SOC2-2017 Trust Services Criteria

SOC2-2017

TSP Section 100 2017 Trust Services Criteria for Security, Availability, Processing Integrity, Confidentiality, and Privacy

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A1.1 Additional Criteria for Availability

A1.1

The entity maintains, monitors, and evaluates current processing capacity and use of system components (infrastructure, data, and software) to manage capacity demand and to enable the implementation o...

A1.1.1 Additional Criteria for Availability

A1.1.1

Measures Current Usage — The use of the system components is measured to establish a baseline for capacity management and to use when evaluating the risk of impaired availability due to capacity const...

A1.1.2 Additional Criteria for Availability

A1.1.2

Forecasts Capacity — The expected average and peak use of system components is forecasted and compared to system capacity and associated tolerances. Forecasting considers capacity in the event of the...

A1.1.3 Additional Criteria for Availability

A1.1.3

Makes Changes Based on Forecasts — The system change management process is initiated when forecasted usage exceeds capacity tolerances.

A1.2 Additional Criteria for Availability

A1.2

The entity authorizes, designs, develops or acquires, implements, operates, approves, maintains, and monitors environmental protections, software, data back-up processes, and recovery infrastructure t...

A1.2.1 Additional Criteria for Availability

A1.2.1

Identifies Environmental Threats — As part of the risk assessment process, management identifies environmental threats that could impair the availability of the system, including threats resulting fro...

A1.2.10 Additional Criteria for Availability

A1.2.10

Implements Alternate Processing Infrastructure — Measures are implemented for migrating processing to alternate infrastructure in the event normal processing infrastructure becomes unavailable.

A1.2.2 Additional Criteria for Availability

A1.2.2

Designs Detection Measures — Detection measures are implemented to identify anomalies that could result from environmental threat events.

A1.2.3 Additional Criteria for Availability

A1.2.3

Implements and Maintains Environmental Protection Mechanisms — Management implements and maintains environmental protection mechanisms to prevent and mitigate against environmental events.

A1.2.4 Additional Criteria for Availability

A1.2.4

Implements Alerts to Analyze Anomalies — Management implements alerts that are communicated to personnel for analysis to identify environmental threat events.

A1.2.5 Additional Criteria for Availability

A1.2.5

Responds to Environmental Threat Events — Procedures are in place for responding to environmental threat events and for evaluating the effectiveness of those policies and procedures on a periodic basi...

A1.2.6 Additional Criteria for Availability

A1.2.6

Communicates and Reviews Detected Environmental Threat Events — Detected environmental threat events are communicated to and reviewed by the individuals responsible for the management of the system, a...

A1.2.7 Additional Criteria for Availability

A1.2.7

Determines Data Requiring Backup — Data is evaluated to determine whether backup is required.

A1.2.8 Additional Criteria for Availability

A1.2.8

Performs Data Backup — Procedures are in place for backing up data, monitoring to detect back-up failures, and initiating corrective action when such failures occur.

A1.2.9 Additional Criteria for Availability

A1.2.9

Addresses Offsite Storage — Back-up data is stored in a location at a distance from its principal storage location sufficient that the likelihood of a security or environmental threat event affecting...

A1.3 Additional Criteria for Availability

A1.3

The entity tests recovery plan procedures supporting system recovery to meet its objectives.

A1.3.1 Additional Criteria for Availability

A1.3.1

Implements Business Continuity Plan Testing — Business continuity plan testing is performed on a periodic basis. The testing includes (1) development of testing scenarios based on threat likelihood an...

A1.3.2 Additional Criteria for Availability

A1.3.2

Tests Integrity and Completeness of Back-Up Data — The integrity and completeness of back-up information is tested on a periodic basis.

C1.1 Additional Criteria for Confidentiality

C1.1

The entity identifies and maintains confidential information to meet the entity’s objectives related to confidentiality.

C1.1.1 Additional Criteria for Confidentiality

C1.1.1

Identifies Confidential information — Procedures are in place to identify and designate confidential information when it is received or created and to determine the period over which the confidential...

C1.1.2 Additional Criteria for Confidentiality

C1.1.2

Protects Confidential Information from Destruction — Procedures are in place to protect confidential information from erasure or destruction during the specified retention period of the information.

C1.2 Additional Criteria for Confidentiality

C1.2

The entity disposes of confidential information to meet the entity’s objectives related to confidentiality.

C1.2.1 Additional Criteria for Confidentiality

C1.2.1

Identifies Confidential Information for Destruction — Procedures are in place to identify confidential information requiring destruction when the end of the retention period is reached.

C1.2.2 Additional Criteria for Confidentiality

C1.2.2

Destroys Confidential Information — Procedures are in place to erase or otherwise destroy confidential information that has been identified for destruction.

P1.1 Additional Criteria for Privacy

P1.1

The entity provides notice to data subjects about its privacy practices to meet the entity’s objectives related to privacy. The notice is updated and communicated to data subjects in a timely manner f...

P1.1.1 Additional Criteria for Privacy

P1.1.1

Communicates to Data Subjects — Notice is provided to data subjects regarding the following: — — Purpose for collecting personal information — — Choice and consent — — Types of personal information co...

P1.1.2 Additional Criteria for Privacy

P1.1.2

Provides Notice to Data Subjects — Notice is provided to data subjects (1) at or before the time personal information is collected or as soon as practical thereafter, (2) at or before the entity chang...

P1.1.3 Additional Criteria for Privacy

P1.1.3

Covers Entities and Activities in Notice — An objective description of the entities and activities covered is included in the entity’s privacy notice.

P1.1.4 Additional Criteria for Privacy

P1.1.4

Uses Clear and Conspicuous Language — The entity’s privacy notice is conspicuous and uses clear language.

P2.1 Additional Criteria for Privacy

P2.1

The entity communicates choices available regarding the collection, use, retention, disclosure, and disposal of personal information to the data subjects and the consequences, if any, of each choice....

P2.1.1 Additional Criteria for Privacy

P2.1.1

Communicates to Data Subjects — Data subjects are informed (a) about the choices available to them with respect to the collection, use, and disclosure of personal information and (b) that implicit or...

P2.1.2 Additional Criteria for Privacy

P2.1.2

Communicates Consequences of Denying or Withdrawing Consent — When personal information is collected, data subjects are informed of the consequences of refusing to provide personal information or deny...

P2.1.3 Additional Criteria for Privacy

P2.1.3

Obtains Implicit or Explicit Consent — Implicit or explicit consent is obtained from data subjects at or before the time personal information is collected or soon thereafter. The individual’s preferen...

P2.1.4 Additional Criteria for Privacy

P2.1.4

Documents and Obtains Consent for New Purposes and Uses — If information that was previously collected is to be used for purposes not previously identified in the privacy notice, the new purpose is do...

P2.1.5 Additional Criteria for Privacy

P2.1.5

Obtains Explicit Consent for Sensitive Information — Explicit consent is obtained directly from the data subject when sensitive personal information is collected, used, or disclosed, unless a law or r...

P2.1.6 Additional Criteria for Privacy

P2.1.6

Obtains Consent for Data Transfers — Consent is obtained before personal information is transferred to or from an individual’s computer or other similar device.

P3.1 Additional Criteria for Privacy

P3.1

Personal information is collected consistent with the entity’s objectives related to privacy.

P3.1.1 Additional Criteria for Privacy

P3.1.1

Limits the Collection of Personal Information — The collection of personal information is limited to that necessary to meet the entity’s objectives.

P3.1.2 Additional Criteria for Privacy

P3.1.2

Collects Information by Fair and Lawful Means — Methods of collecting personal information are reviewed by management before they are implemented to confirm that personal information is obtained (a) f...

P3.1.3 Additional Criteria for Privacy

P3.1.3

Collects Information From Reliable Sources — Management confirms that third parties from whom personal information is collected (that is, sources other than the individual) are reliable sources that c...

P3.1.4 Additional Criteria for Privacy

P3.1.4

Informs Data Subjects When Additional Information Is Acquired — Data subjects are informed if the entity develops or acquires additional information about them for its use.

P3.2 Additional Criteria for Privacy

P3.2

For information requiring explicit consent, the entity communicates the need for such consent, as well as the consequences of a failure to provide consent for the request for personal information, and...

P3.2.1 Additional Criteria for Privacy

P3.2.1

Obtains Explicit Consent for Sensitive Information — Explicit consent is obtained directly from the data subject when sensitive personal information is collected, used, or disclosed, unless a law or r...

P3.2.2 Additional Criteria for Privacy

P3.2.2

Documents Explicit Consent to Retain Information — Documentation of explicit consent for the collection, use, or disclosure of sensitive personal information is retained in accordance with objectives...

P4.1 Additional Criteria for Privacy

P4.1

The entity limits the use of personal information to the purposes identified in the entity’s objectives related to privacy.

P4.1.1 Additional Criteria for Privacy

P4.1.1

Uses Personal Information for Intended Purposes — Personal information is used only for the intended purposes for which it was collected and only when implicit or explicit consent has been obtained un...

P4.2 Additional Criteria for Privacy

P4.2

The entity retains personal information consistent with the entity’s objectives related to privacy.

P4.2.1 Additional Criteria for Privacy

P4.2.1

Retains Personal Information — Personal information is retained for no longer than necessary to fulfill the stated purposes, unless a law or regulation specifically requires otherwise.

P4.2.2 Additional Criteria for Privacy

P4.2.2

Protects Personal Information — Policies and procedures have been implemented to protect personal information from erasure or destruction during the specified retention period of the information.

P4.3 Additional Criteria for Privacy

P4.3

The entity securely disposes of personal information to meet the entity’s objectives related to privacy.

P4.3.1 Additional Criteria for Privacy

P4.3.1

Captures, Identifies, and Flags Requests for Deletion — Requests for deletion of personal information are captured, and information related to the requests is identified and flagged for destruction to...

P4.3.2 Additional Criteria for Privacy

P4.3.2

Disposes of, Destroys, and Redacts Personal Information — Personal information no longer retained is anonymized, disposed of, or destroyed in a manner that prevents loss, theft, misuse, or unauthorize...

P4.3.3 Additional Criteria for Privacy

P4.3.3

Destroys Personal Information — Policies and procedures are implemented to erase or otherwise destroy personal information that has been identified for destruction.

P5.1 Additional Criteria for Privacy

P5.1

The entity grants identified and authenticated data subjects the ability to access their stored personal information for review and, upon request, provides physical or electronic copies of that inform...

P5.1.1 Additional Criteria for Privacy

P5.1.1

Authenticates Data Subjects’ Identity — The identity of data subjects who request access to their personal information is authenticated before they are given access to that information.

P5.1.2 Additional Criteria for Privacy

P5.1.2

Permits Data Subjects Access to Their Personal Information — Data subjects are able to determine whether the entity maintains personal information about them and, upon request, may obtain access to th...

P5.1.3 Additional Criteria for Privacy

P5.1.3

Provides Understandable Personal Information Within Reasonable Time — Personal information is provided to data subjects in an understandable form, in a reasonable time frame, and at a reasonable cost,...

P5.1.4 Additional Criteria for Privacy

P5.1.4

Informs Data Subjects If Access Is Denied — When data subjects are denied access to their personal information, the entity informs them of the denial and the reason for the denial in a timely manner,...

P5.2 Additional Criteria for Privacy

P5.2

The entity corrects, amends, or appends personal information based on information provided by data subjects and communicates such information to third parties, as committed or required, to meet the en...

P5.2.1 Additional Criteria for Privacy

P5.2.1

Communicates Denial of Access Requests — Data subjects are informed, in writing, of the reason a request for access to their personal information was denied, the source of the entity’s legal right to...

P5.2.2 Additional Criteria for Privacy

P5.2.2

Permits Data Subjects to Update or Correct Personal Information — Data subjects are able to update or correct personal information held by the entity. The entity provides such updated or corrected inf...

P5.2.3 Additional Criteria for Privacy

P5.2.3

Communicates Denial of Correction Requests — Data subjects are informed, in writing, about the reason a request for correction of personal information was denied and how they may appeal.

P6.1 Additional Criteria for Privacy

P6.1

The entity discloses personal information to third parties with the explicit consent of data subjects, and such consent is obtained prior to disclosure to meet the entity’s objectives related to priva...

P6.1.1 Additional Criteria for Privacy

P6.1.1

Communicates Privacy Policies to Third Parties — Privacy policies or other specific instructions or requirements for handling personal information are communicated to third parties to whom personal in...

P6.1.2 Additional Criteria for Privacy

P6.1.2

Discloses Personal Information Only When Appropriate — Personal information is disclosed to third parties only for the purposes for which it was collected or created and only when implicit or explicit...

P6.1.3 Additional Criteria for Privacy

P6.1.3

Discloses Personal Information Only to Appropriate Third Parties — Personal information is disclosed only to third parties who have agreements with the entity to protect personal information in a mann...

P6.1.4 Additional Criteria for Privacy

P6.1.4

Discloses Information to Third Parties for New Purposes and Uses — Personal information is disclosed to third parties for new purposes or uses only with the prior implicit or explicit consent of data...

P6.2 Additional Criteria for Privacy

P6.2

The entity creates and retains a complete, accurate, and timely record of authorized disclosures of personal information to meet the entity’s objectives related to privacy.

P6.2.1 Additional Criteria for Privacy

P6.2.1

Creates and Retains Record of Authorized Disclosures — The entity creates and maintains a record of authorized disclosures of personal information that is complete, accurate, and timely.

P6.3 Additional Criteria for Privacy

P6.3

The entity creates and retains a complete, accurate, and timely record of detected or reported unauthorized disclosures (including breaches) of personal information to meet the entity’s objectives rel...

P6.3.1 Additional Criteria for Privacy

P6.3.1

Creates and Retains Record of Detected or Reported Unauthorized Disclosures — The entity creates and maintains a record of detected or reported unauthorized disclosures of personal information that is...

P6.4 Additional Criteria for Privacy

P6.4

The entity obtains privacy commitments from vendors and other third parties who have access to personal information to meet the entity’s objectives related to privacy. The entity assesses those partie...

P6.4.1 Additional Criteria for Privacy

P6.4.1

Discloses Personal Information Only to Appropriate Third Parties — Personal information is disclosed only to third parties who have agreements with the entity to protect personal information in a mann...

P6.4.2 Additional Criteria for Privacy

P6.4.2

Remediates Misuse of Personal Information by a Third Party — The entity takes remedial action in response to misuse of personal information by a third party to whom the entity has transferred such inf...

P6.5 Additional Criteria for Privacy

P6.5

The entity obtains commitments from vendors and other third parties with access to personal information to notify the entity in the event of actual or suspected unauthorized disclosures of personal in...

P6.5.1 Additional Criteria for Privacy

P6.5.1

Remediates Misuse of Personal Information by a Third Party — The entity takes remedial action in response to misuse of personal information by a third party to whom the entity has transferred such inf...

P6.5.2 Additional Criteria for Privacy

P6.5.2

Reports Actual or Suspected Unauthorized Disclosures — A process exists for obtaining commitments from vendors and other third parties to report to the entity actual or suspected unauthorized disclosu...

P6.6 Additional Criteria for Privacy

P6.6

The entity provides notification of breaches and incidents to affected data subjects, regulators, and others to meet the entity’s objectives related to privacy.

P6.6.1 Additional Criteria for Privacy

P6.6.1

Remediates Misuse of Personal Information by a Third Party — The entity takes remedial action in response to misuse of personal information by a third party to whom the entity has transferred such inf...

P6.6.2 Additional Criteria for Privacy

P6.6.2

Provides Notice of Breaches and Incidents — The entity has a process for providing notice of breaches and incidents to affected data subjects, regulators, and others to meet the entity’s objectives re...

P6.7 Additional Criteria for Privacy

P6.7

The entity provides data subjects with an accounting of the personal information held and disclosure of the data subjects’ personal information, upon the data subjects’ request, to meet the entity’s o...

P6.7.1 Additional Criteria for Privacy

P6.7.1

Identifies Types of Personal Information and Handling Process — The types of personal information and sensitive personal information and the related processes, systems, and third parties involved in t...

P6.7.2 Additional Criteria for Privacy

P6.7.2

Captures, Identifies, and Communicates Requests for Information — Requests for an accounting of personal information held and disclosures of the data subjects’ personal information are captured, and i...

P7.1 Additional Criteria for Privacy

P7.1

The entity collects and maintains accurate, up-to-date, complete, and relevant personal information to meet the entity’s objectives related to privacy.

P7.1.1 Additional Criteria for Privacy

P7.1.1

Ensures Accuracy and Completeness of Personal Information — Personal information is accurate and complete for the purposes for which it is to be used.

P7.1.2 Additional Criteria for Privacy

P7.1.2

Ensures Relevance of Personal Information — Personal information is relevant to the purposes for which it is to be used.

P8.1 Additional Criteria for Privacy

P8.1

The entity implements a process for receiving, addressing, resolving, and communicating the resolution of inquiries, complaints, and disputes from data subjects and others and periodically monitors co...

P8.1.1 Additional Criteria for Privacy

P8.1.1

Communicates to Data Subjects — Data subjects are informed about how to contact the entity with inquiries, complaints, and disputes.

P8.1.2 Additional Criteria for Privacy

P8.1.2

Addresses Inquiries, Complaints, and Disputes — A process is in place to address inquiries, complaints, and disputes.

P8.1.3 Additional Criteria for Privacy

P8.1.3

Documents and Communicates Dispute Resolution and Recourse — Each complaint is addressed, and the resolution is documented and communicated to the individual.

P8.1.4 Additional Criteria for Privacy

P8.1.4

Documents and Reports Compliance Review Results — Compliance with objectives related to privacy are reviewed and documented, and the results of such reviews are reported to management. If problems are...

P8.1.5 Additional Criteria for Privacy

P8.1.5

Documents and Reports Instances of Noncompliance — Instances of noncompliance with objectives related to privacy are documented and reported and, if needed, corrective and disciplinary measures are ta...

P8.1.6 Additional Criteria for Privacy

P8.1.6

Performs Ongoing Monitoring — Ongoing procedures are performed for monitoring the effectiveness of controls over personal information and for taking timely corrective actions when necessary.

PI1.1 Additional Criteria for Processing Integrity

PI1.1

The entity obtains or generates, uses, and communicates relevant, quality information regarding the objectives related to processing, including definitions of data processed and product and service sp...

PI1.1.1 Additional Criteria for Processing Integrity

PI1.1.1

Identifies Information Specifications — The entity identifies information specifications required to support the use of products and services.

PI1.1.2 Additional Criteria for Processing Integrity

PI1.1.2

Defines Data Necessary to Support a Product or Service — When data is provided as part of a service or product or as part of a reporting obligation related to a product or service: — 1. The definitio...

PI1.2 Additional Criteria for Processing Integrity

PI1.2

The entity implements policies and procedures over system inputs, including controls over completeness and accuracy, to result in products, services, and reporting to meet the entity’s objectives.

PI1.2.1 Additional Criteria for Processing Integrity

PI1.2.1

Defines Characteristics of Processing Inputs — The characteristics of processing inputs that are necessary to meet requirements are defined.

PI1.2.2 Additional Criteria for Processing Integrity

PI1.2.2

Evaluates Processing Inputs — Processing inputs are evaluated for compliance with defined input requirements.

PI1.2.3 Additional Criteria for Processing Integrity

PI1.2.3

Creates and Maintains Records of System Inputs — Records of system input activities are created and maintained completely and accurately in a timely manner.

PI1.3 Additional Criteria for Processing Integrity

PI1.3

The entity implements policies and procedures over system processing to result in products, services, and reporting to meet the entity’s objectives.

PI1.3.1 Additional Criteria for Processing Integrity

PI1.3.1

Defines Processing Specifications — The processing specifications that are necessary to meet product or service requirements are defined.

PI1.3.2 Additional Criteria for Processing Integrity

PI1.3.2

Defines Processing Activities — Processing activities are defined to result in products or services that meet specifications.

PI1.3.3 Additional Criteria for Processing Integrity

PI1.3.3

Detects and Corrects Production Errors — Errors in the production process are detected and corrected in a timely manner.

PI1.3.4 Additional Criteria for Processing Integrity

PI1.3.4

Records System Processing Activities — System processing activities are recorded completely and accurately in a timely manner.

PI1.3.5 Additional Criteria for Processing Integrity

PI1.3.5

Processes Inputs — Inputs are processed completely, accurately, and timely as authorized in accordance with defined processing activities.

PI1.4 Additional Criteria for Processing Integrity

PI1.4

The entity implements policies and procedures to make available or deliver output completely, accurately, and timely in accordance with specifications to meet the entity’s objectives.

PI1.4.1 Additional Criteria for Processing Integrity

PI1.4.1

Protects Output — Output is protected when stored or delivered, or both, to prevent theft, destruction, corruption, or deterioration that would prevent output from meeting specifications.

PI1.4.2 Additional Criteria for Processing Integrity

PI1.4.2

Distributes Output Only to Intended Parties — Output is distributed or made available only to intended parties.

PI1.4.3 Additional Criteria for Processing Integrity

PI1.4.3

Distributes Output Completely and Accurately — Procedures are in place to provide for the completeness, accuracy, and timeliness of distributed output.

PI1.4.4 Additional Criteria for Processing Integrity

PI1.4.4

Creates and Maintains Records of System Output Activities — Records of system output activities are created and maintained completely and accurately in a timely manner.

PI1.5 Additional Criteria for Processing Integrity

PI1.5

The entity implements policies and procedures to store inputs, items in processing, and outputs completely, accurately, and timely in accordance with system specifications to meet the entity’s objecti...

PI1.5.1 Additional Criteria for Processing Integrity

PI1.5.1

Protects Stored Items — Stored items are protected to prevent theft, corruption, destruction, or deterioration that would prevent output from meeting specifications.

PI1.5.2 Additional Criteria for Processing Integrity

PI1.5.2

Archives and Protects System Records — System records are archived, and archives are protected against theft, corruption, destruction, or deterioration that would prevent them from being used.

PI1.5.3 Additional Criteria for Processing Integrity

PI1.5.3

Stores Data Completely and Accurately — Procedures are in place to provide for the complete, accurate, and timely storage of data.

PI1.5.4 Additional Criteria for Processing Integrity

PI1.5.4

Creates and Maintains Records of System Storage Activities — Records of system storage activities are created and maintained completely and accurately in a timely manner.

CC8.1 Change Management

CC8.1

The entity authorizes, designs, develops or acquires, configures, documents, tests, approves, and implements changes to infrastructure, data, software, and procedures to meet its objectives.

CC8.1.1 Change Management

CC8.1.1

Manages Changes Throughout the System Lifecycle — A process for managing system changes throughout the lifecycle of the system and its components (infrastructure, data, software and procedures) is use...

CC8.1.10 Change Management

CC8.1.10

Identifies and Evaluates System Changes — Objectives affected by system changes are identified, and the ability of the modified system to meet the objectives is evaluated throughout the system develop...

CC8.1.11 Change Management

CC8.1.11

Identifies Changes in Infrastructure, Data, Software, and Procedures Required to Remediate Incidents — Changes in infrastructure, data, software, and procedures required to remediate incidents to cont...

CC8.1.12 Change Management

CC8.1.12

Creates Baseline Configuration of IT Technology — A baseline configuration of IT and control systems is created and maintained.

CC8.1.13 Change Management

CC8.1.13

Provides for Changes Necessary in Emergency Situations — A process is in place for authorizing, designing, testing, approving and implementing changes necessary in emergency situations (that is, chang...

CC8.1.14 Change Management

CC8.1.14

Protects Confidential Information — The entity protects confidential information during system design, development, testing, implementation, and change processes to meet the entity’s objectives relate...

CC8.1.15 Change Management

CC8.1.15

Protects Personal Information — The entity protects personal information during system design, development, testing, implementation, and change processes to meet the entity’s objectives related to pri...

CC8.1.2 Change Management

CC8.1.2

Authorizes Changes — A process is in place to authorize system changes prior to development.

CC8.1.3 Change Management

CC8.1.3

Designs and Develops Changes — A process is in place to design and develop system changes.

CC8.1.4 Change Management

CC8.1.4

Documents Changes — A process is in place to document system changes to support ongoing maintenance of the system and to support system users in performing their responsibilities.

CC8.1.5 Change Management

CC8.1.5

Tracks System Changes — A process is in place to track system changes prior to implementation.

CC8.1.6 Change Management

CC8.1.6

Configures Software — A process is in place to select and implement the configuration parameters used to control the functionality of software.

CC8.1.7 Change Management

CC8.1.7

Tests System Changes — A process is in place to test system changes prior to implementation.

CC8.1.8 Change Management

CC8.1.8

Approves System Changes — A process is in place to approve system changes prior to implementation.

CC8.1.9 Change Management

CC8.1.9

Deploys System Changes — A process is in place to implement system changes.

CC2.1 Communication and Information

COSO Principle 13

The entity obtains or generates and uses relevant, quality information to support the functioning of internal control.

CC2.1.1 Communication and Information

CC2.1.1

Identifies Information Requirements — A process is in place to identify the information required and expected to support the functioning of the other components of internal control and the achievement...

CC2.1.2 Communication and Information

CC2.1.2

Captures Internal and External Sources of Data — Information systems capture internal and external sources of data.

CC2.1.3 Communication and Information

CC2.1.3

Processes Relevant Data Into Information — Information systems process and transform relevant data into information.

CC2.1.4 Communication and Information

CC2.1.4

Maintains Quality Throughout Processing — Information systems produce information that is timely, current, accurate, complete, accessible, protected, verifiable, and retained. Information is reviewed...

CC2.2 Communication and Information

COSO Principle 14

The entity internally communicates information, including objectives and responsibilities for internal control, necessary to support the functioning of internal control.

CC2.2.1 Communication and Information

CC2.2.1

Communicates Internal Control Information — A process is in place to communicate required information to enable all personnel to understand and carry out their internal control responsibilities.

CC2.2.10 Communication and Information

CC2.2.10

Communicates System Objectives — The entity communicates its objectives to personnel to enable them to carry out their responsibilities.

CC2.2.11 Communication and Information

CC2.2.11

Communicates System Changes — System changes that affect responsibilities or the achievement of the entity's objectives are communicated in a timely manner.

CC2.2.2 Communication and Information

CC2.2.2

Communicates With the Board of Directors — Communication exists between management and the board of directors so that both have information needed to fulfill their roles with respect to the entity’s o...

CC2.2.3 Communication and Information

CC2.2.3

Provides Separate Communication Lines — Separate communication channels, such as whistle-blower hotlines, are in place and serve as fail-safe mechanisms to enable anonymous or confidential communicati...

CC2.2.4 Communication and Information

CC2.2.4

Selects Relevant Method of Communication — The method of communication considers the timing, audience, and nature of the information.

CC2.2.5 Communication and Information

CC2.2.5

Communicates Responsibilities — Entity personnel with responsibility for designing, developing, implementing, operating, maintaining, or monitoring system controls receive communications about their r...

CC2.2.6 Communication and Information

CC2.2.6

Communicates Information on Reporting Failures, Incidents, Concerns, and Other Matters — Entity personnel are provided with information on how to report systems failures, incidents, concerns, and othe...

CC2.2.7 Communication and Information

CC2.2.7

Communicates Objectives and Changes to Objectives — The entity communicates its objectives and changes to those objectives to personnel in a timely manner.

CC2.2.8 Communication and Information

CC2.2.8

Communicates Information to Improve Security Knowledge and Awareness — The entity communicates information to improve security knowledge and awareness and to model appropriate security behaviors to pe...

CC2.2.9 Communication and Information

CC2.2.9

Communicates Information About System Operation and Boundaries — The entity prepares and communicates information about the design and operation of the system and its boundaries to authorized personne...

CC2.3 Communication and Information

COSO Principle 15

The entity communicates with external parties regarding matters affecting the functioning of internal control.

CC2.3.1 Communication and Information

CC2.3.1

Communicates to External Parties — Processes are in place to communicate relevant and timely information to external parties, including shareholders, partners, owners, regulators, customers, financial...

CC2.3.10 Communication and Information

CC2.3.10

Communicates System Responsibilities — External users with responsibility for designing, developing, implementing, operating, maintaining, and monitoring system controls receive communications about t...

CC2.3.11 Communication and Information

CC2.3.11

Communicates Information on Reporting System Failures, Incidents, Concerns, and Other Matters — External users are provided with information on how to report systems failures, incidents, concerns, and...

CC2.3.2 Communication and Information

CC2.3.2

Enables Inbound Communications — Open communication channels allow input from customers, consumers, suppliers, external auditors, regulators, financial analysts, and others, providing management and t...

CC2.3.3 Communication and Information

CC2.3.3

Communicates With the Board of Directors — Relevant information resulting from assessments conducted by external parties is communicated to the board of directors.

CC2.3.4 Communication and Information

CC2.3.4

Provides Separate Communication Lines — Separate communication channels, such as whistle-blower hotlines, are in place and serve as fail-safe mechanisms to enable anonymous or confidential communicati...

CC2.3.5 Communication and Information

CC2.3.5

Selects Relevant Method of Communication — The method of communication considers the timing, audience, and nature of the communication and legal, regulatory, and fiduciary requirements and expectation...

CC2.3.6 Communication and Information

CC2.3.6

Communicates Objectives Related to Confidentiality and Changes to Objectives — The entity communicates, to external users, vendors, business partners and others whose products and services are part of...

CC2.3.7 Communication and Information

CC2.3.7

Communicates Objectives Related to Privacy and Changes to Objectives — The entity communicates, to external users, vendors, business partners and others whose products and services are part of the sys...

CC2.3.8 Communication and Information

CC2.3.8

Communicates Information About System Operation and Boundaries—The entity prepares and communicates information about the design and operation of the system and its boundaries to authorized external u...

CC2.3.9 Communication and Information

CC2.3.9

Communicates System Objectives — The entity communicates its system objectives to appropriate external users.

CC5.1 Control Activities

COSO Principle 10

The entity selects and develops control activities that contribute to the mitigation of risks to the achievement of objectives to acceptable levels.

CC5.1.1 Control Activities

CC5.1.1

Integrates With Risk Assessment — Control activities help ensure that risk responses that address and mitigate risks are carried out.

CC5.1.2 Control Activities

CC5.1.2

Considers Entity-Specific Factors — Management considers how the environment, complexity, nature, and scope of its operations, as well as the specific characteristics of its organization, affect the s...

CC5.1.3 Control Activities

CC5.1.3

Determines Relevant Business Processes — Management determines which relevant business processes require control activities.

CC5.1.4 Control Activities

CC5.1.4

Evaluates a Mix of Control Activity Types — Control activities include a range and variety of controls and may include a balance of approaches to mitigate risks, considering both manual and automated...

CC5.1.5 Control Activities

CC5.1.5

Considers at What Level Activities Are Applied — Management considers control activities at various levels in the entity.

CC5.1.6 Control Activities

CC5.1.6

Addresses Segregation of Duties — Management segregates incompatible duties, and where such segregation is not practical, management selects and develops alternative control activities.

CC5.2 Control Activities

COSO Principle 11

The entity also selects and develops general control activities over technology to support the achievement of objectives.

CC5.2.1 Control Activities

CC5.2.1

Determines Dependency Between the Use of Technology in Business Processes and Technology General Controls — Management understands and determines the dependency and linkage between business processes,...

CC5.2.2 Control Activities

CC5.2.2

Establishes Relevant Technology Infrastructure Control Activities — Management selects and develops control activities over the technology infrastructure, which are designed and implemented to help en...

CC5.2.3 Control Activities

CC5.2.3

Establishes Relevant Security Management Process Controls Activities — Management selects and develops control activities that are designed and implemented to restrict technology access rights to auth...

CC5.2.4 Control Activities

CC5.2.4

Establishes Relevant Technology Acquisition, Development, and Maintenance Process Control Activities — Management selects and develops control activities over the acquisition, development, and mainten...

CC5.3 Control Activities

COSO Principle 12

The entity deploys control activities through policies that establish what is expected and in procedures that put policies into action.

CC5.3.1 Control Activities

CC5.3.1

Establishes Policies and Procedures to Support Deployment of Management ‘s Directives—Management establishes control activities that are built into business processes and employees’ day-to-day activit...

CC5.3.2 Control Activities

CC5.3.2

Establishes Responsibility and Accountability for Executing Policies and Procedures—Management establishes responsibility and accountability for control activities with management (or other designated...

CC5.3.3 Control Activities

CC5.3.3

Performs in a Timely Manner—Responsible personnel perform control activities in a timely manner as defined by the policies and procedures.

CC5.3.4 Control Activities

CC5.3.4

Takes Corrective Action—Responsible personnel investigate and act on matters identified as a result of executing control activities.

CC5.3.5 Control Activities

CC5.3.5

Performs Using Competent Personnel—Competent personnel with sufficient authority perform control activities with diligence and continuing focus.

CC5.3.6 Control Activities

CC5.3.6

Reassesses Policies and Procedures—Management periodically reviews control activities to determine their continued relevance and refreshes them when necessary.

CC1.1 Control Environment

COSO Principle 1

The entity demonstrates a commitment to integrity and ethical values.

CC1.1.1 Control Environment

CC1.1.1

Sets the Tone at the Top — The board of directors and management, at all levels, demonstrate through their directives, actions, and behavior the importance of integrity and ethical values to support t...

CC1.1.2 Control Environment

CC1.1.2

Establishes Standards of Conduct — The expectations of the board of directors and senior management concerning integrity and ethical values are defined in the entity’s standards of conduct and underst...

CC1.1.3 Control Environment

CC1.1.3

Evaluates Adherence to Standards of Conduct — Processes are in place to evaluate the performance of individuals and teams against the entity’s expected standards of conduct.

CC1.1.4 Control Environment

CC1.1.4

Addresses Deviations in a Timely Manner — Deviations from the entity’s expected standards of conduct are identified and remedied in a timely and consistent manner.

CC1.1.5 Control Environment

CC1.1.5

Considers Contractors and Vendor Employees in Demonstrating Its Commitment — Management and the board of directors consider the use of contractors and vendor employees in its processes for establishin...

CC1.2 Control Environment

COSO Principle 2

The board of directors demonstrates independence from management and exercises oversight of the development and performance of internal control.

CC1.2.1 Control Environment

CC1.2.1

Establishes Oversight Responsibilities — The board of directors identifies and accepts its oversight responsibilities in relation to established requirements and expectations.

CC1.2.2 Control Environment

CC1.2.2

Applies Relevant Expertise — The board of directors defines, maintains, and periodically evaluates the skills and expertise needed among its members to enable them to ask probing questions of senior m...

CC1.2.3 Control Environment

CC1.2.3

Operates Independently — The board of directors has sufficient members who are independent from management and objective in evaluations and decision making.

CC1.2.4 Control Environment

CC1.2.4

Supplements Board Expertise — The board of directors supplements its expertise relevant to security, availability, processing integrity, confidentiality, and privacy, as needed, through the use of a s...

CC1.3 Control Environment

COSO Principle 3

Management establishes, with board oversight, structures, reporting lines, and appropriate authorities and responsibilities in the pursuit of objectives.

CC1.3.1 Control Environment

CC1.3.1

Considers All Structures of the Entity — Management and the board of directors consider the multiple structures used (including operating units, legal entities, geographic distribution, and outsourced...

CC1.3.2 Control Environment

CC1.3.2

Establishes Reporting Lines — Management designs and evaluates lines of reporting for each entity structure to enable execution of authorities and responsibilities and flow of information to manage th...

CC1.3.3 Control Environment

CC1.3.3

Defines, Assigns, and Limits Authorities and Responsibilities — Management and the board of directors delegate authority, define responsibilities, and use appropriate processes and technology to assig...

CC1.3.4 Control Environment

CC1.3.4

Addresses Specific Requirements When Defining Authorities and Responsibilities — Management and the board of directors consider requirements relevant to security, availability, processing integrity, c...

CC1.3.5 Control Environment

CC1.3.5

Considers Interactions With External Parties When Establishing Structures, Reporting Lines, Authorities, and Responsibilities — Management and the board of directors consider the need for the entity t...

CC1.4 Control Environment

COSO Principle 4

The entity demonstrates a commitment to attract, develop, and retain competent individuals in alignment with objectives.

CC1.4.1 Control Environment

CC1.4.1

Establishes Policies and Practices — Policies and practices reflect expectations of competence necessary to support the achievement of objectives.

CC1.4.2 Control Environment

CC1.4.2

Evaluates Competence and Addresses Shortcomings — The board of directors and management evaluate competence across the entity and in outsourced service providers in relation to established policies an...

CC1.4.3 Control Environment

CC1.4.3

Attracts, Develops, and Retains Individuals — The entity provides the mentoring and training needed to attract, develop, and retain sufficient and competent personnel and outsourced service providers...

CC1.4.4 Control Environment

CC1.4.4

Plans and Prepares for Succession — Senior management and the board of directors develop contingency plans for assignments of responsibility important for internal control.

CC1.4.5 Control Environment

CC1.4.5

Considers the Background of Individuals — The entity considers the background of potential and existing personnel, contractors, and vendor employees when determining whether to employ and retain the i...

CC1.4.6 Control Environment

CC1.4.6

Considers the Technical Competency of Individuals — The entity considers the technical competency of potential and existing personnel, contractors, and vendor employees when determining whether to emp...

CC1.4.7 Control Environment

CC1.4.7

Provides Training to Maintain Technical Competencies — The entity provides training programs, including continuing education and training, to ensure skill sets and technical competency of existing per...

CC1.5 Control Environment

COSO Principle 5

The entity holds individuals accountable for their internal control responsibilities in the pursuit of objectives.

CC1.5.1 Control Environment

CC1.5.1

Enforces Accountability Through Structures, Authorities, and Responsibilities — Management and the board of directors establish the mechanisms to communicate and hold individuals accountable for perfo...

CC1.5.2 Control Environment

CC1.5.2

Establishes Performance Measures, Incentives, and Rewards — Management and the board of directors establish performance measures, incentives, and other rewards appropriate for responsibilities at all...

CC1.5.3 Control Environment

CC1.5.3

Evaluates Performance Measures, Incentives, and Rewards for Ongoing Relevance — Management and the board of directors align incentives and rewards with the fulfillment of internal control responsibili...

CC1.5.4 Control Environment

CC1.5.4

Considers Excessive Pressures — Management and the board of directors evaluate and adjust pressures associated with the achievement of objectives as they assign responsibilities, develop performance m...

CC1.5.5 Control Environment

CC1.5.5

Evaluates Performance and Rewards or Disciplines Individuals — Management and the board of directors evaluate performance of internal control responsibilities, including adherence to standards of cond...

CC6.1 Logical and Physical Access Controls

CC6.1

The entity implements logical access security software, infrastructure, and architectures over protected information assets to protect them from security events to meet the entity's objectives.

CC6.1.1 Logical and Physical Access Controls

CC6.1.1

Identifies and Manages the Inventory of Information Assets — The entity identifies, inventories, classifies, and manages information assets.

CC6.1.10 Logical and Physical Access Controls

CC6.1.10

Protects Encryption Keys — Processes are in place to protect encryption keys during generation, storage, use, and destruction.

CC6.1.2 Logical and Physical Access Controls

CC6.1.2

Restricts Logical Access — Logical access to information assets, including hardware, data (at-rest, during processing, or in transmission), software, administrative authorities, mobile devices, output...

CC6.1.3 Logical and Physical Access Controls

CC6.1.3

Identifies and Authenticates Users — Persons, infrastructure and software are identified and authenticated prior to accessing information assets, whether locally or remotely.

CC6.1.4 Logical and Physical Access Controls

CC6.1.4

Considers Network Segmentation — Network segmentation permits unrelated portions of the entity's information system to be isolated from each other.

CC6.1.5 Logical and Physical Access Controls

CC6.1.5

Manages Points of Access — Points of access by outside entities and the types of data that flow through the points of access are identified, inventoried, and managed. The types of individuals and syst...

CC6.1.6 Logical and Physical Access Controls

CC6.1.6

Restricts Access to Information Assets — Combinations of data classification, separate data structures, port restrictions, access protocol restrictions, user identification, and digital certificates a...

CC6.1.7 Logical and Physical Access Controls

CC6.1.7

Manages Identification and Authentication — Identification and authentication requirements are established, documented, and managed for individuals and systems accessing entity information, infrastruc...

CC6.1.8 Logical and Physical Access Controls

CC6.1.8

Manages Credentials for Infrastructure and Software — New internal and external infrastructure and software are registered, authorized, and documented prior to being granted access credentials and imp...

CC6.1.9 Logical and Physical Access Controls

CC6.1.9

Uses Encryption to Protect Data — The entity uses encryption to supplement other measures used to protect data-at-rest, when such protections are deemed appropriate based on assessed risk.

CC6.2 Logical and Physical Access Controls

CC6.2

Prior to issuing system credentials and granting system access, the entity registers and authorizes new internal and external users whose access is administered by the entity. For those users whose ac...

CC6.2.1 Logical and Physical Access Controls

CC6.2.1

Controls Access Credentials to Protected Assets — Information asset access credentials are created based on an authorization from the system's asset owner or authorized custodian.

CC6.2.2 Logical and Physical Access Controls

CC6.2.2

Removes Access to Protected Assets When Appropriate — Processes are in place to remove credential access when an individual no longer requires such access.

CC6.2.3 Logical and Physical Access Controls

CC6.2.3

Reviews Appropriateness of Access Credentials — The appropriateness of access credentials is reviewed on a periodic basis for unnecessary and inappropriate individuals with credentials.

CC6.3 Logical and Physical Access Controls

CC6.3

The entity authorizes, modifies, or removes access to data, software, functions, and other protected information assets based on roles, responsibilities, or the system design and changes, giving consi...

CC6.3.1 Logical and Physical Access Controls

CC6.3.1

Creates or Modifies Access to Protected Information Assets — Processes are in place to create or modify access to protected information assets based on authorization from the asset’s owner.

CC6.3.2 Logical and Physical Access Controls

CC6.3.2

Removes Access to Protected Information Assets — Processes are in place to remove access to protected information assets when an individual no longer requires access.

CC6.3.3 Logical and Physical Access Controls

CC6.3.3

Uses Role-Based Access Controls — Role-based access control is utilized to support segregation of incompatible functions.

CC6.4 Logical and Physical Access Controls

CC6.4

The entity restricts physical access to facilities and protected information assets (for example, data center facilities, back-up media storage, and other sensitive locations) to authorized personnel...

CC6.4.1 Logical and Physical Access Controls

CC6.4.1

Creates or Modifies Physical Access — Processes are in place to create or modify physical access to facilities such as data centers, office spaces, and work areas, based on authorization from the syst...

CC6.4.2 Logical and Physical Access Controls

CC6.4.2

Removes Physical Access — Processes are in place to remove access to physical resources when an individual no longer requires access.

CC6.4.3 Logical and Physical Access Controls

CC6.4.3

Reviews Physical Access — Processes are in place to periodically review physical access to ensure consistency with job responsibilities.

CC6.5 Logical and Physical Access Controls

CC6.5

The entity discontinues logical and physical protections over physical assets only after the ability to read or recover data and software from those assets has been diminished and is no longer require...

CC6.5.1 Logical and Physical Access Controls

CC6.5.1

Identifies Data and Software for Disposal — Procedures are in place to identify data and software stored on equipment to be disposed and to render such data and software unreadable.

CC6.5.2 Logical and Physical Access Controls

CC6.5.2

Removes Data and Software From Entity Control — Procedures are in place to remove data and software stored on equipment to be removed from the physical control of the entity and to render such data an...

CC6.6 Logical and Physical Access Controls

CC6.6

The entity implements logical access security measures to protect against threats from sources outside its system boundaries.

CC6.6.1 Logical and Physical Access Controls

CC6.6.1

Restricts Access — The types of activities that can occur through a communication channel (for example, FTP site, router port) are restricted.

CC6.6.2 Logical and Physical Access Controls

CC6.6.2

Protects Identification and Authentication Credentials — Identification and authentication credentials are protected during transmission outside its system boundaries.

CC6.6.3 Logical and Physical Access Controls

CC6.6.3

Requires Additional Authentication or Credentials — Additional authentication information or credentials are required when accessing the system from outside its boundaries.

CC6.6.4 Logical and Physical Access Controls

CC6.6.4

Implements Boundary Protection Systems — Boundary protection systems (for example, firewalls, demilitarized zones, and intrusion detection systems) are implemented to protect external access points fr...

CC6.7 Logical and Physical Access Controls

CC6.7

The entity restricts the transmission, movement, and removal of information to authorized internal and external users and processes, and protects it during transmission, movement, or removal to meet t...

CC6.7.1 Logical and Physical Access Controls

CC6.7.1

Restricts the Ability to Perform Transmission — Data loss prevention processes and technologies are used to restrict ability to authorize and execute transmission, movement and removal of information.

CC6.7.2 Logical and Physical Access Controls

CC6.7.2

Uses Encryption Technologies or Secure Communication Channels to Protect Data — Encryption technologies or secured communication channels are used to protect transmission of data and other communicati...

CC6.7.3 Logical and Physical Access Controls

CC6.7.3

Protects Removal Media — Encryption technologies and physical asset protections are used for removable media (such as USB drives and back-up tapes), as appropriate.

CC6.7.4 Logical and Physical Access Controls

CC6.7.4

Protects Mobile Devices — Processes are in place to protect mobile devices (such as laptops, smart phones and tablets) that serve as information assets.

CC6.8 Logical and Physical Access Controls

CC6.8

The entity implements controls to prevent or detect and act upon the introduction of unauthorized or malicious software to meet the entity’s objectives.

CC6.8.1 Logical and Physical Access Controls

CC6.8.1

Restricts Application and Software Installation — The ability to install applications and software is restricted to authorized individuals.

CC6.8.2 Logical and Physical Access Controls

CC6.8.2

Detects Unauthorized Changes to Software and Configuration Parameters — Processes are in place to detect changes to software and configuration parameters that may be indicative of unauthorized or mali...

CC6.8.3 Logical and Physical Access Controls

CC6.8.3

Uses a Defined Change Control Process — A management-defined change control process is used for the implementation of software.

CC6.8.4 Logical and Physical Access Controls

CC6.8.4

Uses Antivirus and Anti-Malware Software — Antivirus and anti-malware software is implemented and maintained to provide for the interception or detection and remediation of malware.

CC6.8.5 Logical and Physical Access Controls

CC6.8.5

Scans Information Assets from Outside the Entity for Malware and Other Unauthorized Software — Procedures are in place to scan information assets that have been transferred or returned to the entity’s...

CC4.1 Monitoring Activities

COSO Principle 16

The entity selects, develops, and performs ongoing and/or separate evaluations to ascertain whether the components of internal control are present and functioning.

CC4.1.1 Monitoring Activities

CC4.1.1

Considers a Mix of Ongoing and Separate Evaluations — Management includes a balance of ongoing and separate evaluations.

CC4.1.2 Monitoring Activities

CC4.1.2

Considers Rate of Change — Management considers the rate of change in business and business processes when selecting and developing ongoing and separate evaluations.

CC4.1.3 Monitoring Activities

CC4.1.3

Establishes Baseline Understanding — The design and current state of an internal control system are used to establish a baseline for ongoing and separate evaluations.

CC4.1.4 Monitoring Activities

CC4.1.4

Uses Knowledgeable Personnel — Evaluators performing ongoing and separate evaluations have sufficient knowledge to understand what is being evaluated.

CC4.1.5 Monitoring Activities

CC4.1.5

Integrates With Business Processes — Ongoing evaluations are built into the business processes and adjust to changing conditions.

CC4.1.6 Monitoring Activities

CC4.1.6

Adjusts Scope and Frequency — Management varies the scope and frequency of separate evaluations depending on risk.

CC4.1.7 Monitoring Activities

CC4.1.7

Objectively Evaluates — Separate evaluations are performed periodically to provide objective feedback.

CC4.1.8 Monitoring Activities

CC4.1.8

Considers Different Types of Ongoing and Separate Evaluations — Management uses a variety of different types of ongoing and separate evaluations, including penetration testing, independent certificati...

CC4.2 Monitoring Activities

COSO Principle 17

The entity evaluates and communicates internal control deficiencies in a timely manner to those parties responsible for taking corrective action, including senior management and the board of directors...

CC4.2.1 Monitoring Activities

CC4.2.1

Assesses Results — Management and the board of directors, as appropriate, assess results of ongoing and separate evaluations.

CC4.2.2 Monitoring Activities

CC4.2.2

Communicates Deficiencies — Deficiencies are communicated to parties responsible for taking corrective action and to senior management and the board of directors, as appropriate.

CC4.2.3 Monitoring Activities

CC4.2.3

Monitors Corrective Action — Management tracks whether deficiencies are remedied on a timely basis.

CC3.1 Risk Assessment

COSO Principle 6

The entity specifies objectives with sufficient clarity to enable the identification and assessment of risks relating to objectives.

CC3.1.1 Risk Assessment

CC3.1.1

Operations Objectives — Reflects Management's Choices — Operations objectives reflect management's choices about structure, industry considerations, and performance of the entity.

CC3.1.10 Risk Assessment

CC3.1.10

Reflects Entity Activities — External reporting reflects the underlying transactions and events within a range of acceptable limits.

CC3.1.11 Risk Assessment

CC3.1.11

Internal Reporting Objectives — Reflects Management's Choices — Internal reporting provides management with accurate and complete information regarding management's choices and information needed in m...

CC3.1.12 Risk Assessment

CC3.1.12

Considers the Required Level of Precision — Management reflects the required level of precision and accuracy suitable for user needs in nonfinancial reporting objectives and materiality within financi...

CC3.1.13 Risk Assessment

CC3.1.13

Reflects Entity Activities — Internal reporting reflects the underlying transactions and events within a range of acceptable limits.

CC3.1.14 Risk Assessment

CC3.1.14

Compliance Objectives — Reflects External Laws and Regulations — Laws and regulations establish minimum standards of conduct, which the entity integrates into compliance objectives.

CC3.1.15 Risk Assessment

CC3.1.15

Considers Tolerances for Risk — Management considers the acceptable levels of variation relative to the achievement of operations objectives.

CC3.1.16 Risk Assessment

CC3.1.16

Establishes Sub-objectives to Support Objectives — Management identifies sub-objectives related to security, availability, processing integrity, confidentiality, and privacy to support the achievement...

CC3.1.2 Risk Assessment

CC3.1.2

Considers Tolerances for Risk — Management considers the acceptable levels of variation relative to the achievement of operations objectives.

CC3.1.3 Risk Assessment

CC3.1.3

Includes Operations and Financial Performance Goals — The organization reflects the desired level of operations and financial performance for the entity within operations objectives.

CC3.1.4 Risk Assessment

CC3.1.4

Forms a Basis for Committing of Resources — Management uses operations objectives as a basis for allocating resources needed to attain desired operations and financial performance.

CC3.1.5 Risk Assessment

CC3.1.5

External Financial Reporting Objectives — Complies With Applicable Accounting Standards — Financial reporting objectives are consistent with accounting principles suitable and available for that entit...

CC3.1.6 Risk Assessment

CC3.1.6

Considers Materiality — Management considers materiality in financial statement presentation.

CC3.1.7 Risk Assessment

CC3.1.7

Reflects Entity Activities — External reporting reflects the underlying transactions and events to show qualitative characteristics and assertions.

CC3.1.8 Risk Assessment

CC3.1.8

External Nonfinancial Reporting Objectives — Complies With Externally Established Frameworks — Management establishes objectives consistent with laws and regulations or standards and frameworks of rec...

CC3.1.9 Risk Assessment

CC3.1.9

Considers the Required Level of Precision — Management reflects the required level of precision and accuracy suitable for user needs and based on criteria established by third parties in nonfinancial...

CC3.2 Risk Assessment

COSO Principle 7

The entity identifies risks to the achievement of its objectives across the entity and analyzes risks as a basis for determining how the risks should be managed.

CC3.2.1 Risk Assessment

CC3.2.1

Includes Entity, Subsidiary, Division, Operating Unit, and Functional Levels — The entity identifies and assesses risk at the entity, subsidiary, division, operating unit, and functional levels releva...

CC3.2.2 Risk Assessment

CC3.2.2

Analyzes Internal and External Factors — Risk identification considers both internal and external factors and their impact on the achievement of objectives.

CC3.2.3 Risk Assessment

CC3.2.3

Involves Appropriate Levels of Management — The entity puts into place effective risk assessment mechanisms that involve appropriate levels of management.

CC3.2.4 Risk Assessment

CC3.2.4

Estimates Significance of Risks Identified — Identified risks are analyzed through a process that includes estimating the potential significance of the risk.

CC3.2.5 Risk Assessment

CC3.2.5

Determines How to Respond to Risks — Risk assessment includes considering how the risk should be managed and whether to accept, avoid, reduce, or share the risk.

CC3.2.6 Risk Assessment

CC3.2.6

Identifies and Assesses Criticality of Information Assets and Identifies Threats and Vulnerabilities — The entity's risk identification and assessment process includes (1) identifying information asse...

CC3.2.7 Risk Assessment

CC3.2.7

Analyzes Threats and Vulnerabilities From Vendors, Business Partners, and Other Parties — The entity's risk assessment process includes the analysis of potential threats and vulnerabilities arising fr...

CC3.2.8 Risk Assessment

CC3.2.8

Considers the Significance of the Risk — The entity’s consideration of the potential significance of the identified risks includes (1) determining the criticality of identified assets in meeting objec...

CC3.3 Risk Assessment

COSO Principle 8

The entity considers the potential for fraud in assessing risks to the achievement of objectives.

CC3.3.1 Risk Assessment

CC3.3.1

Considers Various Types of Fraud — The assessment of fraud considers fraudulent reporting, possible loss of assets, and corruption resulting from the various ways that fraud and misconduct can occur.

CC3.3.2 Risk Assessment

CC3.3.2

Assesses Incentives and Pressures — The assessment of fraud risks considers incentives and pressures.

CC3.3.3 Risk Assessment

CC3.3.3

Assesses Opportunities — The assessment of fraud risk considers opportunities for unauthorized acquisition, use, or disposal of assets, altering the entity’s reporting records, or committing other ina...

CC3.3.4 Risk Assessment

CC3.3.4

Assesses Attitudes and Rationalizations — The assessment of fraud risk considers how management and other personnel might engage in or justify inappropriate actions.

CC3.3.5 Risk Assessment

CC3.3.5

Considers the Risks Related to the Use of IT and Access to Information — The assessment of fraud risks includes consideration of threats and vulnerabilities that arise specifically from the use of IT...

CC3.4 Risk Assessment

COSO Principle 9

The entity identifies and assesses changes that could significantly impact the system of internal control.

CC3.4.1 Risk Assessment

CC3.4.1

Assesses Changes in the External Environment—The risk identification process considers changes to the regulatory, economic, and physical environment in which the entity operates.

CC3.4.2 Risk Assessment

CC3.4.2

Assesses Changes in the Business Model—The entity considers the potential impacts of new business lines, dramatically altered compositions of existing business lines, acquired or divested business ope...

CC3.4.3 Risk Assessment

CC3.4.3

Assesses Changes in Leadership—The entity considers changes in management and respective attitudes and philosophies on the system of internal control.

CC3.4.4 Risk Assessment

CC3.4.4

Assess Changes in Systems and Technology—The risk identification process considers changes arising from changes in the entity’s systems and changes in the technology environment.

CC3.4.5 Risk Assessment

CC3.4.5

Assess Changes in Vendor and Business Partner Relationships—The risk identification process considers changes in vendor and business partner relationships.

CC9.1 Risk Mitigation

CC9.1

The entity identifies, selects, and develops risk mitigation activities for risks arising from potential business disruptions.

CC9.1.1 Risk Mitigation

CC9.1.1

Considers Mitigation of Risks of Business Disruption — Risk mitigation activities include the development of planned policies, procedures, communications, and alternative processing solutions to respo...

CC9.1.2 Risk Mitigation

CC9.1.2

Considers the Use of Insurance to Mitigate Financial Impact Risks — The risk management activities consider the use of insurance to offset the financial impact of loss events that would otherwise impa...

CC9.2 Risk Mitigation

CC9.2

The entity assesses and manages risks associated with vendors and business partners.

CC9.2.1 Risk Mitigation

CC9.2.1

Establishes Requirements for Vendor and Business Partner Engagements — The entity establishes specific requirements for a vendor and business partner engagement that includes (1) scope of services and...

CC9.2.10 Risk Mitigation

CC9.2.10

Assesses Compliance With Confidentiality Commitments of Vendors and Business Partners — On a periodic and as-needed basis, the entity assesses compliance by vendors and business partners with the enti...

CC9.2.11 Risk Mitigation

CC9.2.11

Obtains Privacy Commitments from Vendors and Business Partners — The entity obtains privacy commitments, consistent with the entity’s privacy commitments and requirements, from vendors and business pa...

CC9.2.12 Risk Mitigation

CC9.2.12

Assesses Compliance with Privacy Commitments of Vendors and Business Partners — On a periodic and as-needed basis, the entity assesses compliance by vendors and business partners with the entity’s pri...

CC9.2.2 Risk Mitigation

CC9.2.2

Assesses Vendor and Business Partner Risks — The entity assesses, on a periodic basis, the risks that vendors and business partners (and those entities’ vendors and business partners) represent to the...

CC9.2.3 Risk Mitigation

CC9.2.3

Assigns Responsibility and Accountability for Managing Vendors and Business Partners — The entity assigns responsibility and accountability for the management of risks associated with vendors and busi...

CC9.2.4 Risk Mitigation

CC9.2.4

Establishes Communication Protocols for Vendors and Business Partners — The entity establishes communication and resolution protocols for service or product issues related to vendors and business part...

CC9.2.5 Risk Mitigation

CC9.2.5

Establishes Exception Handling Procedures From Vendors and Business Partners — The entity establishes exception handling procedures for service or product issues related to vendors and business partne...

CC9.2.6 Risk Mitigation

CC9.2.6

Assesses Vendor and Business Partner Performance — The entity periodically assesses the performance of vendors and business partners.

CC9.2.7 Risk Mitigation

CC9.2.7

Implements Procedures for Addressing Issues Identified During Vendor and Business Partner Assessments — The entity implements procedures for addressing issues identified with vendor and business partn...

CC9.2.8 Risk Mitigation

CC9.2.8

Implements Procedures for Terminating Vendor and Business Partner Relationships — The entity implements procedures for terminating vendor and business partner relationships.

CC9.2.9 Risk Mitigation

CC9.2.9

Obtains Confidentiality Commitments from Vendors and Business Partners — The entity obtains confidentiality commitments that are consistent with the entity’s confidentiality commitments and requiremen...

CC7.1 System Operations

CC7.1

To meet its objectives, the entity uses detection and monitoring procedures to identify (1) changes to configurations that result in the introduction of new vulnerabilities, and (2) susceptibilities t...

CC7.1.1 System Operations

CC7.1.1

Uses Defined Configuration Standards — Management has defined configuration standards.

CC7.1.2 System Operations

CC7.1.2

Monitors Infrastructure and Software — The entity monitors infrastructure and software for noncompliance with the standards, which could threaten the achievement of the entity's objectives.

CC7.1.3 System Operations

CC7.1.3

Implements Change-Detection Mechanisms — The IT system includes a change-detection mechanism (for example, file integrity monitoring tools) to alert personnel to unauthorized modifications of critical...

CC7.1.4 System Operations

CC7.1.4

Detects Unknown or Unauthorized Components — Procedures are in place to detect the introduction of unknown or unauthorized components.

CC7.1.5 System Operations

CC7.1.5

Conducts Vulnerability Scans — The entity conducts vulnerability scans designed to identify potential vulnerabilities or misconfigurations on a periodic basis and after any significant change in the e...

CC7.2 System Operations

CC7.2

The entity monitors system components and the operation of those components for anomalies that are indicative of malicious acts, natural disasters, and errors affecting the entity's ability to meet it...

CC7.2.1 System Operations

CC7.2.1

Implements Detection Policies, Procedures, and Tools — Detection policies and procedures are defined and implemented, and detection tools are implemented on Infrastructure and software to identify ano...

CC7.2.2 System Operations

CC7.2.2

Designs Detection Measures — Detection measures are designed to identify anomalies that could result from actual or attempted (1) compromise of physical barriers; (2) unauthorized actions of authorize...

CC7.2.3 System Operations

CC7.2.3

Implements Filters to Analyze Anomalies — Management has implemented procedures to filter, summarize, and analyze anomalies to identify security events.

CC7.2.4 System Operations

CC7.2.4

Monitors Detection Tools for Effective Operation — Management has implemented processes to monitor the effectiveness of detection tools.

CC7.3 System Operations

CC7.3

The entity evaluates security events to determine whether they could or have resulted in a failure of the entity to meet its objectives (security incidents) and, if so, takes actions to prevent or add...

CC7.3.1 System Operations

CC7.3.1

Responds to Security Incidents — Procedures are in place for responding to security incidents and evaluating the effectiveness of those policies and procedures on a periodic basis.

CC7.3.2 System Operations

CC7.3.2

Communicates and Reviews Detected Security Events — Detected security events are communicated to and reviewed by the individuals responsible for the management of the security program and actions are...

CC7.3.3 System Operations

CC7.3.3

Develops and Implements Procedures to Analyze Security Incidents — Procedures are in place to analyze security incidents and determine system impact.

CC7.3.4 System Operations

CC7.3.4

Assesses the Impact on Personal Information — Detected security events are evaluated to determine whether they could or did result in the unauthorized disclosure or use of personal information and whe...

CC7.3.5 System Operations

CC7.3.5

Determines Personal Information Used or Disclosed — When an unauthorized use or disclosure of personal information has occurred, the affected information is identified.

CC7.4 System Operations

CC7.4

The entity responds to identified security incidents by executing a defined incident response program to understand, contain, remediate, and communicate security incidents, as appropriate.

CC7.4.1 System Operations

CC7.4.1

Assigns Roles and Responsibilities — Roles and responsibilities for the design, implementation, maintenance, and execution of the incident response program are assigned, including the use of external...

CC7.4.10 System Operations

CC7.4.10

Evaluates the Effectiveness of Incident Response — The design of incident response activities is evaluated for effectiveness on a periodic basis.

CC7.4.11 System Operations

CC7.4.11

Periodically Evaluates Incidents — Periodically, management reviews incidents related to security, availability, processing integrity, confidentiality, and privacy and identifies the need for system c...

CC7.4.12 System Operations

CC7.4.12

Communicates Unauthorized Use and Disclosure — Events that resulted in unauthorized use or disclosure of personal information are communicated to the data subjects, legal and regulatory authorities, a...

CC7.4.13 System Operations

CC7.4.13

Application of Sanctions — The conduct of individuals and organizations operating under the authority of the entity and involved in the unauthorized use or disclosure of personal information is evalua...

CC7.4.2 System Operations

CC7.4.2

Contains Security Incidents — Procedures are in place to contain security incidents that actively threaten entity objectives.

CC7.4.3 System Operations

CC7.4.3

Mitigates Ongoing Security Incidents — Procedures are in place to mitigate the effects of ongoing security incidents.

CC7.4.4 System Operations

CC7.4.4

Ends Threats Posed by Security Incidents — Procedures are in place to end the threats posed by security incidents through closure of the vulnerability, removal of unauthorized access, and other remedi...

CC7.4.5 System Operations

CC7.4.5

Restores Operations — Procedures are in place to restore data and business operations to an interim state that permits the achievement of entity objectives.

CC7.4.6 System Operations

CC7.4.6

Develops and Implements Communication Protocols for Security Incidents — Protocols for communicating security incidents and actions taken to affected parties are developed and implemented to meet the...

CC7.4.7 System Operations

CC7.4.7

Obtains Understanding of Nature of Incident and Determines Containment Strategy — An understanding of the nature (for example, the method by which the incident occurred and the affected system resourc...

CC7.4.8 System Operations

CC7.4.8

Remediates Identified Vulnerabilities — Identified vulnerabilities are remediated through the development and execution of remediation activities.

CC7.4.9 System Operations

CC7.4.9

Communicates Remediation Activities — Remediation activities are documented and communicated in accordance with the incident response program.

CC7.5 System Operations

CC7.5

The entity identifies, develops, and implements activities to recover from identified security incidents.

CC7.5.1 System Operations

CC7.5.1

Restores the Affected Environment — The activities restore the affected environment to functional operation by rebuilding systems, updating software, installing patches, and changing configurations, a...

CC7.5.2 System Operations

CC7.5.2

Communicates Information About the Event — Communications about the nature of the incident, recovery actions taken, and activities required for the prevention of future security events are made to man...

CC7.5.3 System Operations

CC7.5.3

Determines Root Cause of the Event — The root cause of the event is determined.

CC7.5.4 System Operations

CC7.5.4

Implements Changes to Prevent and Detect Recurrences — Additional architecture or changes to preventive and detective controls, or both, are implemented to prevent and detect recurrences on a timely b...

CC7.5.5 System Operations

CC7.5.5

Improves Response and Recovery Procedures — Lessons learned are analyzed, and the incident response plan and recovery procedures are improved.

CC7.5.6 System Operations

CC7.5.6

Implements Incident Recovery Plan Testing — Incident recovery plan testing is performed on a periodic basis. The testing includes (1) development of testing scenarios based on threat likelihood and ma...