What evidence do auditors commonly ask for on CEK-01 Encryption and Key Management Policy and Procedures?

Approved cryptography and key management policy with owner and review date; Key management procedures covering the key lifecycle; Review log with yearly and change-triggered reviews; Communication records to teams operating cryptography.

What is the most common gap auditors find on CEK-01?

Policy silent on customer-managed keys

CSA CCM v4.1 · CEK - Cryptography, Encryption & Key Management

`CEK-01` Encryption and Key Management Policy and Procedures

Policies and procedures covering cryptography, encryption and the management of keys are approved, documented, communicated, applied, evaluated and kept current, with review and update every year as a minimum and after significant changes.

Source: CSA CCM v4.1, CEK-01. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open CSA CCM v4.1 in the compliance library.

Version 4.1 adds 11 controls (among them API security, log sanitisation and a service bill of materials) and renumbers several domains. CSA accepts v4.0.x during its transition; if your STAR assessment is still on v4.0.1, check the numbering against it.

artefacts

held by a system

at each review

moderate

to go live

SIEM / log platform

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

Review log with yearly and change-triggered reviews · SIEM / log platform

periodic reviewEvidence produced at each review

Communication records to teams operating cryptography · Policy repository / GRC workspace

governing documentDocuments that govern the control

Approved cryptography and key management policy with owner and review date · Policy repository / GRC workspace
Key management procedures covering the key lifecycle · Policy repository / GRC workspace

First move

Start with the 1 of 4 artefacts that already live in a system (SIEM / log platform); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

Policy silent on customer-managed keys
No review after adopting a new KMS or HSM service
Procedures absent beneath a high-level policy

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

Build my evidence sheet

CCC-09 Change Restoration · CEK-02 CEK Roles and Responsibilities