WorkflowSecurity Compliance Automation (SOC 2, ISO 27001, NIS2)

Security Policy Management

Information security policy management that tests every promise against practice, every night

Every policy promise tested against practice each night, and signed by the CISO.

See one case, screen by screen ↓
demo583statementstested against seven systems in one night — 519 match, 41 differ, 23 untested
demo37of 2,214privileged accounts found without the MFA the Access Control Policy promises, each one listed with its integration
demo89of 93Annex A controls with a policy statement; the 4 gaps named, all among the controls new in 2022
target583of 583policy statements checked against practice every night; any no system can show go to their owner for evidence
In short

What is Security Policy Management?

Information security policy management that treats each policy as a set of promises and tests them. Six agents split every policy into its “shall” statements, test each one against the systems that prove it every night, check coverage against ISO 27001 Annex A and SOC 2, keep the exceptions register and run acceptance campaigns. The CISO signs every version and every exception.

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Updated

The problem

Why security policies promise more than the company does

Every ISO 27001, SOC 2, NIS2 or DORA programme starts with a set of written security policies, and every audit asks the same question: does the company do what its policies say? Today the policies are Word files on a portal. Each owner is asked once a year to review theirs, and most change the date and the version number. The mapping to Annex A and the SOC 2 criteria lives in a spreadsheet that was rebuilt by hand when the 2022 edition renumbered the controls, and still misses some of the new ones.

Practice drifts away from the prose without anyone seeing it: quarterly access reviews done twice a year, leavers disabled days late, service accounts that cannot use the MFA the policy promises for “all privileged access”. Exceptions are approved by email and expire unnoticed. Employees “accept” the policy with a click, and their questions go to a mailbox nobody owns. The company learns its policy over-promised when the auditor samples practice — or when an attacker does.

typicalEUR 5–15kwhat an external ISO 27001 gap analysis typically costs — out of date the day it lands
typicalEUR 10Mor 2%the maximum fine NIS2 sets for essential entities, at least — whichever is higher; their management body approves these measures
typical11controlsnew in the 2022 edition of Annex A, each one needing a policy statement
Where a year of policy work goes, in working daysestimated
By hand61 days
With the solution11 days
  • Mapping policies to Annex A and SOC 2 in a spreadsheet10 → 1 d
  • Annual owner reviews of every policy12 → 4 d
  • Checking practice against the policies before the audit15 → 2 d
  • Chasing exceptions, approvals and expiry dates6 → 1 d
  • Acceptance campaigns and employees’ questions10 → 2 d
  • Assembling the evidence for the certification body8 → 1 d

Estimated split for a set of 24 security policies at a large company, by hand and with the solution.

How it works

How a policy stays true

Six specialist agents draft the wording, test every “shall” against real systems each night, check coverage and exceptions, and run acceptance; the CISO signs.

What comes in
Sources in24 policies · 7 systems · identity, vault, tickets, HR, cloud
Agents at work
Drafterwording, cited
Then
Reality agentevery shall, nightly
Coverage reviewer93 Annex A · 33 SOC 2
Then
Exception keepersafeguards tested
Change watcherlaws and new systems
Then
Attestation agentonly their rules
A person decides
CISOapproves every version and exception with a reason code
What comes out
Policies threaded to live evidence
Signed decisions and exceptions
Acceptance and audit evidence
One case, step by step

One broken promise, from the nightly test to a signed decision

Kestrel & Vane Group — about 40,000 people in 30 countries, ISO 27001:2022 certified with a surveillance audit on 18 November — keeps 24 security policies with 583 “shall” statements. On Thursday 15 October the nightly test finds a new red thread in the Access Control Policy. Here is what happens next, screen by screen, in the working solution.

  1. 01Thursday morning

    A short briefing, and only the decisions that need her

    Rachel Kim · CISO

    Rachel's Today screen opens on what the agents did overnight: 583 statements checked, 41 that differ from practice — 3 for the first time — 4 decisions for her, and 86.5% of people who have accepted Acceptable Use v3.0. The decisions are ordered by risk: 37 service accounts that break the MFA promise, the Cryptography Policy review 31 days overdue, an expired exception at Bremen Line 4, and four Annex A controls with no statement.

    Change watcher: “Incident Response §3.2 promises notice ‘within 72 hours’; NIS2 needs an early warning within 24 hours. I opened a review with Sofia Reyes.”

  2. 02She asks

    “Why is Access Control red?” — answered with its sources

    Rachel Kim · CISO

    She types the question in plain words. The Reality agent answers: §5.3 promises MFA for all privileged access, and last night 37 of 2,214 privileged accounts had none. All 37 are service accounts in six integrations, and the safeguards for an exception hold for 34. Each figure carries a numbered source she can click to read, and the answer ends with one action: open the finding.

    Every answer cites the record it came from; any action waits for a person to confirm it.

  3. 03The policy

    Every “shall” threaded to its evidence

    Daniel Osei · Head of Identity & Access, policy owner

    The Access Control Policy v4.2 reads like the document it is, with every “shall” underlined. A thread runs from each statement to its procedure, owner, Annex A or SOC 2 control and the live evidence: green where practice matches, red where it differs, dashed where no system can show it yet. Of 46 statements, 41 match, 3 differ and 2 are untested. The red thread on §5.3 carries the finding: 2,177 of 2,214 privileged accounts use MFA; 37 service accounts do not.

    §5.3 · Differs · A.8.5, A.8.2, CC6.1 · procedure ACS-02 §3.2 · tested Thu 02:10 · confidence 0.97

  4. 0402:14

    The test, step by step, with the rows it read

    Reality agent

    The finding shows the agent's plan as it ran: read the statement and what it means, read the identity export of 14 Oct, 23:00, match the sign-in method of every account, reconcile the count with the privileged access vault, and report. 1,612 personal admin accounts use MFA; 565 service accounts use workload identity; 37 sign in with a password only. Anyone can press “Test again”.

    “Confidence 0.97 — complete export, reconciled to the vault. Not 1.0 because 4 accounts were created after 23:00 and will be read tonight.”

  5. 0502:18 – 02:24

    The safeguards tested, and two honest options

    Exception keeper and Drafter

    The Exception keeper tests the safeguards the Access Control Standard ACS-02 allows instead of MFA: credentials held in the vault 37 of 37, sign-in limited to the four data-centre address ranges 37 of 37, password rotated in the last 30 days 34 of 37. The Drafter costs both ways out. A: move the six integrations to workload identity — 6 weeks, about 30 engineering days, owner Daniel Osei. B: record exception EX-2026-031 today, rotate the 3 overdue passwords by 22 Oct, review in 90 days, with A as the long-term fix. The 37 accounts are listed by integration: ERP batch jobs 11, label printing at plants 8, payroll export 6, backup agents 5, monitoring 4, bank file transfer 3.

    Asked to “rotate the 3 overdue passwords now”, the Exception keeper answers: “I do not change systems” — and drafts the request to the identity engineering lead.

  6. 06She decides

    Approve, approve with edits, or reject — with a reason code

    Rachel Kim · CISO

    Rachel chooses option B. The decision asks for a review date (13 Jan 2027), an exception owner (Daniel Osei), the condition — rotate the 3 overdue passwords by 22 Oct 2026 — and a reason code: EX-C2 · Compensating controls verified. She ticks “I, Rachel Kim (CISO), sign this decision” and signs. A rejection would need a note.

    Agents change nothing until she signs.

  7. 07Recorded

    The register shows it, with its expiry

    Exception keeper

    EX-2026-031 joins the exceptions register: 15 open, every one approved by the CISO, none longer than 180 days. The Exception keeper will re-test the three safeguards 22 Oct and before the review date. The same register shows the one that slipped: EX-2025-019, the Bremen Line 4 workstation on an unsupported operating system, expired on 12 Oct. The agent asked Ben Carter whether the machine is still needed, and offers to re-test its safeguards before Rachel renews or closes it.

    An expired exception turns the statement red again on the policy; it is never extended without a new decision.

  8. 08The next version

    New wording, tested before it can be signed

    Drafter, Daniel Osei and two checks

    The Drafter redlines v4.3: “All privileged access by people shall use phishing-resistant multi-factor authentication. Non-interactive service accounts shall hold vaulted credentials rotated at least every 30 days, or an approved exception.” A new §8.6 makes the rotation a promise that can be tested nightly. Daniel accepts it — “keep phishing-resistant; it matches our token rollout”. The Coverage reviewer confirms A.8.5, A.8.2, A.5.17 and CC6.1 are still covered. The Reality agent's truth test: true today for people, 1,612 of 1,612; true for service accounts once the exception's condition is met on 22 Oct. Only then can Rachel sign.

    “No wording change for §6.1 and §7.2. They are right; practice must catch up.”

  9. 09The gap check

    What no policy covers, every night instead of once a year

    Coverage reviewer

    Every statement is mapped to the 93 Annex A controls, the 33 SOC 2 criteria and NIS2 Article 21. 89 of 93 controls have a statement. The four gaps — 5.7, 8.10, 8.11 and 8.12 — are all among the 11 controls new in 2022: the library was first mapped to the 2013 edition. Click A.5.7, threat intelligence: no policy says anything that meets it, and the Coverage reviewer suggests Sofia Reyes as its owner. One click asks the Drafter for statements.

  10. 10On the shop floor

    Only his rules, in his language, and he can ask

    Jonas Weber · Warehouse Supervisor, Bremen

    The Acceptable Use campaign reaches Jonas on the shared terminal in German: six rules that apply to him as a warehouse supervisor, each in plain words with its clause, to read and accept by 31 October. He asks whether he can read work email on his phone; the Attestation agent answers from §4.2 — only in the company mail app — and cites it. A question the policy does not answer goes to its owner, with a reply within one working day.

    64 of 312 questions were about §4.2, so the Drafter proposed a clearer wording for v3.1.

Who it’s for

Built for everyone who answers for a policy.

The same policy set, seen by the five people who carry it — what their year looked like, and what it looks like now.

RK
Rachel KimCISO · approves every policy version and every exception
CISO
Before
“I sign these policies. I need to know they are true.” Finds out they are not when the auditor samples practice.
Now
Starts each morning with what the nightly test found and the decisions that need her, each with its records, options and a reason code to sign with.
DO
Daniel OseiHead of Identity & Access · owner of the Access Control Policy
Policy owner
Before
“Tell me which sentence is wrong and what it would take to make it right.” Reviews his policy once a year by re-dating it.
Now
Sees each of his 46 statements threaded to its evidence, the three that differ with their records, and a redline he edits instead of a blank page.
ML
Marta LindqvistGRC Analyst · reviews, campaigns, exceptions and the audit evidence
GRC analyst
Before
“Half my year is chasing owners and mapping spreadsheets.”
Now
Runs acceptance by business and site, reminds the 5,225 still pending in one step, and lets the agents answer the questions — 297 of 312 so far.
JW
Jonas WeberWarehouse Supervisor, Bremen plant · asked to accept
Employee
Before
“Just tell me what applies to me, in German.” Clicks “accept” on a long policy between shifts.
Now
Reads six rules that apply to his job, in German, asks his question and gets an answer with the clause.
FH
Fatima HaddadInternal Audit Manager · read-only
Internal auditor
Before
“Show me who approved it, when, and on what evidence.” Pieces it together from email and file names.
Now
Reads every action by people and agents on one trail, verifies the chain and exports it for the certification body.
Built on the engine

6 agents. Each with one job, and hard limits.

Six specialist agents draft the wording, test every “shall” against real systems each night, check coverage and exceptions, and run acceptance; the CISO signs.

Drafter

Writes and updates policy wording, proposes options for a broken promise and clarifications for unclear clauses, and redlines every change with its cited reason and a plain-language score.

  • Never approves its own text
  • Never publishes or edits a signed version
  • Cites a reason for every change
Reality agent

Turns each “shall” into a test against the system that would prove it — identity directory, privileged access vault, IT service desk, HR, endpoint, cloud configuration, vulnerability scanner — runs it every night and records the rows it read and its confidence.

  • Read-only on every system
  • Below confidence 0.85 a person checks the result
  • Never marks a match without rows read
Coverage reviewer

Maps every statement and every draft to the 93 Annex A controls, the 33 SOC 2 criteria and NIS2 Article 21, finds gaps and the controls that rest on a statement that differs.

  • Never closes a gap itself
  • Checks every Drafter text before signature
Exception keeper

Keeps the exceptions register, tests the compensating controls an exception relies on, and re-tests them before expiry.

  • Never grants an exception
  • Never longer than 180 days
  • Does not change systems; drafts the request instead
Attestation agent

Runs read-and-accept campaigns by role and site, shows people only the rules that apply to them in their language, answers their questions from the policy and clusters the questions by clause.

  • Answers only from the policy text
  • Routes anything else to the owner
  • Never accepts for a person
Change watcher

Reads law and standard updates, new systems in the asset inventory and incidents, names the exact statements they affect and opens a review with the owner.

  • Never edits a policy; only opens a review
CISO

Signs; policy owners review their drafts. The agents propose; a named person decides.

Ask in plain words

Ask the agents, in plain words

On every screen — the briefing, the policy, the finding, the draft, the campaign — ask a question or say what to do. Answers cite the record; actions wait for you to confirm.

Why is Access Control red?

Because §5.3 promises MFA for all privileged access, and last night 37 of 2,214 privileged accounts had none. All 37 are service accounts in six integrations; the safeguards for an exception hold for 34.

Which integrations would break if we enforce MFA today?

All six: ERP batch jobs (11 accounts), label printing at plants (8), payroll export (6), backup agents (5), monitoring (4), bank file transfer (3). None can answer a second factor; they need workload identity.

Rotate the 3 overdue passwords now

I do not change systems. I have drafted the rotation request to Priyanka Nair, Identity Engineering Lead, for svc-bankfx-02, svc-payroll-exp-04 and svc-label-mty-02.

What will the auditor find on 18 November?

If nothing changes: the overdue Cryptography review; access reviews and leavers, which auditors sample first — AC §6.1 and §7.2 differ; and 4 Annex A controls with no statement.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

TodayThe CISO's morning briefing: what was tested overnight, what differs, the decisions that need her and what each agent did.
Ask the agentsA question in plain words, answered with numbered sources and one action to confirm.
Policy threadsThe policy as a document, every “shall” underlined and threaded to its procedure, owner, control and live evidence — green, red or untested.
The findingThe Reality agent's test step by step, the systems it read, its confidence, and the safeguards the Exception keeper tested.
Two honest optionsFix the practice or record an exception with conditions, each with time, cost and safeguards — and the 37 accounts by integration.
The decisionApprove, approve with edits or reject, with a review date, a condition, a reason code and the CISO's signature.
Exceptions registerEvery exception with its owner, risk and expiry; the Exception keeper's last test and what happens at expiry.
The next versionA redline with a cited reason for each change, the owner's review and the two checks that must pass before the CISO signs.
Framework coverageAll 93 Annex A controls by theme, the four with no statement, and a draft for a gap one click away. SOC 2 and NIS2 on the same screen.
Acceptance campaignAcceptance by business and site, the sites furthest behind, and the questions people asked.
The employee's viewOnly the rules that apply to the person, in their language, with a place to ask and to accept.
Audit trailEvery action by people and agents, with what it was on and why, hash-chained, verifiable and exportable.
Your rulesThe nightly test time, confidence floor, longest exception, review cycle and per-statement tolerances — all settings, changed with a reason.
Governance

Built for the audit: cited, signed, on the record.

Every value cites its sourceEach figure and each agent statement links to the record behind it — the system export with its timestamp, the clause, the standard — and a click reads the passage.
Agents read systems, never change themThe connections are read-only. An agent asked to rotate a password or fix a setting drafts the request for the person who owns it.
Only the CISO approvesEvery policy version and every exception is approved by the CISO with a reason code; a rejection needs a note. Owners review their drafts first.
Agents check each otherThe Drafter never approves its own text. The Coverage reviewer and the Reality agent must pass a new wording before the CISO can sign it.
Exceptions expire, and are re-testedNo exception runs longer than 180 days. Its safeguards are re-tested before expiry, and an expired exception turns the statement red again until someone decides.
A trail that shows tamperingEvery action by people and agents is on a hash-chained audit trail that internal audit can verify and export; access is scoped by role, and employees see only their own rules.
Configuration

Your rules, not ours

What Kestrel & Vane decided: frameworks, rules, connections and reminders. Every change asks for a reason and is logged.

SettingDefaultChoose from
Nightly practice test02:00The time the Reality agent tests every statement
Confidence floor0.85Below it, a person checks the result before it counts as a match
Longest exception180 daysThe Exception keeper cannot propose longer
Review cycle12 months, or on significant changeOwners reminded 60, 30 and 7 days before; CISO told at 14 days overdue
Tolerance · leavers (AC §7.2)0 late accountsSet per statement
Tolerance · patching (VM §3.2)2% of findings, up to 7 days lateSet per statement
FrameworksISO/IEC 27001:2022 Annex A · SOC 2 · NIS2 Article 21(2)Annex A (93 controls) · SOC 2 (33 common criteria) · NIS2 Art. 21(2) (10 measures) · DORA Article 9, for financial entities
Acceptance reminders7, 3 and 1 day before; managers after the due dateAnnual campaigns, in 11 languages
Connections

Works with the systems that prove practice

Document storethe policies and standards you have today, split into their “shall” statements
Identity directory and privileged access vaultaccounts, sign-in methods, privileged roles, checkouts and rotation
IT service desk and HR systemaccess requests, changes and revocations; starters, leavers and role changes
Endpoint, cloud and vulnerability scannerdevice encryption and data-loss rules, cloud configuration, scan findings
Learning platformacceptance campaigns and the record of who accepted which version
FrameworksISO/IEC 27001:2022 Annex A, SOC 2 Trust Services Criteria, NIS2 Article 21, DORA Article 9
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
583of 583
policy statements checked against practice every night; any no system can show go to their owner for evidence
Every night
24 policies, 7 systems
typical
EUR 5–15k
what an external ISO 27001 gap analysis typically costs; here the coverage check re-runs every night
TodayOnce a year, by consultants
With agentsEvery night, cited
typical
EUR 10Mor 2%
NIS2 maximum fine for essential entities, whose management body approves these policies

“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (a 2026 ISO 27001 checklist quoting vendor figures — external gap analysis EUR 5–15k; Directive (EU) 2022/2555 (NIS2) Art. 20, 21 and 34 — fines for essential entities of at least EUR 10M or 2% of worldwide turnover, whichever is higher; ISO/IEC 27001:2022 Annex A — 93 controls, 11 new in 2022). Kestrel & Vane Group and the people named on this page are fictional — characters and sample data in the working solution.

Questions

What CISOs and GRC teams ask us.

What is Security Policy Management?

Information security policy management that treats each policy as a set of promises and tests them. Six agents split every policy into its “shall” statements, test each one against the systems that prove it every night, check coverage against ISO 27001 Annex A and SOC 2, keep the exceptions register and run acceptance campaigns. The CISO signs every version and every exception.

How does it test a policy against practice?

The Reality agent turns each statement into a test against a system of record — the identity directory, privileged access vault, IT service desk, HR system, endpoint management, cloud configuration or vulnerability scanner — and runs it every night. It shows its plan, the rows it read and its confidence; below 0.85 a person checks the result. Statements no system can show go to their owner for evidence.

Does it replace an ISO 27001 gap analysis?

It re-runs the coverage check every night. The Coverage reviewer maps every statement and every new draft to the 93 Annex A controls, the 33 SOC 2 criteria and NIS2 Article 21, names the controls with no statement and the ones resting on a statement that differs, and asks the Drafter for wording to close a gap.

How are policy exceptions handled?

An owner requests an exception with its compensating controls; the Exception keeper tests those controls and routes it to the CISO, who approves with a reason code, a review date and any condition. No exception runs longer than 180 days, safeguards are re-tested before expiry, and an expired exception turns the statement red again.

How does policy attestation work?

The Attestation agent asks only the people a policy applies to, by role and site, in their language. They read the rules that apply to them and can ask questions; the agent answers from the policy with the clause cited, or sends the question to the owner. Questions that cluster on one clause become a proposed clarification.

Does the AI change our systems or publish policies?

No. The agents read systems and never change them, never publish, never grant an exception and never approve their own text. A request to change a system becomes a drafted request for the person who owns it.

Do people stay in control?

Yes. Policy owners review their drafts, the Coverage reviewer and Reality agent must pass a new wording, and only the CISO approves a version or an exception, with a reason code; a rejection needs a note. Every action by people and agents is on a hash-chained audit trail.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents — your policy set, standards and the systems that prove practice — and it goes live once every quality gate has passed. We will walk you through it on your own policies first.

See it on
your policies.

We'll run Security Policy Management on your own policy set and the systems that prove it.