OK, getting very close now. /path/to/keys is accessible and readable, but not writable (for good reason!). However, temporary files are (failing to be) created in that directory, as revealed by: 
print `/usr/bin/gpg --home /path/to/keys --list-keys 2>&1`;

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Which outputs: 
gpg: failed to create temporary file `/path/to/keys/.#lk0x91f5268.host
+name.24199': Permission denied gpg: fatal: can't create lock for `/pa
+th/to/keys/trustdb.gpg'

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I think I can take it from here. Thanks for the suggestions.

In reply to Re^4: Module works when run in a shell, but not when run as a CGI by azureblue
in thread Module works when run in a shell, but not when run as a CGI by azureblue

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