISO 27001, and scopes cross-border escrow to the correct legal system without mixing jurisdictions.

Temporally deterministic (as of today or any reference date), with jurisdiction isolation (CH/DE/AT/EU) and a citation verifier at the end of every answer.

Frequently asked questions before engaging us

What does a TTP mandate cost?

Project-specific. Setup typically CHF 15'000 – 60'000, ongoing escrow operation from CHF 9'000/year. The final price depends on complexity, the number of keys/tables and audit requirements.

In which jurisdiction do you hold the keys?

Switzerland (HQ Baar, ZG). On request additionally EU (Munich) or UK (London). Data residency is agreed contractually.

Who has access to the keys?

Only a clearly defined, documented group of individuals under the four-eyes principle. Every access is documented in the audit log.

Can you act as a data trustee for clinical trials?

Yes. We have experience in pseudonymisation escrow between sponsor, CRO and research institution, with a documented re-identification procedure for pharmacovigilance cases.

Is your infrastructure ISO 27001 certified?

The custody infrastructure follows ISO 27001 standards with BSI lead-auditor support. Audit reports are available on request.

Are inquiries subject to confidentiality?

Yes, Art. 321 SCC. Key contents and audit logs are shared exclusively with the persons you designate.

Ready for a TTP mandate, secure key escrow with ISO 27001 governance.

30-minute initial consultation with Dr. Staiger. If needed, you will subsequently receive a use-case brief with a recommended architecture.