What evidence do auditors commonly ask for on CEK-02 CEK Roles and Responsibilities?

RACI for key custodians, key administrators and approvers; Job descriptions or role assignments for key management staff; Signed key custodian acknowledgements; Access lists to KMS or HSM consistent with assigned roles.

What is the most common gap auditors find on CEK-02?

Key administration and key use not separated

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

`CEK-02` CEK Roles and Responsibilities

Roles and responsibilities for cryptography, encryption and key management are defined and put into effect.

Source: CSA CCM v4.1, CEK-02. 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

hard

to go live

Policy repository / GRC workspace

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

none for this control

periodic reviewEvidence produced at each review

Signed key custodian acknowledgements · Identity provider / directory

governing documentDocuments that govern the control

RACI for key custodians, key administrators and approvers · Policy repository / GRC workspace
Job descriptions or role assignments for key management staff · Policy repository / GRC workspace
Access lists to KMS or HSM consistent with assigned roles · Policy repository / GRC workspace

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

Key administration and key use not separated
Custodian roles assigned but people unaware of duties
Role list out of date after staff changes

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

CEK-01 Encryption and Key Management Policy and Procedures · CEK-03 Data Protection