Isc-V1 2024

ISC
1
Regulations, Standards, and
Frameworks
Module
1 National Institute of Standards and

Technology Frameworks 3
2 Privacy and Data Security Standards 15
3 Center for Internet Security Critical Security Controls:

Part 1 21
4 Center for Internet Security Critical Security Controls:

Part 2 33
5 COBIT 2019 Framework 43

NOTES
S1–2 © Becker Professional Education Corporation. All rights reserved.

1
MODULE
National Institute of
Standards and Technology
Frameworks ISC 1
Overview
The application of information technology (IT) in an organization is the systematic
implementation of hardware and software so that data can be transmitted, modified, accessed,
and stored both securely and efficiently. As the field of information science advances, the speed
at which IT devices can perform these tasks has rapidly increased, and organizations must
reevaluate their technology on a regular basis.
Organizations adopt technology to enhance or support business operations, protect digital
records and assets, and safeguard physical assets. This makes the selection and deployment of
management information systems critical to the success of any organization.
1 National Institute of Standards and Technology (NIST)

Cybersecurity Framework (CSF)
1.1 NIST Background

The National Institute of Standards and Technology (NIST) was established in 1901 to remove
barriers to industrial competitiveness and improve access to resources to promote U.S. research
capabilities. In 1995, the NIST branched out into the cybersecurity field with the NIST Special
Publication 800-12, An Introduction to Information Security. To date, three of the most prolific sets
of standardized frameworks promulgated by NIST include the NIST Cybersecurity Framework
(CSF), NIST Privacy Framework, and NIST SP 800-53 Security and Privacy Controls for Information
Systems and Organizations.
1.2 Cybersecurity Framework

Introduction
The NIST Cybersecurity Framework is a voluntary framework that includes three primary
components to manage cybersecurity risk:
1. Framework Core
2. Framework Implementation Tiers
3. Framework Profile
© Becker Professional Education Corporation. All rights reserved. Module 1 National

S1–3Institute of Standards
1 National Institute of Standards and Technology Frameworks ISC 1
Tier 1 Tier 2 Tier 3 Tier 4

(Partial) (Risk Informed) (Repeatable) (Adaptive)
CORE TIERS
PROFILE
Source: Reprinted courtesy of the National Institute

of Standards and Technology, U.S. Department of
Commerce. Not copyrightable in the United States.
1.2.1 Framework Core

The NIST CSF was a legislative imperative for NIST aimed at developing a set of plain language
controls for the protection of critical IT infrastructure. Specifically, the focus of the NIST CSF is
to develop a program to identify, assess, and manage cybersecurity risks in a cost-effective and
repeatable manner.
The framework core consists of five areas of focus, or functions, which represent different points
in the security risk management life cycle that help enhance cybersecurity protection. These
components are not ordered steps; they are functions that should be performed concurrently.
The five components are Identify, Protect, Detect, Respond, and Recover.
1. Identify: This function focuses on creating canonical records of the assets an organization
uses to support information processing operations, users who are both internal and
external to an organization, and systems.
2. Protect: This function focuses on safeguards and access controls to networks, applications,
and other devices deployed as well as regular updates to security software, including
encryption for sensitive information, data backups, plans for disposing of files or unused
devices, and training for those with access to a company's network.
3. Detect: This function identifies the tools and resources needed to detect active
cybersecurity attacks, which includes monitoring network access points, user devices,
unauthorized personnel access, and high-risk employee behavior or the use of high-risk
devices.
4. Respond: This function outlines how a company should contain a cybersecurity event, react
using planned responses that mitigate losses, and notify all affected parties.
5. Recover: This function focuses on supporting the restoration of a company's network to
normal operations through repairing equipment, restoring backed up files or environments,
and positioning employees to rebound with the right response.
S1–4 Module 1 National

© Becker InstituteEducation
Professional of Standards and Technology
Corporation. Frameworks
All rights reserved.
ISC 1 1 National Institute of Standards and Technology Frameworks
These five functions define the high-level framework and are subdivided into 23 categories, and
then 108 subcategories.
Categories: Tie outcomes to specific activities and company needs.
Subcategories: Divide categories into management and technical activities that help achieve the
category outcomes.
Function ID Function Category ID

Asset Management ID.AM
Business Environment ID.BE
Governance ID.GV
ID Identify
Risk Assessment ID.RA
Risk Management Strategy ID.RM
Supply Chain Risk Management ID.SC
Identify Management and Access Control PR.AC
Awareness and Training PR.AT
Data Security PR.DS
PR Protect
Information Protection Processes & Procedures PR.IP
Maintenance PR.MA
Protective Technology PR.PT
Anomalies and Events DE.AE
DE Detect Security Continuous Monitoring DE.CM
Detection Processes DE.DP
Response Planning RS.RP
Communications RS.CO
RS Response Analysis RS.AN
Mitigation RS.MI
Improvements RS.IM
Recovery Planning RC.RP
RC Recover Improvements RC.IM
Communications RC.CO
Subcategory Informative Resources

ID.BE-1: The organization's COBIT 5 APO08.01, APO08.04, APO08.05,
role in the supply APO10.03, APO10.04, APO10.05
chain is identified and ISO/IEC 27001:2013 A.15.1.1, A.15.1.2,
communicated A.15.1.3, A.15.2.1, A.15.2.2
NIS SP 800-53 Rev.4 CP-2, SA-12
Source: Reprinted courtesy of the National Institute of Standards and Technology, U.S. Department of Commerce. Not
copyrightable in the United States.

Cybersecurity Framework Core: Detect, Respond,

Illustration 1
and Recover
Falcon CPAs and Associates is a large accounting and IT auditing firm that has several
clients for whom it provides bookkeeping, tax work, and IT audit services. Falcon decided
to run a scan using its new NIST-based security software for a client. The application scans
various applications and devices, generating a report with findings.
The report came back with high-risk employee behavior and the use of high-risk devices
as potential red flags. The employee behavior included access to records on the weekends
and after business hours. The use of high-risk devices included excessive use of USB
drives that were being plugged into the network to transfer data. Both were related to an
individual who was later determined to be stealing employee banking information from the
payroll department outside of normal working business hours.
Falcon's utilization of the application helped to detect high-risk areas and behaviors,
including those determined to be from an individual committing theft of banking
information. Falcon's response may include the analysis of impact, communication to those
employees impacted by the stolen information, and mitigation strategies to reduce the risk
of similar breaches. Falcon's recovery may include restoring any stolen data, improving
protections to restrict unauthorized access, and taking necessary disciplinary or legal action
against the individual committing the data theft.
Illustration 2 Detective Measures as Concurrent Protections
A locked door on an empty house is a preventive measure: if the criminal knows no one is
home, the criminal is free to break the lock and steal from the house. If the same locked
door has a webcam pointed at it to identify the thief and simultaneously alert the police,
the presence of the camera may deter the thief from breaking into the house. The camera
is not a preventive measure; it does nothing to stop a break-in, but because the thief can
see the detective measure put in place, the camera may deter the crime.
This concept applies to the NIST Framework Core. Detection processes may be included
as part of the protection process as a way to protect information and data. Similar to the
webcam in the empty house, if detection tools are in place to identify individuals who
access information or data, such detection tools may serve as a deterrent and protect
sensitive information.

1.2.2 Implementation Tiers

The NIST CSF provides a measure of an organization's information security infrastructure
sophistication in the form of four Implementation Tiers. These tiers do not serve to implement
the five functions. Rather, the tiers act as a benchmark, identifying the degree to which
information security practices are integrated throughout an organization. An organization must
select a tier based on the perception of its own risk given the cybersecurity policies currently in
place.
Tier 1 Tier 2 Tier 3 Tier 4

(Partial) (Risk-Informed) (Repeatable) (Adaptive)
Risk Management Process
Integrated Risk Management Program
External Participation
Source: Reprinted courtesy of the National Institute of Standards and Technology, U.S.
Department of Commerce. Not copyrightable in the United States.
The CSF Framework Profiles determine success or failure of information security

implementation, whereas the Implementation Tiers inform an organization as to the
effectiveness of those profiles. Tiers are divided by level and then subdivided into risk
management process, risk management program integration, and external participation.

Implementation Tiers
Risk Management Risk Management External Participation
Process Program Integration
Tier 1 Risk management is Incident management Corporate cybersecurity
(Partial) ad hoc and reactive is ad hoc and not is isolated, and the
where prioritization integrated into organization does not
of information organizational evaluate external risks.
security efforts is not processes.
strategic or directed by
organizational priority.
Tier 2 Cybersecurity The rest of the There is awareness of
(Risk- prioritization is based on organization is aware how environmental
Informed) organizational risk, and of cybersecurity, but security risks impact
management approves not managing securely. the organization, but
cybersecurity efforts; There is awareness, but inconsistent actions
however, cybersecurity no integration. are taken to respond to
may be isolated those risks.
from organizational
processes.
Tier 3 The organization utilizes There is an The organization
(Repeatable) cybersecurity in planning organizational collaborates with, and
and has enshrined risk approach to contributes to, the
cybersecurity practices cybersecurity where security community
in formal, documented cybersecurity is at large. It also has
policies. integrated into governance structures
planning and regularly internally to manage
communicated among cyber risk (governance
senior leadership. counsels, written
agreements, etc.).
Tier 4 Organizational Managing cybersecurity The organization
(Adaptive) cybersecurity is based on is an organization-wide robustly participates in
iterative improvement affair where cyber risk external information-
based on internal and is prioritized similarly sharing activities and
external cyber incidents to other forms of frequently contributes
and is responsive to organizational risk. to the cybersecurity
evolving threats. community at large.
1.2.3 Framework Profiles

Framework Profiles are the mechanisms by which NIST recommends companies measure
cybersecurity risk and establish a roadmap to ensure the organization can minimize such risk.
These Framework Profiles can be thought of as implementation guides with insight specific
to a particular industry. Profiles should factor organizational goals, industry goals, legal and
regulatory requirements, industry best practices, and risk management priorities.
NIST recommends organizing the Framework Profiles into a Current Profile, a Target Profile, and
a gap analysis.
A Current Profile is the current state of organizational risk management.
A Target Profile is the desired future state of organizational risk management.
A gap analysis identifies differences between the current and desired state, serving as a
means by which an organization can drive change.

An example would be a Profile of a particular industry that gives an overview of the entire sector,
business objectives, goals for reducing cybersecurity threats, and a roadmap for how to reach
those goals.
2 National Institute of Standards and Technology (NIST)

Privacy Framework
2.1 Privacy Framework

The NIST Privacy Framework is a relatively new offering from NIST, published in early 2020, to
protect individuals' data as used in data processing applications. The Privacy Framework was
developed to be industry-agnostic and to account for cultural and individual constructs around
privacy.
Leveraging a similar structure to NIST CSF, the Privacy Framework expresses control objectives in
the form of a Framework Core, with sophistication measures in Framework Profiles, and finally
mechanisms to drive organizational change and success through Framework Implementation
Tiers.
In addition to the similar structure, there is a degree of overlap between the CSF and Privacy
Frameworks. The following graphic shows concepts present in both, meaning they have
similar risk management approaches, but they are applied to each subject matter differently.
Additionally, the Privacy Framework can apply elements in practice that are only found in the
Cybersecurity framework. For instance, the guidance in NIST Privacy Framework version 1.0
suggests that the Cybersecurity Framework risks—Detect, Respond, and Recover—can be
applied to the Privacy Framework risks to further support the management of cybersecurity-
related privacy events.
Cybersecurity Privacy
Framework Framework
IDENTIFY-P/C
GOVERN-P
CONTROL-P
COMMUNICATE-P
PROTECT-P/C
DETECT-C
RESPOND-C
RECOVER-C

Framework Core
The Privacy Framework Core is contained in Appendix A of the Privacy Framework and is divided
into the following eight Framework Functions:
Function Category
Unique Function Unique Category
Identifier Identifier
ID.IM-P Inventory and Mapping
ID.BE-P Business Environment
ID-P Identify-P
ID.RA-P Risk Assessment
ID.DE-P Data Processing Ecosystem Risk Management
GV.PO-P Governance Policies, Processes, and Procedures
GV.RM-P Risk Management Strategy
GV-P Govern-P
GV.AT-P Awareness and Training
GV.MT-P Monitoring Review
CT.PO-P Data Processing Policies, Processes, and
Procedures
CT-P Control-P
CT.DM-P Data Processing Management
CT.DP-P Disassociated Processing
CM.PO-P Communication Policies, Processes, and
CM-P Communicate-P Procedures
CM.AW-P Data Processing Awareness
PR.PO-P Data Protection Policies, Processes, and
Procedures
PR.AC-P Identity Management, Authentication, and Access
PR-P Protect-P Control
PR.DS-P Data Security
PR.MA-P Maintenance
PR.PT-P Protective Technology
DE.AE Anomalies and Events
DE Detect DE.CM Security Continuous Monitoring
DE.DP Detection Processes
RS.RP Response Planning
RS.CO Communications
RS Respond RS.AN Analysis
RS.MI Mitigation
RS.IM Improvements
RC.RP Recovery Planning
RC Recover RC.IM Improvements
RC.CO Communications
Source: Reprinted courtesy of the National Institute of Standards and Technology, U.S. Department of Commerce. Not
copyrightable in the United States.

These Functions help organizations answer the following questions:

Identify-P: What are the company's privacy risks related to data processing activities?
Govern-P: What is the best governance structure for privacy risks related to the company's
data processing activities?
Control-P: What is the best management structure for privacy risks related to data
processing activities?
Communicate-P: How should the organization drive dialogue around privacy risks related
to data processing activities?
Protect-P: What are the safeguards that should be in place around privacy risks related to
data processing activities?
Detect: How should the organization detect data privacy risks and events?
Respond: How should the organization respond to data privacy events?
Recover: How should the company continue business after data privacy events?
The Functions are subdivided into 29 categories to address privacy program considerations.
Those categories, in turn, are divided into 100 subcategories. As with the NIST CSF, the
subcategories in the NIST Privacy Framework are individual controls resulting in successfully
addressing the 29 controls and the eight Framework Functions.
Framework Profiles
NIST Privacy Framework Profiles operate identically to NIST CSF Framework Profiles. NIST
identified a successful model in the NIST CSF and replicated that same platform for other
control sets.
The NIST Privacy Framework recommends creating a Current and Target Profile and using
those to gauge maturity and sophistication while developing a gap analysis and roadmap for
improvement. As with the NIST CSF, the Privacy Framework Current Profile refers to current
state privacy practices, while Target Profile refers to future privacy practices.
Framework Implementation Tiers
The Privacy Framework Tiers mirror those found in NIST CSF. There are four Tiers: Partial,
Risk- Informed, Repeatable, and Adaptive. Also, similar to the NIST CSF is the utility of those
Tiers, which is gauging performance and communicating internally about how to allocate
resources based on current and target Tiers.
As with the CSF, the subdivisions in the Privacy Framework are divided into four Tiers.
For the risk management process, risk management program integration, and ecosystem
relationships, the implementation statements are materially identical and reframed for
privacy.
One key difference is the addition of workforce as a Tier subdivision. As part of the
measurement of Tier maturity, NIST added the measurement of workforce dedicated to
an organization's privacy function. At the Partial end of the spectrum, no one is assigned
to privacy, and training is ad hoc. At the Adaptive end of the spectrum, there are dedicated
privacy personnel throughout the organization and regular broad-based training.
Another difference between the NIST CSF and Privacy Framework Tiers is the expression
of progression through the Tiers. In the Privacy Framework, progression is recommended
based on accomplishing goals in prior Tiers. In the Privacy Framework, Tiers are used more
as a gauge of privacy maturity.

3 NIST Security and Privacy Controls
3.1 NIST SP 800-53

NIST SP 800-53 Security and Privacy Controls for Information Systems and Organizations has
evolved into a set of security and privacy controls applicable to all information systems and has
become the standard for federal information security systems.
NIST SP 800-53 is a stricter standard compared to the NIST CSF or Privacy Frameworks.
While the CSF and Privacy Frameworks are designed for cost-effectiveness and best-practice
implementation, the controls in NIST SP 800-53 are designed for protecting information systems
against sophisticated threats. Even though there is a cost-based approach to NIST SP 800-53
implementation, organizations must carefully evaluate adopting the framework because it can
become burdensome given that there are nearly 1,200 detailed controls.
Purpose and Applicability
NIST SP 800-53 establishes controls for systems and organizations that can be implemented
within organizations or systems that process, store, or transmit information. These
standards are designed to help organizations identify the security and privacy controls
needed to manage risk and satisfy the following security and privacy requirements:
y Office of Management and Budget (OMB) Circular A-130: Requires the controls for
federal information systems.
y The Federal Information Security Modernization Act (FISMA): Requires the
implementation of minimum controls to protect federal information and information
systems.
Target Audience
The following audience is intended for the NIST SP 800-53:
y Individuals with system, information security, privacy, or risk management and
oversight responsibilities, including authorizing officials, chief information officers,
senior agency information security officers, and senior agency officials for privacy
y Individuals with system development responsibilities, including mission owners,
program managers, system engineers, system security engineers, privacy engineers,
hardware and software developers, system integrators, and acquisition or procurement
officials
y Individuals with logistical or disposition-related responsibilities, including program
managers, procurement officials, system integrators, and property managers
y Individuals with security and privacy implementation and operations responsibilities,
including mission or business owners, system owners, information owners or stewards,
system administrators, continuity planners, and system security or privacy officers
y Individuals with security and privacy assessment and monitoring responsibilities,
including auditors, inspectors general, system evaluators, control assessors,
independent verifiers and validators, and analysts
y Commercial entities, including industry partners, producing component products and
systems, creating security and privacy technologies, or providing services or capabilities
that support information security or privacy

Organizational Responsibilities
When managing security and privacy risks, the following are required by the organization:
y Well-defined security and privacy requirements for systems and organizations
y The use of trustworthy information system components based on state-of-the-practice
hardware, firmware, and software development and acquisition processes
y Rigorous security and privacy planning and system development life cycle management
y The application of system security and privacy engineering principles and practices to
securely develop and integrate system components into information systems
y The employment of security and privacy practices that are properly documented
and integrated into, and supportive of, the institutional and operational processes of
organizations
y Continuous monitoring of information systems and organizations to determine the
ongoing effectiveness of controls, changes in information systems and environments of
operation, and the state of security and privacy organization-wide
NIST SP 800-53 is subdivided into 20 different control families that cover organizational risk.
Those families are listed below with the organizational questions they seek to answer.
AC–Access Control: How does the organization manage application and resource access?
AT–Awareness and Training: How should the company deliver training on information
security risk?
AU–Audit and Accountability: How does the company evaluate information security
controls?
CA–Assessment, Authorization, and Monitoring: How does the organization collect
information security telemetry and use it to hunt for threats?
CM–Configuration Management: How are assets and software configured securely?
CP–Contingency Planning: How is the company prepared for downtime and outages?
IA–Identity and Authentication: How is identification and authentication managed?
IR–Incident Response: How is the organization prepared for information security and
events?
MA–Maintenance: How does the company ensure secure maintenance of infrastructure?
MP–Media Protection: How is information on physical media managed?
PE–Physical and Environmental Protection: How are facilities secured from intrusion or
harm?
PL–Planning: How does the organization manage information security planning?
PM–Program Management: How does the organization securely manage its information
security program?
PS–Personnel Security: How are employees evaluated for potential compromise?
PT–PII Processing and Transparency: How is personally identifiable information (PII)
managed (this family is new to NIST 800-53 Rev. 5)?
RA–Risk Assessment: How is environmental risk evaluated?
SA–System and Services Acquisition: How are systems securely evaluated and acquired?
SC– System and Communications Protection: How is data securely transmitted digitally?

SI–System and Information Integrity: How is the integrity of data in company systems
maintained and evaluated?
SR–Supply Chain Risk Management: How does the company secure its supply chain (new
to NIST 800-53 Rev. 5)?
The control families are subdivided into controls and control enhancements. Controls are the
objectives to be implemented for family conformance. Control enhancements are best practices,
some of which are recommended, while others are necessary for conformance to a baseline.
Controls and control objectives are written as statements for implementation. Some of
those statements for implementation include bracketed and italicized language, which is an
organization-defined parameter. Organizations are required to enter values or compliance
statements in lieu of the placeholder.
One key difference between NIST SP 800-53 Rev. 4 and NIST SP 800-53 Rev. 5 is that the latest
revision dropped priority and baseline allocation. In prior iterations, NIST categorized the NIST
SP 800-53 standards into low, moderate, and high control baselines. Those baselines informed
the sensitivity of federal systems to which the controls applied. As those are inapplicable and
potentially confusing in the private sector, the control baselines were dropped in favor of
comprehensive conformance.
With respect to implementation models, NIST SP 800-53 outlines three control implementation
approaches that are to be implemented on a per-control basis:
1. Common (Inheritable): Implement controls at the organizational level, which are adopted
by information systems.
2. System-Specific: Implement controls at the information system level.
3. Hybrid: Implement controls at the organization level where appropriate and the remainder
at the information system level.

2
MODULE
Privacy and Data

Security Standards ISC 1
1 Data Privacy
1.1 Privacy Laws

Privacy laws exist to protect an individual's private life and keep personal details out of the
public domain. These laws also create trust between consumers and enterprises so that when
a consumer's personal information is shared, such as with a credit card company or a health
care provider, sensitive information will be safeguarded according to rules outlined in applicable
privacy regulations.
Privacy laws regulate how those entrusted with private information must collect, process,
maintain, and disclose it. Generally, those entrusted with the information must be clear about
what data they collect, keep it confidential, and limit access to only those who need it.
Today's modern privacy laws in the United States focus on particular types of data or entities,
such as health care data, financial data, or data held by federal agencies. There is no single
federal law that applies generally and regulates all personal data. Unlike the United States, the
European Union enacted one comprehensive data privacy law, the General Data Protection
Regulation (GDPR), that applies generally and governs how all entrusted with personal data
should handle such information. A few U.S. states, such as California, have enacted similar
privacy laws of general applicability that apply to those doing business in the state or the data of
the people in the state.
1.2 Data Breaches

With society's use of the internet and the cloud, data exchange is more prevalent than ever.
The rise in available data has led to a surge in data breaches. A data breach is the exposure of
confidential information to unauthorized persons. There are two categories of data breaches:
Unintentional: A breach resulting from negligence or error.
Intentional: A breach resulting from bad actors illegally gaining access to data.
Data breaches can create significant consequences for companies and consumers. For
companies, a data breach can cause business disruption, reputational harm, financial loss, data
loss, and potential legal and regulatory implications. The IBM Cost of Data Breach Report for
2022 shows that the average cost of a data breach is over $4 million. This cost includes four
categories of expenditures:
Detection and Escalation: The cost to detect a breach, such as forensics and investigative
efforts.
Notification: The cost to notify necessary parties, such as consumers and regulators.
Post-breach Response: The cost to rectify the effects of the breach, such as paying
regulatory fines, implementing credit-monitoring services for consumers, and providing
ongoing communications to consumers.
© Becker Professional Education Corporation. All rights reserved. Module 2 S1–15 Privacy
2 Privacy and Data Security Standards ISC 1
Loss of Business and Revenue: Revenue is temporarily lost during downtime caused by
data breaches, and this can ultimately lead to loss of customers, which creates a more
permanent loss of revenue.
For consumers, the impact is different and more personal. A data breach can mean exposure
of personal information, such as name, home address, Social Security number, and payment or
banking information. This exposure puts consumers at risk of identity theft and monetary theft.
2 Modern Privacy Regulations
2.1 Health Insurance Portability and Accountability Act (HIPAA)

The Health Insurance Portability and Accountability Act (HIPAA) of 1996 required the Department
of Health and Human Services to adopt national standards promoting health care privacy and
security. In response, the department adopted the Privacy Rule and the Security Rule. HIPAA
and the rules that resulted regulate how the health care industry maintains and discloses health
information.
The HIPAA Privacy Rule governs the privacy of protected health information (PHI). This rule
applies to specific health care-related entities and businesses, called covered entities, which
include any of the following:
Health care providers that transmit health information electronically
Health plans
Health care clearing houses
Business associates who are service providers who need access to PHI to perform services
for covered entities
The Privacy Rule permits a covered entity to use and disclose PHI, with no further authorization
required:
To the individual.
For treatment, payment, and health care operations.
Incident to an otherwise permitted use and disclosure.
With valid authorization.
After giving the individual the opportunity to agree or object.
As a limited (redacted) dataset for research, public health, or health care operations.
For public interest and benefit activities provided by the law.
The HIPAA Security Rule specifically governs electronic PHI. Under the Security Rule, all covered
entities must:
Ensure the confidentiality, integrity, and availability of all electronic PHI;
Protect against reasonably anticipated threats to the security of the information;
Protect against reasonably anticipated impermissible uses or disclosures; and
Ensure compliance by the covered entity's workforce.
S1–16 Module 2 Privacy

© Becker Professional Education and Data
Corporation. Security
All rights Standards
reserved.
ISC 1 2 Privacy and Data Security Standards
HIPAA requires different safeguards for covered entities or business associates, including the
following:
Administrative Safeguards: Standards include security management processes, assigned
security responsibility, workforce security, information access management, security
awareness and training, security incident procedures, contingency plans, and evaluation.
Physical Safeguards: Standards include facility access controls, workstation use,
workstation security, and device and media controls.
Technical Safeguards: Standards include access control, audit controls, data integrity
controls, person or entity authentication, and transmission security.
2.1.1 Health Information Technology for Economic and Clinical Health (HITECH) Act
of 2009
HIPAA was amended by the Health Information Technology for Economic and Clinical Health
(HITECH) Act. HITECH was enacted in 2009 to promote health information technology and the
transition from paper to electronic records. HITECH amended HIPAA in a few ways. Namely,
it increased penalties for HIPAA violations, required that patients receive the option to obtain
records in electronic form, and added "business associates" as a covered entity. The U.S.
Department of Health and Human Services defines covered entities as individuals, organizations,
and agencies who must comply with the Rules' requirements to protect the privacy and security
of health information and must provide individuals with certain rights with respect to their
health information.
The most significant change resulting from HITECH, however, is the addition of breach
notification rules. HITECH requires that covered entities provide notice of a breach to impacted
individuals within 60 days after discovery of the breach.
2.2 General Data Protection Regulation (GDPR)

Effective May 2018, GDPR became the European Union's general applicability law regulating the
privacy of data. GDPR provides circumstances when it is lawful to process personal data, such
as with proper consent or when complying with a legal obligation. This law is one of the strictest
privacy laws in the world, as it imposes steep penalties for violators, with fines reaching millions
of dollars. Although enacted by the EU, the law's scope extends beyond the EU. GDPR applies to
any of the following:
Data processors based in the EU, even if the actual processing takes place outside of the EU
Data processors not based in the EU if the processor is offering goods or services to those in
the EU or is monitoring the behavior of those in the EU
Data processors not based in the EU but where EU law applies via public international law
(e.g., EU embassies)
GDPR provides six principles that must be followed when processing data:
Lawfulness, Fairness, Transparency: Data must be processed lawfully, fairly, and in a
transparent manner.
Purpose Limitation: Data must be processed for specified, explicit, and legitimate
purposes. Further processing beyond the purpose is permitted for public interest archiving,
scientific or historical research, or statistical purposes.
Data Minimization: Data processing must be adequate, relevant, and limited to what is
necessary for the purpose.
Accuracy: Data must be accurate and kept updated.
Storage Limitation: Data must be stored only for as long as is necessary. Storing it for
longer periods is permitted for public interest archiving, scientific or historical research, or
statistical purposes.
Integrity and Confidentiality: Data must be processed securely and protected against
unauthorized or unlawful processing, accidental loss, destruction, or damage.
2.2.1 Privacy Shield

To support transatlantic commerce, the European Union (EU) and the United States
implemented the Safe Harbor Framework, allowing companies to transfer data between the EU
and the United States legally. Ultimately, the EU's court declared the Framework invalid in 2015.
As a result, the EU and the United States negotiated the Privacy Shield in 2016 to replace the
invalidated Safe Harbor Framework agreement. Then, in July 2020, the EU court declared the
Privacy Shield invalid as well.
Until the EU and the United States reach a new agreement, companies that transfer data across
the Atlantic live in uncertainty. The U.S. Federal Trade Commission, responsible for enforcing
the Privacy Shield in the United States, expects U.S. companies to continue complying with their
obligations under the Privacy Shield until further notice.
3 Data Security Standards
3.1 Payment Card Industry Data Security Standard (PCI DSS)

With the rise of cashless transactions, financial institutions in the payment card industry created
the PCI (Payment Card Industry) Security Standards Council to enhance payment security.
The council created the PCI Data Security Standard (DSS), a framework for entities to apply to
promote data security when processing payments. The PCI DSS provides the following six goals
and 12 requirements:
Goals PCI DSS Requirements

Build and Maintain a Secure 1. Install and maintain a firewall configuration to protect
Network and Systems cardholder data.
2. Do not use vendor-supplied defaults for system passwords
and other security parameters.
Protect Cardholder Data 3. Protect stored cardholder data.
4. Encrypt transmission of cardholder data across open, public
networks.
Maintain a Vulnerability 5. Protect all systems against malware and regularly update
Management Program anti-virus software or programs.
6. Develop and maintain secure systems and applications.
Implement Strong Access 7. Restrict access to cardholder data through use of need-to-
Control Measures know restrictions.
8. Identify and authenticate access to system components.
9. Restrict physical access to cardholder data.
Regularly Monitor and Test 10. Track and monitor all access to network resources and
Networks cardholder data.
11. Regularly test security systems and processes.
Maintain an Information 12. Maintain a policy that addresses information security for all
Security Policy personnel.

reserved.
ISC 1 2 Privacy and Data Security Standards
The following diagram outlines a typical card payment processing network in which these 12
requirements must be applied, which affects retailers, banks, and the card payment processors
themselves. The process starts when a customer makes a purchase at a business using either
a physical or virtual debit or credit card that is processed on a third-party payment processor's
network (also referred to as a card network). The transaction is sent to the business' bank
(acquiring bank) using an electronic gateway supplied by the card network. The acquiring
bank then submits a payment request to the card network, which routes payment from the
customer's bank (issuing bank) to the acquiring bank. Note that the sequence of these steps
may vary depending on the card network and payment processor, with variation in the method
of authorization, transmission of data and its encryption, tokenization to mask sensitive data,
transaction settlement, and compliance practices.
MERCHANT BANK
(ACQUIRING BANK)
Acquiring bank
submits payment
request to 3rd party
(card) network
CUSTOMER CARD NETWORK

RETAILER/MERCHANT MERCHANT ELECTRONIC 3rd party processes
Customer CUSTOMER'S BANK
GATEWAY/ACCOUNT payments, routing
makes a (ISSUING BANK)
purchase Retailer submits from issuing bank
transaction through to acquirer
gateway
Adhering to each of the twelve PCI DSS requirements in the above payment processing network
involves the following:
1. Monitoring transaction traffic as it is transmitting between all entities, beginning with the
retailer and ending with the acquiring bank.
2. Enforcing strict password and security settings so that default credentials are changed after
gateway installation, and ensuring complex passwords are used.
3. Using encryption for transaction data at rest, adopting access controls to permit only
authorized use on the gateway platform, and implementing proper backup measures.
4. Encrypting data in transit when transactions are submitted to the card network across the
internet and other public networks.
5. Implementing antivirus software to protect against malware for web-based interfaces that
capture cardholder data and any other setting in which malware can be installed.
6. Using intrusion detection and prevention systems to protect against unauthorized system
access and data breaches at the retailer, issuing bank, card network, and acquiring bank.
7. Applying strict requirements to grant access to cardholder data, periodically revoking access
when applicable.
8. Requiring multiple authentication methods at every access point or component within the
system, including the merchant gateway, banks, and payment processor.
9. Creating physical barriers to server rooms, switch closets, and other equipment that either
stores cardholder data or facilitates the processing of transactions.
10. Implementing network monitoring that provides audit trails and log activity that are
reviewed for malicious activity.
11. Identifying vulnerabilities in systems and processes by performing activities such as
penetration tests and auditing processes.
12. Creating, enforcing, and regularly updating written policy for each stage of the payment
process that outlines responsibilities and procedures to protect cardholder data, as it
applies to a given entity.

reserved.
3
MODULE
Center for Internet Security
Critical Security Controls:
Part 1 ISC 1
1 Center for Internet Security (CIS) Controls
1.1 Overview
The Center for Internet Security (CIS) Controls are a recommended set of actions, processes,
and best practices that can be adopted and implemented by organizations to strengthen their
cybersecurity defenses. CIS Controls were first developed in 2008 by an international consortium
and have evolved over time. The controls are currently supported by the SANS Institute, which
provides training, administers certification, and performs research. However, each iteration
of control updates involves experts across industries, entity-type (government vs. public
companies), and job roles (from operators to policy makers).
The most recent update to the CIS Controls®, Version 8, modifies the controls so that they
are no longer organized by who manages a device. Rather, the controls are now task-focused
and organized by activities. This change decreased the number of CIS controls from 20 to 18
and positions the controls to accommodate shifts in the cybersecurity ecosystem to cloud
computing, remote work, and virtualization. Within the 18 controls are 153 subcategories called
Safeguards, down from the prior version's 171 subcategories in Version 7.1. Safeguards are the
recommendations prescribed to achieve each control objective.
1.2 Design Principles

The CIS Controls were designed with the following principles in mind:
Align: Controls should map to other top cybersecurity standards. As such, they map to
standards like the NIST Cybersecurity Framework, COBIT, HIPAA, NIST Special Publication
800-53 Rev. 5, and the AICPA's Trust Services Criteria (SOC 2®).
Measurable: Controls should be simple and measurable, avoiding vague language.
Offense Informs Defense: Controls are drafted based on data from actual cybersecurity
attacker behavior and how to defend against it.
Focus: Controls should help prioritize the most critical problems and avoid resolving every
cybersecurity issue.
Feasible: All recommendations should be practical.
© Becker Professional Education Corporation. All rights reserved. Module 3 Center

S1–21
for Internet Security Cr
3 Center for Internet Security Critical Security Controls: Part 1 ISC 1
1.3 Implementation Groups

The implementation of the CIS Controls can be tailored to an organization's size by using one of
three Implementation Groups (IGs). These are self-assessed categories that identify a subset of
the CIS Controls, which are critical for companies to adopt, given their size.
Essen�al Cyber Hygiene
IG1
IG2 IG3
Source: CIS Critical Security
Controls: Version 8
IG1
Essen�al Cyber Hygiene This group is for small or medium-sized organizations that have a limited
IG1 cybersecurity defense mechanism in place in terms of personnel or IT assets.
The main focus of this group is to keep the company operational because their
cybersecurity expertise is limited, the data being used is not sensitive, and the
company cannot sustain long periods of downtime.
IG2 (Includes IG1)

Essen�al Cyber Hygiene This group is for companies that have IT staff who support multiple departments
IG1 that have various risk profiles. These organizations typically have sensitive client
data, and they can tolerate short interruptions in service. One of the biggest
concerns for these entities is loss of trust in the event of a data breach.
IG2
IG3 (Includes IG1 and IG2)

Essen�al Cyber Hygiene Organizations in this group have security experts in all the domains within
IG1 cybersecurity like penetration testing, risk management, and application security.
Data assets under management at these companies include those that are
sensitive and likely subject to compliance with standards or regulatory oversight.
IG2 IG3 Attacks on these organizations can cause significant damage to the company and
the public.
S1–22 Module 3 Center

© Becker for Internet
Professional Security
Education Critical Security
Corporation. Controls:
All rights reserved.Part 1
ISC 1 3 Center for Internet Security Critical Security Controls: Part 1
2 CIS Controls 01–09
2.1 Control 01: Inventory and Control of Enterprise Assets

This control helps organizations actively track and manage all IT assets connected to a
company's IT infrastructure physically or virtually within a cloud environment. This allows
companies to know the totality of IT assets that should be monitored and protected. Using an IT
inventory list, as shown in the following example, will allow organizations to track various data
points for company assets:
Support
Asset Serial Warranty
Model User End-of-Life
Description Number Expiration
Date
Laptop N4300008A ProBook 500 Avery Greene 20X5 20X5
Scanner XCH00R DesignJet T830 Martin Glenn 20X6 20X7
Having a comprehensive view of company assets will also give visibility into how data flows
throughout an organization. Knowing which devices contain sensitive information can help IT
managers prioritize the security and maintenance for those devices (e.g., knowing servers and
laptops that store employee records should be closely monitored for needed updates, cyber
threats, and other irregularities so that unauthorized access is prevented).
Companies should also focus on the potential for external devices to connect to a company's
network through means such as guest networks, even if they are segregated from the core
network. Other scenarios in which external devices connect to a company's core network
include temporary access granted to auditors and permanent access given to managed service
providers (MSPs) to manage a company's IT operations.
One challenge organizations face is portable end-user devices that periodically connect to a
company's network and then disappear, making it difficult for organizations to have a holistic
view of its inventory when devices are off, paused, or otherwise disconnected from the
corporate network. Having a robust IT inventory system will mitigate these issues.
The following is a list of the Safeguards (recommendations) within Control 01, along with the
asset type associated with the Safeguard, security function, and whether the Safeguard is a
priority for an Implementation Group:
SECURITY
CONTROL ASSET TYPE IG1 IG2 IG3
FUNCTION
1.1 Establish and Maintain Detailed Asset

DEVICES IDENTIFY
Inventory
1.2 Address Unauthorized Assets DEVICES RESPOND
1.3 Utilize an Active Discovery Tool DEVICES DETECT
1.4 Use DHCP Logging to Update Company

Inventory—Helps detect which devices are DEVICES IDENTIFY
active on the network.
1.5 Use a Passive Asset Discovery Tool—
Identifies devices connected to a DEVICES DETECT
company’s network.
Source: CIS Critical Security Controls Version 8

S1–23
2.2 Control 02: Inventory and Control of Software Assets

This control provides recommendations for organizations to track and actively manage all
software applications so that only authorized software is installed on company devices. This
control also provides guidance on finding unmanaged and unauthorized software already
installed so that it can be removed and remediated.
Software within scope consists of operating systems, programming software, business
applications, drivers, open-source software, and some forms of firmware, which is embedded
software that comes standard in hardware such as a scanner or printer.
Control lists and policies should be in place so that only approved software is installed on
company devices. Maintaining a software inventory list keeps the company informed on whether
the most current software patches are installed, applications reaching end-of-life support are
renewed or transitioned out, and any additional safeguards needed are in place to compensate
for software-related risks.
One popular method of managing software applications is using tools that provide an inventory
check against commonly used applications in other companies. Such tools reference information
regarding each application's patch level, latest version installed, and naming structure.
SECURITY
FUNCTION
2.1 Establish and Maintain a Software

APPLICATIONS IDENTIFY
Inventory
2.2 Ensure Authorized Software Is Currently
Supported
2.3 Address Unauthorized Software APPLICATIONS RESPOND
2.4 Utilize Automated Software Inventory

APPLICATIONS DETECT
Tools
2.5 Allowlist Authorized Software—Ensures
only authorized software can be accessed APPLICATIONS PROTECT
or executed.
2.6 Allowlist Authorized Libraries—Ensures
that only specific files can be loaded into a APPLICATIONS PROTECT
system process.
2.7 Allowlist Authorized Scripts—Ensures only
authorized scripts, or lines of code, can be APPLICATIONS PROTECT
executed.
2.3 Control 03: Data Protection

This control helps organizations develop ways to securely manage the entire life cycle of their
data, from the initial identification and classification data to its disposal.
Organizations must identify, archive, label, and classify their data to understand the implications
of the data being lost or compromised. Classification categories are labeled at the discretion of
the enterprise and should be assigned based on sensitivity, such as internal, public, sensitive,
and confidential. These labels will vary by industry and each country's relevant regulations,
privacy requirements, and compliance obligations.

After sensitivity is defined, data mapping should be developed that identifies the various
software applications that access each of these sensitivity levels. This would allow devices and
software to be consolidated into one network so that more sensitive classifications are separate
from less sensitive forms of data. Retention requirements, access control lists, access logging
mechanisms, and data disposal plans can also be implemented in a tailored fashion once data
classification levels are assigned. Encryption can be strategically used to further secure data at
rest and in transit so that data compromise is avoided.
SECURITY
FUNCTION
3.1 Establish and Maintain a Data

DATA IDENTIFY
Management Process
3.2 Establish and Maintain a Data Inventory DATA IDENTIFY
3.3 Configure Data Access Control Lists DATA PROTECT
3.4 Enforce Data Retention DATA PROTECT
3.5 Securely Dispose of Data DATA PROTECT
3.6 Encrypt Data on End-User Devices DEVICES PROTECT
3.7 Establish and Maintain a Data

DATA IDENTIFY
Classification Scheme
3.8 Document Data Flows DATA IDENTIFY
3.9 Encrypt Data on Removable Media DATA PROTECT
3.10 Encrypt Sensitive Data in Transit DATA PROTECT
3.11 Encrypt Sensitive Data at Rest DATA PROTECT
3.12 Segment Data Processing and Storage

NETWORK PROTECT
Based on Sensitivity
3.13 Deploy a Data Loss Prevention Solution DATA PROTECT
3.14 Log Sensitive Data Access DATA DETECT
2.4 Control 04: Secure Configuration of Enterprise Assets and

Software
This control helps organizations establish and maintain secure baseline configurations for
their enterprise assets, including network devices, mobile and portable end-user devices,
non-computing assets such as Internet of Things (IoT) devices, operating systems, and other
corporately managed hardware or software applications.

S1–25
Many applications are sold preconfigured with default configuration settings that were designed
for ease of installation or usage. However, default configurations may present vulnerabilities
that can be exploited, allowing unauthorized users to gain access to an organization's core
network. This means organizations should implement control activities to assess preconfigured
devices at their baseline state, modify vulnerable configuration settings, and eventually move to
a continuous review phase.
Publicly available security standards, such as the CIS Benchmarks Program or NIST National
Checklist Program Repository, can be used by organizations as a starting point for asset
reconfiguration. Adhering to these standards will also assist in complying with any applicable
laws and regulations.
Security hardening, which is the process of making an organization less vulnerable to attacks,
can be incorporated into adjusting target security configurations so that they are continuously
"hardened" against new forms of attack. These improvements may include removing any
unused or unnecessary software, closing network ports that are openly exposed to the internet,
changing default passwords, and turning off nonessential services.
Security tools such as firewalls, intrusion detection/prevention systems, data loss prevention
(DLP) systems, and mobile device management (MDM) software can also be used to secure
networks and end-user devices. Organizations with multiple types of environments or data
classification levels may have several security baselines that should be addressed. Once target
configuration levels have been implemented, they should be continuously monitored for
deviations and necessary updates.
SECURITY
FUNCTION
4.1 Establish and Maintain a Secure

APPLICATIONS PROTECT
Configuration Process
Configuration Process for Network NETWORK PROTECT
Infrastructure
4.3 Configure Automatic Session Locking on
USERS PROTECT
Enterprise Assets
4.4 Implement and Manage a Firewall on
DEVICES PROTECT
Servers
4.5 Implement and Manage a Firewall on End-
DEVICES PROTECT
User Devices
4.6 Securely Manage Enterprise Assets and
NETWORK PROTECT
Software
4.7 Manage Default Accounts on Enterprise
USERS PROTECT
Assets and Software
4.8 Uninstall or Disable Unnecessary Services
DEVICES PROTECT
on Enterprise Assets and Software
4.9 Configure Trust DNS Servers on Enterprise
DEVICES PROTECT
Assets
4.10 Enforce Automatic Device Lockout on
DEVICES RESPOND
Portable End-User Devices
4.11 Enforce Remote Wipe Capability on
DEVICES PROTECT
Portable End-User Devices
4.12 Separate Enterprise Workspaces on
DEVICES PROTECT
Mobile End-User Devices

2.5 Control 05: Account Management

This control outlines best practices for companies to manage credentials and authorization
for user accounts, privileged user accounts, and service accounts for company hardware and
software applications.
As with other enterprise assets, accounts must be inventoried and tracked so that appropriate
controls may be applied. Centralized account management tools and services can be utilized
for consolidated account management across the organization. Organizations should develop
and communicate an acceptable use policy and account safety guidelines. Credentials should be
treated as highly sensitive information, and formal training should be provided to educate users
on account safety best practices as well as the organization's account security policies. These
may include password requirements, controls for inactivity, and account lockout policies.
Administrative accounts should be restricted to specific use cases. End-users requiring
administrative privileges should have separate accounts to run administrative actions to lower
the risk of a user's account being compromised because these accounts are more likely to
be targeted by attackers. Service accounts used to run systems and services must be well-
documented, indicating ownership and purpose.
Single Sign-on and Multifactor Authentication
One common and convenient form of authentication is single sign-on (SSO). This lets users
use a single log-in to securely authenticate across multiple applications. While this increases
the number of applications an attacker can gain access to with a single password, security
can be enhanced using multifactor authentication (MFA) so that the users must have a
secondary point of contact to validate their identity.
SECURITY
FUNCTION
5.1 Establish and Maintain an Inventory of

USERS IDENTIFY
Accounts
5.2 Use Unique Passwords USERS PROTECT
5.3 Disable Dormant Accounts USERS RESPOND
5.4 Restrict Administrator Privileges to

USERS PROTECT
Dedicated Administrator Accounts
USERS IDENTIFY
Service Accounts
5.6 Centralize Account Management USERS PROTECT

S1–27
2.6 Control 06: Access Control Management

This control expands on Account Management (Control 05) by specifying the type of access
that user accounts should have. Ideally, an organization's users should only have the necessary
privileges required for their job role.
Organizations should follow the principles of "least privilege" and "need-to-know" role
assignments. These methodologies assist with the goal that users only have access to
systems, services, and data needed to perform their job duties. Accounts that do not follow
these principles pose a security risk to the organization by allowing unauthorized access.
Authentication and authorization systems should be inventoried and centrally managed.
Protocols should be put in place for granting access and revoking access based on job duties,
roles, and responsibilities. Access control models, such as role-based access control (RBAC), can
be utilized to help facilitate this process by defining roles within the organization and assigning
appropriate access to each role to provide separation of duties. For accounts with administrative
access or remote access, additional controls such as multifactor authentication (MFA) and
privileged account management (PAM) can be used as an additional security layer.
A comprehensive solution for provisioning and de-provisioning employee access should also be
in place. Sophisticated methods allow access to all applications across the organization to be
removed synchronously within minutes of initiating such a change in the system.
SECURITY
FUNCTION
6.1 Establish an Access Granting Process USERS PROTECT
6.2 Establish an Access Revoking Process USERS PROTECT
6.3 Require Multifactor Authentication for

USERS PROTECT
Externally Exposed Applications
USERS PROTECT
Remote Network Access
USERS PROTECT
Administrative Access
USERS IDENTIFY
Authentication and Authorization Systems
6.7 Centralize Access Control USERS PROTECT
6.8 Define and Maintain Role-Based Access

DATA PROTECT
Control

2.7 Control 07: Continuous Vulnerability Management

This control assists organizations in continuously identifying and tracking vulnerabilities within
its infrastructure so that it can remediate and eliminate weak points or windows of opportunity
for bad actors.
An evolving cybersecurity landscape requires organizations to keep abreast of threats
and vulnerabilities to be able to defend against them. Attackers can exploit and leverage
vulnerabilities to compromise assets and gain a foothold into a company's network. Unknown
vulnerabilities, referred to as zero-day exploits, occur when there is no known solution to a
weak point. In these instances, attackers can carry out attacks for which there is not yet any
remediation.
Organizations must remain proactive in scanning, monitoring, and managing vulnerabilities to
reduce the window of opportunity for attackers to capitalize on them. As new vulnerabilities
are discovered, they should be assessed for their likelihood of exploitation and impact if they
occur so that they can be ranked and prioritized. Classification schemes such as the Common
Vulnerability Scoring System (CVSS) or Common Vulnerabilities and Exposures (CVE®) list can
be integrated into the assessment process to help determine the impact to the business. These
classification schemes are sources of commonly known security vulnerabilities.
SECURITY
FUNCTION
7.1 Establish and Maintain a Vulnerability

Management Process
7.2 Establish and Maintain a Remediation
APPLICATIONS RESPOND
Process
7.3 Perform Automated Operating System
Patch Management
7.4 Perform Automated Application Patch
Management
7.5 Perform Automated Vulnerability Scans of
Internal Enterprise Assets
7.6 Perform Automated Vulnerability Scans of
Externally Exposed Enterprise Assets
7.7 Remediate Detected Vulnerabilities APPLICATIONS RESPOND

S1–29
2.8 Control 08: Audit Log Management

This control establishes an enterprise log management process so that organizations can be
alerted and recover from an attack in real time, or near real time, using log collection and
analytic features. These types of applications typically retain one of two types of logs, system
logs and audit logs, which provide valuable information that can be used for prevention,
troubleshooting, incident response, discovering patterns, and detecting anomalies.
System logs provide a list of events such as start and end times, points of restoration, and
system crashes. Audit logs are tied to a specific user, recording when a person logs in or out,
accesses a file, or opens an application.
Event Logs
Having access to event logs is critical to incident response, and it can also facilitate
processes for legal matters, such as eDiscovery, accountability for auditing, lessons learned
for process improvement, and data retention for compliance requirements. An enterprise
log management process should address the entire life cycle of audit logs beginning with
log collection and ending with log disposal. Audit logs may be captured from a variety of
connection methods, whether directly to a company's network via a hard-wired connection,
wirelessly, or using a virtual private network (VPN). Organizations should also be notified
when failed user attempts are made to connect to resources without the appropriate
privileges.
SECURITY
FUNCTION
8.1 E
stablish and Maintain an Audit Log
NETWORK PROTECT
Management Process
8.2 Collect Audit Logs NETWORK DETECT
8.3 Ensure Adequate Audit Log Storage NETWORK PROTECT
8.4 Standardize Time Synchronization NETWORK PROTECT
8.5 Collect Detailed Audit Logs NETWORK DETECT
8.6 Collect DNS Query Audit Logs NETWORK DETECT
8.7 Collect URL Request Audit Logs NETWORK DETECT
8.8 Collect Command-Line Audit Logs DEVICES DETECT
8.9 Centralize Audit Logs NETWORK DETECT
8.10 Retain Audit Logs NETWORK PROTECT
8.11 Conduct Audit Log Reviews NETWORK DETECT
8.12 Collect Service Provider Logs DATA DETECT

2.9 Control 09: Email and Web Browser Protections

This control provides recommendations on how to detect and protect against cybercrime
attempted through email or the internet by directly engaging employees. Email clients and
web browsers provide attackers direct access to users who make them vulnerable to social
engineering tactics and delivering malicious payloads.
Attacks such as phishing scams and business email compromise (BEC) can be conducted by
attackers using email to target senior executives who control data and financial resources or
target high-value assets with data that could be used for exploitation or financial gain. Email
client and web browser vulnerabilities can also be exploited to introduce malware into an
organization's network, so only supported and updated versions should be used.
It is recommended that policies and tools be put in place to enforce URL filtering, block certain
file types, and restrict options such as the ability for users to install add-ons. URL blocking can be
done through domain name system (DNS) filtering, which effectively blocks users from accessing
certain domains on a blacklist.
SECURITY
FUNCTION
9.1 Ensure Use of Only Fully Supported

Browsers and Email Clients
9.2 Use DNS Filtering Services NETWORK PROTECT
9.3 Maintain and Enforce Network-Based URL

NETWORK PROTECT
Filters
9.4 Restrict Unnecessary or Unauthorized
Browser and Email Client Extensions
9.5 Implement Domain-Based Message
Authentication Reporting and NETWORK PROTECT
Conformance
9.6 Block Unnecessary File Types NETWORK PROTECT
9.7 Deploy and Maintain Email Server Anti-

NETWORK PROTECT
Malware Protections

S1–31
NOTES

4
MODULE
Center for Internet Security
Critical Security Controls:
Part 2 ISC 1
1 CIS Controls 10–18
The Center for Internet Security (CIS) Controls are a recommended set of actions, processes,
and best practices that can be adopted and implemented by organizations to strengthen their
cybersecurity defenses. Within the 18 controls are 153 subcategories called Safeguards, which
are the recommendations prescribed to achieve each control objective.
1.1 Control 10: Malware Defenses

This control assists companies in preventing the installation and propagation of malware onto
company assets and its network.
Malware can infiltrate as viruses, worms, spyware, adware, keyloggers, and ransomware.
Endpoint assets and devices can be leveraged as both entry points and targets for malware.
Malware can cause substantial damage to an organization by stealing intellectual property or
log-in credentials, destroying data, encrypting data for ransom, or executing other nefarious
activities.
Anti-malware solutions should be automated, centrally managed, maintained, and deployed to
all potential entry points. Security features that prevent the execution of malicious code should
be enabled where possible and any software autorun or autoplay features should be disabled by
default.
As malware defenses become better at defending against threats, some malicious actors have
adjusted their tactics to what is known as LotL, or "living-off-the-land." This approach minimizes
the likelihood that an attacker will get caught by using an organization's existing tools against
itself. Existing tools and applications typically already have access to a wide variety of company
applications, allowing the perpetrator a quick window into a company's systems.
Illustration 1 Malware Impacting Medical Records
Family Practice Medical Inc. (FPMI) is a national chain of health care clinics that offer
primary and emergent care services to more than 50,000 patients. Through their website,
a group of organized cybercriminals was able to identify an open port through which
they gained access to FPMI's network. Once they were in, one of the attackers was able
to open the company's Windows Management Instrumentation (WMI) interface, which
is the primary means the company uses to access credentials, manage security and
antivirus software, and manage file storage. Because the team of attackers was able to
turn off security flags and remove files using WMI, they successfully extracted hundreds of
thousands of medical records and payment information without being detected.

S1–33
SECURITY
FUNCTION
10.1 Deploy and Maintain Anti-Malware

DEVICES PROTECT
Software
10.2 Configure Automatic Anti-Malware
DEVICES PROTECT
Signature Updates
10.3 Disable Autorun and Autoplay for
DEVICES PROTECT
Removable Media
10.4 Configure Automatic Anti-Malware
DEVICES DETECT
Scanning of Removable Media
10.5 Enable Anti-Exploitation Features DEVICES PROTECT
10.6 Centrally Manage Anti-Malware Software DEVICES PROTECT
10.7 Use Behavior-Based Anti-Malware

DEVICES DETECT
Software
1.2 Control 11: Data Recovery

This control establishes data backup, testing, and restoration processes that allow organizations
to effectively recover company assets to a pre-incident state.
Organizational data is a critical resource for conducting business and can be targeted by
ransomware attacks that encrypt data and leave criminals demanding ransom for its restoration.
Human error, misconfigurations, and natural factors (power outages, flooding, etc.) can also
cause data to become unusable or unavailable. Therefore, organizations must establish
processes to enable the recovery and restoration of data to a prior trusted state.
Data value, sensitivity, classification, and retention requirements all factor into the mechanisms
and cadence that will be used for backup and storage methods. Automating the backup process,
utilizing off-site storage in a different geographical location, and using encryption are all
recommended practices. These functions should be tested at least once per quarter to confirm
the protocols and technology in place will work properly. It is also recommended to restore files
using a test bed environment.
SECURITY
FUNCTION
11.1 Establish and Maintain a Data Recovery

DATA RECOVER
Process
11.2 Perform Automated Backups DATA RECOVER
11.3 Protect Recovery Data DATA PROTECT
11.4 Establish and Maintain an Isolated

DATA RECOVER
Instance of Recovery Data
11.5 Test Data Recovery DATA RECOVER

1.3 Control 12: Network Infrastructure Management

This control establishes procedures and tools for managing and securing a company's network
infrastructure. Network infrastructure includes both physical and virtual devices, such as
firewalls, gateways, routers, switches, and wireless access points.
Network architecture documentation and diagrams should be kept up-to-date to accurately
reflect the organization's network topology and layout. Additionally, that documentation should
have critical vendor contact information to increase the likelihood that system upgrades or
patches are implemented in a timely manner. Companies should monitor for end-of-life network
components to make the appropriate upgrades prior to the end date or establish mitigating
controls.
Organizations must continuously identify and remediate insecure default network configuration
settings, misconfigured network settings, insecure protocol usage, and outdated network
software. There are commercial tools available to help fulfill this requirement by evaluating a
company's network against a set of rules to determine whether they are in conflict. These tools
provide sanity checks and should be run every time a significant change is made to firewalls,
access controls lists, or other filtering mechanisms in place.
SECURITY
FUNCTION
12.1 Ensure Network Infrastructure Is Up-to-

NETWORK PROTECT
Date
12.2 Establish and Maintain a Secure Network
NETWORK PROTECT
Architecture
12.3 Securely Manage Network Infrastructure NETWORK PROTECT
12.4 Establish and Maintain Architecture

NETWORK IDENTIFY
Diagram(s)
12.5 Centralize Network Authentication,
NETWORK PROTECT
Authorization, and Auditing
12.6 Use of Secure Network Management and
NETWORK PROTECT
Communication Protocols
12.7 Ensure Remote Devices Utilize a VPN and
Are Connecting to an Enterprise’s AAA DEVICES PROTECT
Infrastructure
12.8 Establish and Maintain Dedicated
Computing Resources for All DEVICES PROTECT
Administrative Work
1.4 Control 13: Network Monitoring and Defense

This control establishes processes for monitoring and defending a company's network
infrastructure against internal and external security threats. Even though network monitoring
and defense software solutions may be highly proficient when purchased, there is still
some degree of fine-tuning that is specific to a company's network that is required. There is,
nevertheless, the possibility of human error or new attack schemes that were not common at
the time of the network system's inception. Therefore, continuous monitoring is critical to keep
pace with an evolving cybersecurity landscape.

S1–35
Denial of Service (DoS) and Ransomware

Two common ways networks can be attacked include denial of service (DoS) attacks and
ransomware. DoS attacks involve a perpetrator gaining access to a company's network and
overloading it with traffic so that it is effectively rendered useless. Ransomware attacks are
situations in which an attacker or group of attackers gain access to a company's system,
block employees from accessing it, demand payment to regain access, and threaten to
either keep all systems blocked or publish sensitive data to the public (or dark web) if the
company doesn't comply.
To combat these schemes, organizations should establish event logging and alerting
mechanisms that can be implemented through tools such as security information and event
management (SIEM) to help centralize and assist in log analysis. Traffic flow monitoring,
alerting, and detection safeguards can also be implemented with tools such as network
intrusion prevention systems (NIPS), next-generation firewalls (NGFW), data loss prevention
(DLP) systems, and endpoint detection and response (EDR) systems.
Many organizations have their own security or network operations center (often referred to as
the SOC or NOC, respectively) that is uniquely equipped to run a robust IT networking operation.
Smaller organizations often do not have the resources to employ such a large team, so they
outsource their IT function to managed service providers (MSPs) to access these services.
SECURITY
FUNCTION
13.1 Centralize Security Event Alerting NETWORK DETECT
13.2 Deploy a Host-Based Intrusion

DEVICES DETECT
Detection Solution
13.3 Deploy a Network Intrusion Detection
NETWORK DETECT
Solution
13.4 Perform Traffic Filtering Between
NETWORK PROTECT
Network Segments
13.5 Manage Access Controls for Remote
DEVICES PROTECT
Assets
13.6 Collect Network Traffic Flow Logs NETWORK DETECT
13.7 Deploy a Host-Based Intrusion

DEVICES PROTECT
Prevention Solution
13.8 Deploy a Network Intrusion Prevention
NETWORK PROTECT
Solution
13.9 Deploy Port-Level Access Control DEVICES PROTECT
13.10 Perform Application Layer Filtering NETWORK PROTECT
13.11 Tune Security Event Alerting Thresholds NETWORK DETECT

1.5 Control 14: Security Awareness and Skills Training

This control guides organizations in establishing a security awareness and training program
to reduce cybersecurity risk. One of the goals of this type of training is to influence employee
behavior in a way that makes them conscious about the various tactics that can be employed by
attackers that allow unauthorized access.
Uninformed employees pose one of the greatest risks to the security of an organization, and
risks can originate externally or internally. Social engineering techniques targeting enterprise
workforces can lead to significant business disruption, financial losses, and loss of reputation.
Human error, negligence, and misuse of organizational assets can also introduce security issues.
Regular training is one of the best ways to establish security awareness, including educating
staff on recognition of unusual behavior, social engineering tactics, best practices for handling
organizational assets and data, and the risks involved with using insecure networks and devices.
Staff should also understand the organization's processes for reporting incidents, issues, and
concerns.
Training should not be reduced to an annual occurrence. Rather, it should be more frequent and
include messages that resonate with users, such as the impact of recent data breaches at well-
known companies, the rise of phishing scams during tax season, or information on phony gift
rewards sent via email.
SECURITY
FUNCTION
14.1 Establish and Maintain a Security

N/A PROTECT
Awareness Program
14.2 Train Workforce Members to Recognize
N/A PROTECT
Social Engineering Attacks
14.3 Train Workforce Members on
N/A PROTECT
Authentication Best Practices
14.4 Train Workforce on Data Handling Best
N/A PROTECT
Practices
14.5 Train Workforce Members on Causes of
N/A PROTECT
Unintentional Data Exposure
14.6 Train Workforce Members on
Recognizing and Reporting Security N/A PROTECT
Incidents
14.7 Train Workforce on How to Identify and
Report if Their Enterprise Assets Are N/A PROTECT
Missing Security Updates
14.8 Train Workforce on Dangers of
Connecting to and Transmitting N/A PROTECT
Enterprise Data Over Insecure Networks
14.9 Conduct Role-Specific Security
N/A PROTECT
Awareness and Skills Training

S1–37
1.6 Control 15: Service Provider Management

This control helps organizations develop processes to evaluate third-party service providers that
have access to sensitive data or that are responsible for managing some or all of a company's
IT functions. Proper controls in this area enhance the likelihood that a company's data,
applications, and hardware are protected adequately.
Risks can be introduced by third-party service providers that do not hold themselves to the same
security standards as other organizations. Part of the reason for this disparity in organizational
standards is that there are only a few industry standards available in the public domain.
Examples of such standards include the Shared Assessments program for the finance industry
and the Higher Education Community Vendor Assessment Toolkit (HECVAT) for higher education.
As such, it is recommended that companies establish service provider management processes
to oversee the entire service provider life cycle. Service providers should be assessed, and their
performance and standards catalogued from initial engagement through decommissioning
for adherence to security standards, protocols, and best practices. System and Organization
Controls (SOC) audit reports can be used to assess the risks of doing business with service
providers.
SECURITY
FUNCTION

N/A IDENTIFY
Service Providers
15.2 Establish and Maintain a Service Provider
N/A IDENTIFY
Management Policy
15.3 Classify Service Providers N/A IDENTIFY
15.4 Ensure Service Provider Contracts

N/A PROTECT
Include Security Requirements
15.5 Assess Service Providers N/A IDENTIFY
15.6 Monitor Service Providers N/A DETECT
15.7 Securely Decommission Service

N/A PROTECT
Providers
1.7 Control 16: Application Software Security

This control establishes safeguards that manage the entire life cycle of software that is acquired,
hosted, or developed in-house to detect, deter, and resolve cybersecurity weaknesses before
they are exploited. This is becoming more challenging in today's environment because software
development life cycles have shortened and have become more complex because software
applications are often a mix of various sources of existing code, libraries, and new code. Instead
of being created from scratch, many new applications are aggregations of these various sources,
making it critical to understand the facets of each to thwart bad actors.
Software vulnerabilities may exist for various reasons like a flawed design, poor infrastructure,
coding errors, poor authentication protocols, and the failure to test for software anomalies.
Specific types of vulnerabilities mentioned in the CIS Control document for Control 16
include buffer overflows, cross-site scripting (XSS), SQL injections, and race conditions. These
vulnerabilities can be leveraged by attackers to escalate privileges (the terms escalate and elevate
are used somewhat interchangeably across standards in the context of privileges), compromise
assets, and gain a foothold into the company network.

IT managers must consider whether best practices and safeguards are being followed, such as
secure design standards and secure code reviews, and security testing tools are integrated into
the software development life cycle (SDLC). It is recommended to introduce application security
as early in the SDLC as possible because coding changes as development processes becomes
more complex. Processes should also be in place to inventory third-party software components,
tools, and applications. Suggested activities include determining whether software is up-to-
date, configurations settings are reviewed, and compensating controls are in place for attack
mitigation.
One common blind spot modern organizations have is the lack of visibility into Software-as-
a-Service (SaaS) platforms. These platforms can be hosted anywhere across the globe and
their software development and review processes usually do not involve their clients. As
such, companies using SaaS should inquire about such practices and consider obtaining SOC
reports to obtain assurance as to whether they operate according to the terms of service-level
agreements, especially if the platform is a steward of sensitive employee or customer data.
Some larger organizations may consider implementing a bug bounty program in which
employees are paid for finding flaws in company-produced or company-used software. These
programs create camaraderie and healthy competition and are effective ways to find software
vulnerabilities.
SECURITY
FUNCTION

Application Development Process
16.2 Establish and Maintain a Process
to Accept and Address Software APPLICATIONS PROTECT
Vulnerabilities
16.3 Perform Root Cause Analysis on Security
Vulnerabilities
16.4 Establish and Manage an Inventory of
Third-Party Software Components
16.5 Use Up-to-Date and Trusted Third-Party
Software Components
16.6 Establish and Maintain a Severity Rating
System and Process for Application APPLICATIONS PROTECT
Vulnerabilities
16.7 Use Standard Hardening Configuration
Templates for Application Infrastructure
16.8 Separate Production and Non-Production
Systems
16.9 Train Developers in Application Security
Concepts and Secure Coding
16.10 Apply Secure Design Principles in
Application Architectures
16.11 Leverage Vetted Modules or Services for
Application Security Components
16.12 Implement Code-Level Security Checks APPLICATIONS PROTECT
16.13 Conduct Application Penetration Testing APPLICATIONS PROTECT
16.14 Conduct Threat Modeling APPLICATIONS PROTECT

S1–39
1.8 Control 17: Incident Response Management

This control provides the recommendations necessary to establish an incident response
management program to detect, respond, and prepare for potential cybersecurity attacks. When
security incidents occur, their impact can be widespread throughout the organization.
In certain cases, laws and regulations may require notification of data breaches and impose
fines for noncompliance, which makes it imperative to have programs in place to detect, contain,
and eliminate threats. Examples include the Health Insurance Portability and Accountability Act
(HIPAA), which governs medical information in the United States, or the General Data Protection
Regulation (GDPR), which governs data in the European Union.
The incident response process should include the designation of a key contact, establishment of
an incident response team, and the development of communication plans for notifying impacted
business units, stakeholders, and regulatory agencies. It is also important to periodically carry
out exercises to test the incident response process to ascertain its effectiveness and identify
opportunities for improvement.
SECURITY
FUNCTION
17.1 Designate Personnel to Manage Incident

N/A RESPOND
Handling
17.2 Establish and Maintain Contact
N/A RESPOND
Information for Reporting
17.3 Establish and Maintain an Enterprise
N/A RESPOND
Process for Reporting Incidents
17.4 Establish and Manage an Incident
N/A RESPOND
Response Process
17.5 Assign Key Roles and Responsibilities N/A RESPOND
17.6 Define Mechanisms for Communicating

N/A RESPOND
During Incident Response
17.7 Conduct Routine Incident Response
N/A RECOVER
Exercises
17.8 Conduct Post-Incident Reviews N/A RECOVER
17.9 Establish and Maintain Security Incident

N/A RECOVER
Thresholds
1.9 Control 18: Penetration Testing

This control helps organizations test the sophistication of their cybersecurity defense system in
place by simulating actual attacks in an effort to find and exploit weaknesses. Penetration testing
is typically performed as a dramatic demonstration of an attack, as a method to verify whether a
company's defenses work, and to make sure the company has the right defenses in place.
Penetration testing in this control is different than vulnerability testing in Control 7 in that
penetration testing seeks to go beyond identifying weaknesses. It attempts to exploit those weak
points and see what additional damage could be done once that first point of failure is reached.

Similar to penetration testing, "Red Team" exercises focus on specific tactics, techniques, and
procedures (TTPs) to see how an organization fares against certain types of attackers. Each
industry is exposed to a different mix of cybersecurity risks, with some bearing more risk simply
due to the nature of the business. For instance, health care companies and financial institutions
possess Social Security numbers, banking information, credit cards, and other personal
information that can be used to exploit one of their customers.
Illustration 2 Penetration Testing: Payment Transactions
First Payment Network Inc. is a credit card processing company that has developed a new
technology that couples bio-recognition with payment transactions. First Payment wishes
to see how easy it would be to either forge a fingerprint on in-person scanners used for
transactions or to bypass the processing card network's code that requires the bio-metric
for validation. To test this technology prior to launching it, First Payment engages an MSP
that specializes in Red Team exercises and specifically, financial transactions.
Penetration testing generally begins with a discovery or observation of an organization's

environment, followed by scanning to locate vulnerabilities that can be used to gain access.
Then those vulnerabilities become targets, and the team of testers exploits those targets
to demonstrate how an attacker can bypass controls. The results are then studied, and the
company revises its controls accordingly. This process can, and should be, performed at least
annually for large organizations with significant cybersecurity risk.
SECURITY
FUNCTION
18.1 Establish and Maintain a Penetration

N/A IDENTIFY
Testing Program
18.2 Perform Periodic External Penetration
NETWORK IDENTIFY
Tests
18.3 Remediate Penetration Test Findings NETWORK PROTECT
18.4 Validate Security Measures NETWORK PROTECT
18.5 Perform Periodic Internal Penetration

N/A IDENTIFY
Tests

S1–41
NOTES

5
MODULE
COBIT 2019
Framework ISC 1
1 Overview
1.1 Control Objectives for Information and Related Technologies

(COBIT)
In 1996, the Information Systems Audit and Control Association (ISACA) developed what would
become one of the most widely used enterprise IT governance standards: the Control Objectives
for Information and Related Technologies (COBIT). ISACA is a nonprofit that was formed in
1967 by a small group of computing pioneers who formed to help companies and technology
professionals manage, optimize, and protect information technology (IT) assets. Since then,
ISACA has evolved into a standards and educational organization that spans the globe and has
thousands of members.
To accomplish its mission, ISACA created the COBIT framework, which provides a roadmap that
organizations can use to implement best practices for IT governance and management. COBIT
was originally developed as a set of standards for auditors that unified multiple different and
disparate standards. Over time, the COBIT standards changed and developed with different
goals:
COBIT 1
1996 Standards for IT Auditors were established
COBIT 2
1998 IT control guidance was added
COBIT 3
2000 COBIT was released as a management framework
COBIT 4
2005 COBIT was released as a comprehensive IT governance
framework
COBIT 5
2012 COBIT launched as a comprehensive global framework
mapping enterprise strategy to IT strategy
COBIT 2019
2018 COBIT was updated by adding a maturity model based on the
Capability Maturity Model Integration (CMMI) and a
governance implementation guide
1.2 Governance Stakeholders

COBIT distinguishes between governance and management, recognizing them as two unique
disciplines that each exist for different reasons and require different sets of organizational
resources. Organizational governance is typically the responsibility of a company's board
of directors, consisting of a chairperson and focused organizational structures (e.g., audit
committee, executive committee, marketing committee).
Material from COBIT®, © 2019 ISACA. All rights reserved. Used with permission.
© Becker Professional Education Corporation. All rights reserved. Module 5 S1–43

5 COBIT 2019 Framework ISC 1
Management is responsible for the daily planning and administration of company operations,
generally consisting of a chief executive officer (CEO), chief financial officer (CFO), chief
operations officer (COO), and other executive leaders. Management is selected and guided by
the board of directors.
Stakeholders can be either internal or external, with the board of directors and management
considered internal. Other internal stakeholders include business managers, IT managers,
assurance providers, and risk managers. External stakeholders include regulators, investors,
business partners, and IT vendors, parties who are entitled to some information about
compliance and risk mitigation but are not entitled to the same information given to internal
stakeholders.
1.3 COBIT® 2019 Overview

As part of its foundation, COBIT® 2019 was developed using the following:
COBIT 5
Six principles for a governance system
Three principles for a governance framework
Other standards and regulations
Community contribution
These principles, standards, and regulations were used to form the COBIT core model, which can
then be customized through Design Factors and Focus Areas to arrive at a tailored enterprise
governance system for any organization.
The following graphic depicts the inputs of the core model, the path that organizations can take
to customize the application of the model, and the underlying publications that can be used as a
roadmap to implement the COBIT framework:
COBIT 5
6 Principles for a
Governance
System Design
Tailored Enterprise
Factors
Governance System
3 Principles for a for Information
Governance Technology
Framework Focus
Area
Other Standards,
Frameworks,
Regs
Community
Contribution COBIT 2019 COBIT 2019 COBIT 2019 COBIT 2019
Framework: Framework: Design Guide Implementation
Intro & Governance & Guide
Methodology Mgmt. Objectives
COBIT Core Publications
S1–44 Module 5 COBIT

© Becker Professional Education Corporation. 2019
All rights Framework
reserved.
ISC 1 5 COBIT 2019 Framework
2 Governance System Principles
2.1 Six Principles for a Governance System

The six principles outlined for a governance system that were used to develop the COBIT 2019
core model are shown below.
GOVERNANCE SYSTEM PRINCIPLES
1 2 3 4 5 6
Provide Holistic Dynamic Governance Tailored End-to-End

Stakeholder Approach Governance Distinct to Enterprise Governance
Value System From Needs System
Management
Provide Stakeholder Value: Governance systems should create value for the company's
stakeholders by balancing benefits, risks, and resources. This should be accomplished
through a well-designed governance system with an actionable strategy.
Holistic Approach: Governance systems for IT can comprise diverse components,
collectively providing a holistic model.
Dynamic Governance System: When a change in one governance system occurs, the
impact on all others should be considered so that the system continues to meet the
demands of the organization. This means having a system that is dynamic enough that it
can continue to be relevant while adjusting as new challenges arise.
Governance Distinct From Management: Management activities and governance systems
should be clearly distinguished from each other because they have different functions.
Tailored to Enterprise Needs: Governance models should be customized to each
company, using design factors to prioritize and tailor the system.
End-to-End Governance System: More than just the IT function should be considered in a
governance system. All processes in the organization involving information and technology
should be factored into an end-to-end approach.

3 Governance Framework Principles
3.1 Three Principles for a Governance Framework

In addition to the governance system principles, there are three principles that were used to
develop the COBIT 2019 GOVERNANCE FRAMEWORK PRINCIPLES
core model, as follows.
1 3
Aligned to
Based on
Major Standards
Conceptual
Model
Open and Flexible

Based on Conceptual Model: Governance frameworks should identify key components

as well as the relationships between those components in order to provide for greater
automation and to maximize consistency.
Open and Flexible: Frameworks should have the ability to change, adding relevant content
and removing irrelevant content, while keeping consistency and integrity.
Aligned to Major Standards: Frameworks should align with regulations, frameworks, and
standards.
4 Governance System Components
4.1 COBIT Core Model

According to the COBIT 2019 core model, governance and management objectives should be
set so that information technology and systems contribute to company goals. Governance
objectives always relate to a governance process while management objectives are always
associated with management processes. Boards of directors are responsible for governance,
whereas middle and senior management is responsible for management objectives.

reserved.
The COBIT 2019 core model is summarized in the following graphic:
COBIT CORE MODEL

GOVERNANCE OBJECTIVES
Evaluate, Direct, and Monitor (EDM)
EDM01-Ensured EDM02-Ensured EDM03-Ensured EDM04-Ensured EDM05-Ensured
Governance Benefits Delivery Risk Optimization Resource Stakeholder
Framework Setting Optimization Engagement
and Maintenance
MANAGEMENT OBJECTIVES
Align, Plan, and Organize (APO) Monitor,
Evaluate, and
AP001- AP002- AP003- AP004- AP005- AP006- AP007- Assess (MEA)
Managed I&T Managed Managed Managed Managed Managed Managed
Mgmt. Strategy Enterprise Innovation Portfolio Budget and Human
Framework Architecture Costs Resources MEA01-Managed
Performance and
AP008- AP009- AP010- AP011- AP012- AP013- AP014- Conformance
Managed Managed Managed Managed Managed Risk Managed Managed Data Monitoring
Relationships Service Vendors Quality Security
Agreements
MEA02-Managed
Build, Acquire, and Implement (BAI) System of Internal
Control
BAI01- BAI02- BAI03- BAI04- BAI05- BAI06- BAI07-Mgd. IT
Managed Managed Managed Managed Managed Managed IT Change
Programs Requirements Solutions ID & Availability and Organizational Changes Acceptance and
Definition Build Capacity Change Transitioning
BAI08- BAI09- BAI10- BAI11-

Managed Managed Managed Managed MEA03-Managed
Knowledge Assets Configuration Projects Compliance With
External
Requirements
Deliver, Service, and Support (DSS)

DSS01- DSS02-Mgd. DSS03- DSS04- DSS05- DSS06- MEA04-Managed
Managed Service Managed Managed Managed Managed Assurance
Operations Requests and Problems Continuity Security Business Proc.
Incidents Services Controls
Governance objectives are grouped into one domain:

Evaluate, Direct, and Monitor (EDM): Those charged with governance evaluate strategic
objectives, direct management to achieve those objectives, and monitor whether objectives
are being met. There are five objectives within this domain: ensuring business delivery,
governance framework setting, risk optimization, resource optimization, and stakeholder
engagement.
Management objectives have four domains:
Align, Plan, and Organize (APO): Focuses on information technology's overall strategy,
organization, and supporting activities. There are 14 objectives within this domain. Managed
data is one of the most significant, as it ensures that critical data assets must be utilized
to achieve company goals. The other objectives provide guidance on IT infrastructure
and architecture, innovation, budgeting, human resources, vendors, quality, security, and
managing risk.

Build, Acquire, and Implement (BAI): Addresses the implementation of information

technology's solutions in the organization's business processes. This domain has 11
objectives, offering guidance on requirements definitions, identifying solutions, managing
capacity, dealing with organizational and IT change, managing knowledge, administering
assets, and managing configuration.
Deliver, Service, and Support (DSS): Addresses the security, delivery, and support of IT
services. The six objectives in this domain cover managed operations, service requests,
managed problems, continuity, security services, and business process controls.
Monitor, Evaluate, and Assess (MEA): Addresses information technology's conformance
to the company's performance targets and control objectives along with external
requirements. There are four objectives in this domain covering managed performance and
conformance monitoring, managed system of internal control, compliance with external
requirements, and managed assurance.
Illustration 1 COBIT EDM Assessment
The Alliance Corp., a high-end furniture retailer and manufacturer, is interested in aligning
its information and technology processes with its strategic objectives. The CEO consults
with the CIO, who recommends they use the COBIT 2019 framework as a benchmark to
determine where the company currently stands relative to best practices. To accomplish
this, the executive team assesses the company using each of the 40 governance and
management objectives by first determining whether there is a gap and then gauging the
importance of that objective.
Below is an excerpt of the assessment for the EDM domain:
Process ID Process Name Gap? Importance

Evaluate, Direct, and Monitor (EDM)
EDM01 Ensured Governance Framework Setting and Yes High
Maintenance
EDM02 Ensured Benefits Delivery Yes Moderate
EDM03 Ensured Risk Optimization Yes High
EDM04 Ensured Resource Optimization Yes High
EDM05 Ensured Stakeholder Engagement No Very High
The executive team rates four out of five EDM processes as gaps, with the only objective
not considered a gap being that stakeholders are indeed supportive and communicate
effectively regarding existing IT strategy. EDM01 is rated as a gap because there is no
consistent approach that aligns IT governance with the company's objectives. Compliance
with legal is lacking, and processes are not effectively overseen. It rates EDM02 through
EDMO4 as gaps because IT services and personnel are not cost effectively delivered
throughout the organization. There is significant overlap in processes and wasted expenses
that could be avoided, which indicates that the company is operating at a much higher risk
level than its risk appetite and tolerance threshold.
As a result, the executive team decides to overhaul the IT function by eliminating
duplicative processes, placing a budget and better purchase approval process in place,
requiring employees to use the company's help desk for all tasks that can be resolved
remotely, and repurposing IT staff working on low-value-add tasks to activities that align
with the executive team's governance objectives.

reserved.
4.2 Components of the Governance System

Components of a governance system are factors that either collectively or individually contribute
to the successful execution of a company's governance system over information technology and
systems. These components can be of different types and interact with each other. The COBIT
2019 core model uses the following seven components to satisfy management and governance
objectives:
Processes: These are a set of activities or practices that produce outputs that help achieve
overall information technology goals.
Organizational Structures: These structures are the decision-making entities within an
organization.
Principles, Policies, Frameworks: These serve as the guide for turning desired behavior
into practice.
Information: This refers to the information needed for the governance system to function
properly.
Culture, Ethics, and Behavior: These factors influence the success of all management and
governance activities.
People, Skills, and Competencies: These are needed so that sound decisions are made,
corrective actions are taken when necessary, and critical objectives are completed.
Services, Infrastructure, and Applications: These are the tools required so that a well-
designed governance system is in place for information technology processing.
5 Design Factors and Focus Areas
5.1 Design Factors

COBIT design factors influence the design of a company's IT governance system, with a total of
11 factors that should be considered:
Enterprise Strategy: IT governance strategies generally include a primary strategy
and a secondary strategy. Examples include growth/acquisition strategies, innovation/
differentiation strategies, cost leadership strategies, and client service/stability strategies.
Enterprise Goals: Goals support the strategy and are structured based on the balanced
scorecard dimensions, which are financial, customer, internal, and growth.
Risk Profile: The risk profile addresses current risk exposure for the organization and maps
out which risks exceed the organization's risk appetite. These risks include IT operational
incidents, software adoption and usage problems, noncompliance, technology-based
innovation, and geopolitical issues.
Information and Technology (I&T, or IT) Issues: Common issues include regular IT audit
findings of poor IT quality or control, insufficient IT resources, frustration between IT and
different departments, hidden IT spending, problems with data quality, and noncompliance
with applicable regulations.
Threat Landscape: The threat landscape is the environment in which the company
operates. The threat landscape may be classified as normal or high because of geopolitical
threats or issues, the industry sector, or economic issues.

Compliance Requirements: Compliance demands on the company can be classified as low,

normal, or high. The classifications are intuitive, with low requirements implying minimal
compliance demands, normal compliance indicating that the organization is typical of
its industry, and high requirements meaning that the company is subject to higher-than-
average compliance requirements.
Role of IT: IT can be categorized as:
y Support—an IT system that is not critical for operating a business or maintaining
continuity.
y Factory—an IT system that will have an immediate impact in business operations and
continuity if it fails.
y Turnaround—an IT system that drives innovation for the business but is not required
for critical business operations.
y Strategic—an IT system that is crucial for both innovation and business operations.
Sourcing Model for IT: Sourcing is the type of IT procurement model the company adopts,
ranging from outsourcing, to cloud-based (Web-based), built in-house, or a hybrid of any of
these sources.
IT Implementation Methods: The methods that can be used to implement new IT projects
include the Agile development method, the DevOps method, the traditional (waterfall)
method, or a hybrid of these methods.
Technology Adoption Strategy: IT adoption falls into three categories:
y First-mover strategy—emerging technologies adopted as soon as possible to gain an
edge.
y Follower strategy—emerging technologies are adopted after they are proven.
y Slow-adopter strategy—very late to adopt new technologies.
Enterprise Size: Two enterprise sizes are defined—large companies with a total full-time
employee count of more than 250 (default), and small and medium companies with 50 to
250 full-time employees.
5.2 Focus Areas

Focus areas are different types of governance issues, domains, or topics that can be solved
by a combination of management and governance objectives, along with their underlying
components. The COBIT materials provide some examples, such as cybersecurity, cloud
computing, and digital transformation, but state that the number is unlimited.

reserved.
6 COBIT Core Publications
6.1 Publications Available

The COBIT 2019 framework was designed so that companies could adopt its recommendations
in a way that is customized to their own organizational needs. The following publications are the
roadmap to help achieve that customization:
COBIT 2019 Framework: Introduction and Methodology: This publication introduces the
core concepts of the framework.
COBIT 2019 Framework: Governance and Management Objectives: This publication
provides a comprehensive outline of the 40 management and governance objectives, their
related components, and references to other relevant standards and frameworks.
COBIT 2019 Design Guide: Designing an Information and Technology Governance
Solution: This publication covers design topics that influence governance as well as a
guideline for designing a customized governance system.
COBIT 2019 Implementation Guide: Implementing and Optimizing an Information and
Technology Governance Solution: This document provides a road map for continuous
improvement when designing information technology governance systems, and it can be
used in conjunction with the design guide.

NOTES

reserved.
ISC
2
Information Systems and
Data Management
Module
1 IT Infrastructure 3
2 Enterprise and Accounting Information Systems 19
3 Availability, Resiliency, and Disaster Recovery 37
4 Change Management 51
5 Introduction to Data Collection and

the Data Life Cycle 67
6 Data Storage and Database Design 71
7 Data Extraction, Integration, and

Process Documentation 83
NOTES

1
MODULE
IT Infrastructure ISC 2
1 IT Infrastructure
The supporting IT architecture within most modern companies has multiple, interconnected
technological components with the core infrastructure involving a combination of on-premises
and outsourced hardware, software, and specialized personnel. Some organizations manage this
infrastructure themselves, but many are increasingly relying on third-party providers to support
their IT operations, causing the focus on quality System and Organization Controls (SOC) 2®
engagements to grow aggressively in recent years. Therefore, the topics covered throughout
this module are applicable to both an organization’s internal employees and those individuals
auditing the organization.
SOC 2® engagements are examinations in which a third party evaluates and reports on a service
organization’s system controls as it relates to the AICPA’s five Trust Services Criteria: security,
availability, processing integrity, confidentiality, and privacy. Even though SOC 2® audits can
involve any third-party company that manages or has access to sensitive data, they typically
involve companies that manage the IT function of other organizations as their primary business.
These third-party reports give users reasonable assurance that the service organization’s
controls listed in its system description are accurately depicted and effective.
SOC 2® engagements emphasize auditors to not only have an advanced understanding of
information technology terminology, but also technical expertise in the way in which key
components of the modern IT landscape function. This includes being conversant in a variety of
operating systems, network infrastructure topologies, end-user devices, and the hardware used
across all these domains.
1.1 Computer Hardware

Organizations designing their IT infrastructure must decide what hardware will be utilized to
conduct business. Computers, the physical components that comprise computers, computer-
related equipment, and external peripheral devices are referred to as computer hardware (or
just “hardware”). This may include end-user devices such as laptops or desktops, and back-end
devices such as servers, server-side equipment, switches, and routers.
1.1.1 Computers and End-User Devices

End-user devices (EUDs) are electronic machines, typically computers or minicomputers, that
directly interact with employees or consumers at the “edge” of a network, meaning they are the
point in a chain of applications or an organization’s IT architecture that interfaces with a human.
EUDs are different than devices used by programmers, administrators, and developers, who are
the people responsible for building, maintaining, and repairing the underlying infrastructure on
which EUDs operate.
These intermediary individuals work with non-EUDs such as switches, servers, routers, and
other network support devices. Examples of EUDs include company-issued laptops, desktops,
tablets, and wearables that are used by an employee who is strictly the final consumer of that
device rather than an intermediary. The end user may also be a customer of the manufacturer
of that device.

1 IT Infrastructure ISC 2
1.1.2 Internal Computer Hardware

Key hardware components within a computer include microprocessors; graphics and sound
cards; hard drives (permanent storage); random access memory, or RAM (temporary storage);
the power supply; and the motherboard, which connects most of these critical pieces.
1.1.3 External Computer Hardware

Some hardware devices may be external peripheral devices and do not need to be integrated
into the machine itself. Computer mice, keyboards, speakers, microphones, disk drives, memory
devices, network cards, and monitors may be built in or may be external devices that connect
either wirelessly or directly to a computer through a wired connection. Other external devices
include printers, scanners, and networking equipment.
1.1.4 Infrastructure Housing

Although not hardware, the facilities and the safeguards on those facilities that contain
hardware, such as data centers or offices, are part of the broader IT infrastructure. This includes
advanced security systems to monitor and control access. It also includes ventilation and climate
control to keep temperatures down to prevent equipment from overheating.
1.2 Network Infrastructure

Network infrastructure refers to the hardware, software, layout, and topology of network
resources that enable connectivity and communication between devices on a computer network.
1.2.1 Network Infrastructure Hardware

Traditional hardware found in most networks are as follows:
Modems: Modems connect a network to an internet service provider’s network, usually
through a cable connection. It is the device that brings internet into a home or office. A
modem receives analog signals from the internet service provider and translates those
signals into digital signals. Each modem has a public IP address.
Routers: Routers manage network traffic by connecting devices to form a network. They
read the source and destination fields in information packet headers to determine the most
efficient path through the network for the packet to travel. They also act as a link between
a modem and the organization’s switches. If there are no switches, then the router will
connect directly to a user’s device.
Switches: Switches are similar to routers in that they connect and divide devices within a
computer network. However, switches do not perform as many advanced functions as a
router, such as assigning IP addresses. The same way a traditional power strip converts
one electrical outlet into multiple outlets, a network switch can turn one network jack into
several network jacks, so multiple devices can share one network connection.
Gateways: A gateway is a computer or device that acts as an intermediary between
different networks. It transforms data from one protocol into another so that information
can flow between networks. A protocol is a rule, or set of rules, that governs the way in
which information is transmitted, with one of the most common protocols being that which
is used for the internet, known as TCP/IP (transmission control protocol/internet protocol). A
gateway interprets these differing protocols and converts them into the appropriate format
to facilitate network movement, usually between a company’s network and the internet.
S2–4 Module 1 IT Infrastructure

© Becker Professional Education Corporation. All rights reserved.
ISC 2 1 IT Infrastructure
Edge-Enabled Devices: Edge-enabled devices allow computing, storage, and networking

functions closer to the devices where the data or system request originates, rather than a
distant central location. The benefits of this form of distributed computing power are faster
network response times and operability because data does not have to be transmitted to a
remote centralized server for processing.
Servers: Servers are physical or virtual machines that coordinate the computers, programs,
and data that are part of the network. Most business networks use a client/server model in
which the client sends a request to the server and it provides a response or executes some
action. There are various types of servers, including Web servers, file servers, print servers,
and database servers.
Firewalls: Firewalls are software applications or hardware devices that protect a person’s or
a company’s network traffic by filtering it through security protocols with predefined rules.
For companies, these rules may be aligned with company policies and access guidelines.
Firewalls are intended to prevent unauthorized access into the organization and to prevent
employees from downloading malicious programs or accessing restricted sites.
Basic packet-filtering firewalls work by analyzing network traffic that is transmitted in
packets (data communicated) and determining whether that firewall software is configured
to accept the data. If not, the firewall blocks the packet. Firewalls can be set to only allow
trusted sources (IP addresses) to transmit across the network. Other types of firewalls
include:
y Circuit-Level Gateways: Verifies the source of a packet and meets rules and policies
set by the security team.
y Application-Level Gateways: Inspects the packet itself. These gateways are very
resource-intensive and may slow performance.
y Network Address Translation Firewalls: Assigns an internal network address to
specific, approved external sources so that those sources are approved to be inside the
firewall.
y Stateful Multilayer Inspection Firewalls: Combines packet-filtering and network
address translation.
y Next-Gen Firewalls: Assigns different firewall rules to different applications as well
as users. In this way, a low-threat application has more permissive rules assigned to it
while a high-security application may have a highly restrictive rule set assigned.
1.2.2 Network Infrastructure Physical Layout (Topology)

Network topology refers to the physical layout of equipment, or “nodes,” in a network, which
is essential for understanding how to properly engineer the network for optimal performance.
Each topology has different requirements for components, such as the length and type
of connecting cables, data transmission rates, and physical position of each node in the
network. These variables are based on the size of the network, the performance needs of the
organization, and the environment in which the network is built.
The following are the four most common types of network topologies:
Bus Topology: This layout is either in a linear or tree form, with each node connected to a
single line or cable. Data can be transmitted by any node on the system at the same time,
which can cause signal interference. To avoid this, cables must be terminated, or properly
finished, at each end so that signal transmission is optimally managed. A disadvantage of
this is if the central line is compromised, the entire network goes offline.

Mesh Topology: In a mesh topology, there are numerous connections between nodes, with
all nodes being connected in a full mesh topology and only some connected in a partial
mesh topology. This form of layout is commonly used in wireless networks. While the
number of pathways allows high levels of traffic and promotes network stability if a node is
damaged, it can be costly to implement and maintain over the network’s life span.
Ring Topology: Nodes are connected in a circular path in ring topologies. When data is
transferred to a destination device, it must first go through every other device between the
source and destination. There are unidirectional ring paths that allow data transmission
to move in one direction, and there are multidirectional paths that allow two-way data
transmission. An advantage of ring topologies is that data transmission collision is
minimized or eliminated, but this can result in very slow network performance.
Star Topology: In a star topology, data passes through a central hub that acts as a switch
or server, and then transmits to peripheral devices that act as clients. There can be multiple
hubs so that if one fails, only the nodes connected to that hub will stop functioning. Even
though the hub is a single point of failure for all connected nodes, this topology structure
makes it easier to identify damaged cables.
Bus Topology (linear) Bus Topology (tree) Ring Topology
Mesh Topology Star Topology

1.2.3 Network Infrastructure Protocols

Devices in a network communicate with other devices using protocols. The type of protocol
governs the way data is transmitted based on the method used, such as the type of cable, port,
or wireless transmission mechanism.
The Open Systems Interconnection (OSI) model, which was developed by the International
Organization for Standardization (ISO), helps explain how these protocols work as well as how
networking devices communicate with each other. The OSI model segregates network functions
into seven different layers, with each layer responsible for a specific data exchange function,
as follows:
Application 7
Presentation 6
Session 5
Transport 4
Network 3
Data Link 2
Physical 1
Data flows through each layer using a process called encapsulation, which adds a header or a
footer to the data point received from the previous layer. It starts at the Application layer with a
message, which is then passed to the Presentation layer where a header or footer is added.
The data continues the encapsulation process through each layer down to the Physical layer,
which represents the actual networking device that is being used to transmit the message. At
the Physical layer, the message is transformed into electrical impulses that are then sent to the
receiving networking device. There, the decapsulation process begins, starting with the Physical
layer until it reaches the Application layer.
As the information moves through the OSI model layers from the sending network device to the
receiving network device, the header that was added by each specific layer is interpreted by the
same layer at the receiving device.

The following explains the purpose of each layer and the different protocols that operate
within them:
Application Layer (Layer 7): This layer serves as the interface between applications that a
person uses and the network protocol needed to transmit a message. It does not represent
that actual application being used. Some of the common and most well-known protocols
used at this layer include Hypertext Transfer Protocol (HTTP), File Transfer Protocol (FTP),
Simple Mail Transfer Protocol (SMTP), and Electronic Data Interchange (EDI).
Presentation Layer (Layer 6): This layer transforms data received from the Application
layer into a format that other devices using the OSI model can interpret, such as standard
formats for videos, images, and web pages. Encryption also occurs at this layer. Common
formats used are American Standard Code for Information Interchange (ASCII), Joint
Photographic Experts Group (JPEG), and Moving Picture Experts Group (MPEG).
Session Layer (Layer 5): Layer 5 allows sessions between communicating devices to be
established and maintained. Sessions allow networking devices to have dialogue with each
other. Common protocols at this layer are Remote Procedure Call (RPC), Structured Query
Language (SQL), and Network File System (NFS).
Transport Layer (Layer 4): The Transport layer supports and controls the communication
connections between devices. This involves setting the rules for how devices are referenced,
the amount of data that can be transmitted, validating the data’s integrity, and determining
whether data has been lost. Common protocols within this layer include Transmission
Control Protocol (TCP), User Datagram Protocol (UDP), Secure Sockets Layer (SSL), and
Transport Layer Security (TLS).
Network Layer (Layer 3): The Network layer adds routing and address headers or footers
to the data, such as source and destination IP addresses, so that the message reaches the
correct devices. This layer also detects errors. Common protocols include Internet Protocol
(IP), Internet Protocol Security (IPSec), Network Address Translation (NAT), and Internet
Group Management Protocol (IGMP).
Data Link Layer (Layer 2): In the Data Link layer, data packets are formatted for
transmission. This is determined by the hardware and networking technology, which is
usually Ethernet. This layer also adds Media Access Control (MAC) addresses, which are
device identifiers that act as source and destination reference numbers to route messages
to the correct device. Some of the protocols used are Integrated Services Digital Network
(ISDN), Point-to-Point Tunneling Protocol (PPTP), Layer 2 Tunneling Protocol (L2TP), and
Address Resolution Protocol (ARP).
Physical Layer (Layer 1): This layer converts the message sent from the Data Link layer into
bits so it can be transmitted to other physical devices. It also receives messages from other
physical devices and converts those back from bits to a format that can be interpreted by
the Data Link layer. Protocols used in this layer include High-Speed Serial Interface (HSSI),
Synchronous Optical Networking (SONET), V.35, and X.21.

1.2.4 Network Infrastructure Architecture

A company’s network infrastructure architecture refers to the way an organization structures
its network from a holistic design standpoint, considering factors such as geographical layout,
physical and logical layout, and network protocols used.
Networks can be wired, wireless, virtual, or on-premises; they can use a variety of hardware
and software to enable connectivity, and be spread across a wide geographical area or a more
narrow, concentrated area. Common types of network architecture designs include:
Local-Area Networks (LANs): Provides network access to a limited geographic area such as
a home or single-location office.
Wide-Area Networks (WANs): Provide access to larger geographic areas such as cities,
regions, or countries. WANs connect other networks such as LANs together to provide broad
coverage. The largest example of a WAN is the internet.
Software-defined Wide Area Networks (SD-WANs): Monitors the performance of WAN
connections and manages traffic to optimize connectivity. In a WAN, the control and
management of the network is integrated into the hardware. In a SD-WAN setup, control
and management are separated from the hardware and included in a software.
Virtual Private Networks (VPNs): These are virtual connections through a secure
channel or tunnel that provide remote and secure access to an existing network. These are
commonly referred to as RDCs, or remote desktop connections.
1.3 Software
Software consists of the applications, procedures, or programs that provide instructions for a
computer to execute. Software is controlled by a user interacting with the program, which in
turn gives instructions to the physical computer’s operating system. The term software spans a
variety of categories and can refer to programs that manage multiple applications such as an
operating system, can be a standalone program, or can be local to a component of a computer
or a peripheral device such as a printer.
1.3.1 Operating Systems

An operating system (OS) is software that orchestrates the global functioning of a group of
applications, hardware, and their performance by acting as an intermediary between these
resources to allow a user to execute specific tasks. An OS defines the parameters for managing a
system’s memory, processes, records, devices, and user interface. By optimizing these functions,
an OS balances resources and allocates them in a way that allows the system to run seamlessly
without delays or interruptions even with multiple applications running simultaneously.
1.3.2 Firmware
Software that is locally embedded in hardware instructs the hardware how to operate and
is commonly known as firmware. Firmware operates like software but exists locally on the
machine directing the function of the physical components, such as the motherboard and
microprocessor. Firmware is not updated frequently, or at all, which is very different from how
often a typical software program is updated on a frequent basis.

1.3.3 Mobile Technology

Mobile technology refers to any wireless-enabled device that is connected, or has the ability
to connect, to a private network or the internet. This technology allows the user to conduct
business and communicate in real time, which can sustain a business that might otherwise
collapse during a crisis or a temporary inability to meet in person. Mobile technology combines
hardware, such as laptops, tablets, hot spots, and mobile phones, with mobile applications and
operating systems that allow connectivity to networks. This connectivity is typically done with
wireless technology such as Wi-Fi, Bluetooth®, and 4G or 5G cellular technology.
Mobile devices can be EUDs (end-user devices) or non-EUDs. Mobile EUDs like laptops, tablets,
and smartphones provide direct interfaces with a user. Mobile non-EUDs are wireless devices
like routers, switches, firewalls, and wireless access points. These run on some form of mobile
technology, but they are not direct interfaces with a person.
An extension of mobile technology is IoT (Internet of Things) devices, which typically require
either Bluetooth or an internet connection to access a larger network. The mobile range for
connectivity is usually more limited than first-generation (traditional) mobile technology and can
be found in artificially intelligent personal assistants, smartwatches, Bluetooth earphones and
speakers, lighting, electrical equipment, thermostats, and appliances such as refrigerators and
dishwashers.
2 Cloud Computing
2.1 Cloud Computing Models

Cloud computing is a computing model that uses shared resources over the internet. Cloud
customers rent storage space, processing power, proprietary software, or a combination of the
three on remote servers from another company.
When a company acquires its own infrastructure rather than renting it, the company must
purchase enough resources to cover its peak usage so the business can accommodate high-
volume periods. During low-volume periods, this costly infrastructure is idle. The company
would also be responsible for maintenance and tech support on its hardware.
For the customers of cloud computing, the service offers infrastructure elasticity, renting only as
much as needed on a minute-to-minute basis. Processing and storage are rented in increments
of computing power used per units of time, so customers pay lower amounts during low-
volume periods and larger amounts during high-volume periods. Customers benefit because
the provider of the cloud services usually performs all maintenance and tech support on this
hardware.
Cloud computing services are offered by some companies with large computing infrastructures
to either lease excess capacity during off-peak times or use purpose-built infrastructure to
support their customers. Cloud computing gives customers the opportunity to gain efficiencies
by allowing them to rent from cloud service providers (CSPs) instead of purchasing or building
out costly solutions.
Additional efficiencies exist when a company's data is in one virtual location, especially if
company operations are in many locations. Data processing can be performed more efficiently
from that single virtual location, and IT hardware support may be reduced throughout the
company. Because cloud service providers offer distributed redundancy among many data
centers, having cloud data storage reduces the likelihood that data is lost in an attack or
a disaster.

Because of its benefits, cloud computing and the variations of its use are becoming pervasive in
modern society. There are three primary cloud computing models, in addition to a fully on-site
or on-premises solution:
On-Premises IaaS PaaS SaaS

More Control
Application Usage Application Usage Application Usage Application Usage
Application Design, Application Design, Application Design, Application Design,

Tools, and Data Tools, and Data Tools, and Data Tools, and Data
Environment Runtime Environment Runtime Environment Runtime Environment Runtime
Virtual Management Virtual Management Virtual Management Virtual Management
Firewalls & Firewalls & Firewalls & Firewalls &

Cybersecurity Cybersecurity Cybersecurity Cybersecurity
Operating Systems Operating Systems Operating Systems Operating Systems
Servers Servers Servers Servers
Storage Storage Storage Storage
Networking Networking Networking Networking
Data Center Data Center Data Center Data Center

Less Control
= Managed by organization
= Managed by third-party CSP

Enterprise Risk Management—Integrating with Strategy and Performance Framework, © 2017 Committee of Sponsoring
Organizations of the Treadway Commission (COSO). Used with permission.
IaaS (Infrastructure-as-a-Service): The CSP provides an entire virtual data center of

resources in an IaaS model, and organizations can outsource servers, storage, hardware,
networking services, and networking components to third-party providers, which is
generally billed on a per-use basis. The company is typically responsible for keeping the
environment in which it operates consistently up and running for users, as well as virtually
managing the performance of the physical infrastructure, while the CSP is responsible for
the physical management of that infrastructure.
The degree to which the organization has control over certain functions will vary across
CSPs and organizations. Some companies may only use operating systems and firewalls
but not update, patch, or maintain them, while other organizations may fully support those
functions.
PaaS (Platform-as-a-Service): The CSP provides proprietary tools or solutions remotely
that are used to fulfill a specific business purpose. In a PaaS model, the tools facilitate the
creation of programs and delivery of services, such as building an online platform to sell
merchandise, advertise products, or build other websites, all of which run on a CSP’s hosted
infrastructure. The CSP is responsible for keeping the application’s uptime at an acceptable
level by maintaining all of the back-end infrastructure required to run that application.

SaaS (Software-as-a-Service): The CSP provides a business application or software that

organizations use to perform specific functions or processes. In a SaaS model, customers
generally purchase the service through licensing. The CSP offers access to the application via
the internet and is responsible for recurring upgrades, security enhancements, and other
support functions.
A common service offered in conjunction with SaaS models are Business Processes as a Service
(BPaaS) models, in which third parties use SaaS software to deliver specific business functions
such as outsourced payroll, billing, or logistics services.
2.1.1 Cloud Computing Deployment Models

There are four common types of cloud computing deployment models, and how the cloud
environment is shared differs with each model.
Public: The cloud in this model is owned and managed by a CSP that makes the cloud
services available to people or organizations who want to use or purchase them.
Private: In this model, the cloud is created for a single organization and is managed by
the organization or a CSP. The cloud infrastructure can exist on or off the organization’s
premises.
Hybrid: The cloud in a hybrid model is composed of two or more clouds, with at least one
being a private cloud, that remain unique cloud entities but with technology in place that
facilitates the portability of data and applications between each entity.
Community: A community cloud infrastructure is shared by multiple organizations to
support a common interest, such as companies banding together for regulatory compliance,
a common mission, or collaboration with industry peers.
2.1.2 Cloud Service Providers (CSP)

A cloud service provider (CSP) is a third party that provides cloud computing services such as
application delivery, hosting, or monitoring to customers. The CSP performs all maintenance and
tech support on the hardware. CSPs often have advanced skills and experience managing cloud
infrastructure and environments, and cloud computing takes advantage of this expertise.
A CSP could be a company that uses purpose-built infrastructure to support customers or one
with a large computing infrastructure that leases excess capacity during off-peak times. CSPs
often serve multiple cloud customers at once and use common resources and technology for all
customers, which is referred to as multi-tenant.
Information about CSPs may be found in SOC 2® reports regarding compliance with regulations
or standards. This could be critical for users of SOC 2® reports who are interested in controls
implemented by the service organization to comply with HIPAA security requirements. It may
also be of interest to potential or existing CSP clients looking for compliance with standards
issued by the Cloud Security Alliance, known as the Cloud Controls Matrix, which is a framework
designed for best practices regarding cloud security, data protection, and compliance in a cloud
environment.

2.2 COSO Enterprise Risk Management—Integrating With Strategy

and Performance
The Committee of Sponsoring Organizations (COSO), created by the Treadway Commission,
has developed guidance and best practices for internal control, enterprise risk management,
governance, and fraud deterrence. COSO’s Enterprise Risk Management—Integrating With Strategy
and Performance framework categorizes methods for addressing an organization’s risk into five
components, with 20 supporting principles:
MISSION, VISION, & CORE VALUES
STRATEGY DEVELOPMENT
BUSINESS OBJECTIVE FORMULATION
IMPLEMENTATION & PERFORMANCE
Strategy & Information, Communication,

Governance & Culture Performance Review & Revision
Objective-Setting & Reporting
PROCUREMENT
1. Exercises Board Risk 6. Analyzes Business 10. Identifies Risk 15. Assesses Substantial 18. Leverages Information
Oversight Context 11. Assesses Severity of Change and Technology
2. Establishes Operating 7. Defines Risk Appetite Risk 16. Reviews Risk and 19. Communicates Risk
Structures 8. Evaluates Alternative 12. Prioritizes Risks Performance Information
3. Defines Desired Strategies 13. Implements Risk 17. Pursues Improvement 20. Reports on Risk,
Culture 9. Formulates Business Responses in Enterprise Risk Culture, and
4. Demonstrates Objectives 14. Develops Portfolio Management Performance
Commitment to Core View
Values
5. Attracts, Develops,
and Retains Capable
Individuals
1. Governance and Culture: The governance component sets the company’s tone and
reinforces the importance of having oversight of enterprise risk management. Culture is
related to the company’s target behaviors and values and involves understanding risk.
2. Strategy and Objective-Setting: This component is considered with enterprise risk
management and strategy during the strategic planning process. A company’s risk appetite
should be aligned with its strategy, and business objectives should be put into place to help
achieve that level of appetite through identifying risk, assessing it, and responding to it.
3. Performance: This component requires that organizations prioritize their risks based
on risk appetite so that business objectives are assessed, met, and reported to key
stakeholders.
4. Review and Revision: This component involves reviewing a company’s performance over
time and making revisions to functions when needed.
5. Information, Communication, and Reporting: This component recommends that a
continual process be in place that supports sharing both internal and external information
throughout the organization.
The set of 20 principles were designed to be practical and customizable so that organizations of
any industry, size, or type can implement them. They were also designed with the thought that
management and a company’s board of directors could use these as a standard for reasonable
expectations when managing risks associated with business objectives and strategy.
Material from Enterprise Risk Management—Integrating with Strategy and Performance Framework, © 2017
Committee of Sponsoring Organizations of the Treadway Commission (COSO). Used with permission.

2.3 COSO Enterprise Risk Management for Cloud Computing

COSO’s Enterprise Risk Management for Cloud Computing publication provides specific guidance to
organizations for applying the COSO framework to cloud computing. In general, an organization
must integrate the governance of cloud computing into its overall risk management strategy.
COSO provides key risk management considerations for organizations using cloud service
providers. When outsourcing to a CSP, ownership of risk remains with the organization. Proper
governance of cloud computing and CSPs may include a Cloud Computing Steering Committee
that oversees cloud computing efforts. An organization should also understand a CSP’s values
and culture due to a CSP becoming an extension of the organization.
An organization must consider how a CSP affects the organization’s risk profile, how a CSP’s risks
can impact performance, what responsibilities belong to a CSP, and how a CSP’s internal controls
address risk. If a CSP has an outage, critical systems at the organization may be down. A CSP
may provide firewall or VPN capabilities, but configuration and enforcement may be left to the
organization. Finally, organizations should continuously update and reassess ERM when there
are changes to the organization’s cloud needs or CSP.
2.3.1 Applying the COSO Framework to Establish Computing Governance

The COSO Enterprise Risk Management (ERM) framework can help organizations establish ideal
configurations for cloud options by applying eight components. This allows management to
tailor the solution based on the company’s own risk appetite.
COSO Framework Applicability to Organization’s Consideration of Cloud

Component Computing
This serves as the foundation for a company’s risk appetite,
Internal Environment helping a company understand the level at which it wants to
outsource technology functions.
Management should understand how outsourcing technology
Objective-Setting
functions will help it reach, or potentially hinder, its objectives.
Management must understand how adopting a CSP could make
Event Identification
event identification more complex, or easier.
Management should understand the risks of its cloud strategy,
Risk Assessment understanding the impact to its risk profile, inherent and residual
risk, and likelihood of the impact of all risks.
Management should determine whether its risk response will be
Risk Response to avoid a risk, reduce its likelihood, share the risk by transferring
a portion of it to another entity, or accept the risk.
The organization should understand how traditional controls—
Control Activities such as detective, preventative, automated, and manual—as well
as entity-level controls are modified in a cloud environment.
Management should understand how operating in the cloud will
Information and
affect the timeliness, availability, and dissemination of information
Communication
and communication.
Management should modify its monitoring mechanisms to
Monitoring accommodate new complexities introduced by adopting a cloud
solution.

2.3.2 Cloud Risks

There are multiple risks that should be considered when evaluating CSPs and their services:
1. The rate of competitor adoption
2. Being in the same risk ecosystem as the CSP and other tenants
3. Transparency
4. Reliability and performance
5. Lack of application portability (vendor lock-in)
6. Security and compliance
7. Cyber attacks
8. Data leakage
9. IT organizational change
10. CSP long-term viability
COSO also recognizes that risk increases when moving from a private model to a public
deployment model. Risk also increases with less control, as is shown below, when moving from
an IaaS model to a SaaS model.
SaaS Less Control, More Risk

Less Control
PaaS
More Control, Less Risk
IaaS
More Risk
Private Hybrid Public

Enterprise Risk Management for Cloud Computing Publication, © 2021 Committee of Sponsoring
Organizations of the Treadway Commission (COSO). Used with permission.

2.3.3 Cloud Evaluation and Adoption

Organizations evaluating various cloud options can choose among a public, private, or hybrid
model, which means their computing environment may be combined with other tenants.
Companies should understand the behavior and profile of those other tenants and whether
their activity could have a direct impact on IT operations. In effect, the ERM composition of two
companies sharing the same cloud will be combined to differing degrees, depending on the
model selected.
Some cloud applications can be quickly adopted by an organization with minimal investment,
whereas others require substantial time and expense to implement. Management should
evaluate this prior to committing to a cloud solution as well as determine whether they fully
understand any compliance risks that come with having a CSP assume certain functions within
an organization. When some functions are shared or supported by a cloud application, it can
remove transparency and oversight that might have otherwise existed in a company before the
cloud solution was adopted.
Illustration 1 Evaluating Cloud Providers
FinGuard Financial is considering outsourcing its clearing and settlement functions to

support real-time clearing for stock trades executed by its clients. FinGuard’s CFO presents
senior management with the following three options:
I. MisRoq Clearinghouse platform—this company houses clients with up to 50 other
companies per computing machine. Pricing is based on the relative use of the platform
with a monthly minimum. If more trades are made through FinGuard than another
institution sharing the same machine, then FinGuard pays more.
II. Cliff Clearinghouse Partners—this firm custom builds a clearinghouse platform
that does not share physical space or computing power with any other entity. This
dedicated option is the most expensive, at 5 percent of trading fees paid by investors.
It is the most secure, has the most advanced computing power on the market, and has
backup platforms at a separate location for redundancy if the primary platform fails.
III. R&M Group Clearinghouse—this organization offers shared cloud hosting with a
maximum of two other companies on the same machine and location. Pricing is on-
demand, based on the level of computing power used by FinGuard, at a fixed rate per
hour. Advanced computing power has a higher price per hour than general purpose
computing power.
Because it is a global market infrastructure operator, FinGuard decides to go with
option II. Even though option III offers competitive pricing and reduced risk through the
limited number of shared tenants, FinGuard wants a dedicated platform because it is so
widespread geographically and is willing to pay a premium to get it. Option I has too much
risk due to the fact that it is shared with so many other institutions. In the event of a stock-
trading frenzy, a trading platform crash would prevent investors from making trades, which
could magnify losses or cause them to miss out on gains.

2.3.4 Recommended Risk Responses

Given the variety of cloud computing options available to companies today, management
should adapt its programs and controls so that each risk related to cloud environments has the
appropriate response. To reduce the likelihood of unauthorized cloud activity, policies need
to be implemented. This is particularly important for data and compliance issues, making data
classification processes and policies very much a necessity.
To determine whether those safeguards are in place and working correctly, there should be
periodic assessments of the CSP’s control environment. There should also be management
oversight, designing the way in which controls are monitored. When incidents, such as a
cyberattack, do occur, an incident management plan should be in place to control and mitigate
the threat.
Risks related to vendor lock-in are common but not always evident to companies with long-
standing vendor relationships. CSP exit strategies give the organization a contingency plan,
should an abrupt switch be required.
Monitoring the regulatory environment for changes is also critical to minimize the risk of
noncompliance. Countries across the globe are rapidly implementing protective rules to
restrict the use of sensitive information outside of country borders, making it important for
companies operating in multiple nations to be alert. Additionally, if a company is publicly traded,
noncompliance disclosures may be required if CSPs are supporting critical business processes.

NOTES

2
MODULE
Enterprise and Accounting

Information Systems ISC 2
1 Enterprise Resource Planning (ERP) Systems
1.1 Overview
Enterprise resource planning (ERP) systems are cross-functional systems that support
different business functions and facilitate integration of information across departments such
as accounting, customer management, finance, human resources, inventory management,
manufacturing, marketing, and vendor management.
An ERP solution facilitates real-time communication between systems and typically operates
under a centralized database and user interface. This interface may offer multiple modules that
function independently or as an integrated system that allows data to be shared across different
departments or divisions of an organization.
An accounting information system (AIS) is more specific in nature than an ERP and offers the
particular accounting functions an organization may need. An ERP may include AIS capabilities
while being more robust than a standalone AIS and integrated with other departments.
1.2 Accounting Information Systems (AIS)

The system that accountants and financial managers interact with the most is the AIS. An AIS
collects, records, and stores accounting information, then compiles that information using
accounting rules to report both financial and nonfinancial information to decision makers in an
enterprise.
1.2.1 AIS Subsystems

An AIS typically is made up of three main subsystems (or modules):
Transaction Processing System (TPS): This subsystem converts economic events into
financial transactions (i.e., journal entries) and distributes the information to support daily
operations. A TPS typically covers three main transaction cycles: sales cycle, conversion
cycle, and expenditure cycle.
Financial Reporting System (FRS): This subsystem aggregates daily financial information
from the TPS and other sources for infrequent events such as mergers, lawsuit settlements,
or natural disasters to enable timely regulatory and financial reporting.
Management Reporting System (MRS): This subsystem provides internal financial
information to solve day-to-day business problems, such as budgeting, variance analysis, or
cost-volume-profit analysis.
© Becker Professional Education Corporation. All rights reserved. Module 2 S2–19 Enterprise and Acc
2 Enterprise and Accounting Information Systems ISC 2
1.2.2 Objectives of an AIS

The three subsystems of an AIS collectively achieve the following five objectives:
1. Record valid transactions.
2. Properly classify those transactions.
3. Record the transactions at their correct value.
4. Record the transactions in the correct accounting period.
5. Properly present the transactions and related information in the financial statements of the
organization.
1.2.3 Sequence of Events of an AIS

An AIS processes transactions in the following order:
1. Transaction data from source documents is entered into the AIS by an end user.
Alternatively, an order may be entered through the internet by a customer.
2. Original source documents, if they exist, are filed.
3. Transactions are recorded in the appropriate journal.
4. Transactions are posted to the general and subsidiary ledgers.
5. Trial balances are prepared.
6. Adjustments, accruals, and corrections are entered.
7. Financial reports are generated.
1.2.4 AIS Audit Trail

A well-designed AIS creates an audit trail for accounting transactions. The audit trail allows
a user to trace a transaction from source documents to the ledger and to vouch from the
ledger back to source documents. The ability to trace and vouch between records and source
documents is important in auditing.
An example of a basic accounting audit trail follows. Source documents are often stored as
electronic documents, thus alleviating the need to file paper documents. Sophisticated scanning
systems can turn paper documents into electronic documents before they are processed.
Input Output
Source
Financial
document Trial
Journal Ledger statements
(invoice, balance
reports
time card)
Store file
File original
source
document
S2–20 Module 2 Enterprise

© Becker Professional andCorporation.
Education AccountingAllInformation Systems
rights reserved.
ISC 2 2 Enterprise and Accounting Information Systems
Audit trails are also useful for service auditors in a SOC 2® engagement, particularly if the service
organization is an outsourced accounting firm providing bookkeeping, payroll, or other financial
services. In that case, the service auditor would need a way to track transaction origination to
the final output, such as a payroll check register report or financial statements.
1.3 Transaction Cycles

The transaction cycles are the core functions within an accounting department, such as the
revenue cycle, purchasing and disbursement cycle, and other processes that involve the
recognition and/or facilitation of transactions.
INTERNAL EXTERNAL
Pays
employees
Manages
cash and Human Resources
working and Payroll Cycles
capital
Managers /
Employees
Records Records Reports to

Production Cycles payroll managers
and Fixed Asset inventory &
Cycles fixed assets
Revenue and
Cash Collections
Submits PO & Cycles
invoices Customers
General Ledger
and Reporting Records
Supplies Cycles sales
product transactions Remits
Records payment
transactions
Record cash,
interest,
investment
Purchasing &
activity
Disbursement
Bank
Cycles
Transacts
with bank
Remits
payment Treasury
Cycles
Vendor
1.3.1 Revenue and Cash Collections Cycles

The key AIS functions of the revenue and cash collections cycle include the following:
AIS allows real-time access to the inventory subsidiary ledger to check availability upon
receiving a customer order.
AIS automatically approves or denies credit based on the customer's credit record and
payment history.
AIS concurrently records sales invoices in the database, digitally transmits inventory release
orders to the warehouse, and digitally sends packing slips to the shipping department.
AIS has a terminal for the shipping department to digitally input shipping notices upon
shipment. The input triggers the system to update the customer's credit record, reduce
inventory subsidiary ledger records, insert the shipping date in sales invoice records, update
general ledger accounts, and distribute management reports (e.g., inventory summary, sales
summary).
AIS has a terminal for the cash receipts clerk to access the cash receipt system and record
the remittance.
AIS closes the sales invoice, posts to the general ledger accounts, updates the customer's
payment record, and distributes management reports (e.g., as transaction listings,
discrepancy reports, and general ledger change reports).
1.3.2 Purchasing and Disbursement Cycles

The key AIS functions of the purchasing and disbursements cycle include the following:
AIS reads the requested purchase to verify that it is on the approved list, and then displays
a list of approved vendors with vendor contact information as an input to the competitive
bidding process or selection of vendors.
AIS digitally prepares the purchase order (PO) and delivers the PO to the vendor.
AIS has a terminal for the receiving department to enter the PO number and inputs the
quantities received. AIS concurrently updates the receiving report file, reconciles the
quantity received against open PO records, closes the PO if no exceptions are identified,
updates the inventory subsidiary ledger, and updates the general ledger accounts.
AIS has a terminal for the accounts payable clerk to enter invoices from suppliers into the
system. The system automatically links the invoices to the PO records and receiving report
records and creates a digital accounts payable voucher stored in a centralized repository.
AIS automatically approves payment of invoices and sets the payment date according to the
terms on the invoice.
AIS prints and distributes the signed checks to the mail room for mailing. The system
records payments in the check register file, closes the vendor invoice, updates the
associated general ledger accounts, and distributes transaction reports to users.
1.3.3 Human Resources and Payroll Cycles

The key AIS functions of the human resources and payroll cycle include the following:
AIS is integrated with the human resource management system (HRMS) to enable real-time
changes of employment data, such as benefits, pay rates, deductions, employment status,
new hires, terminations, etc.
AIS, in connection with operational systems, allows employees to enter timekeeping data in
real time to produce time and attendance files and the labor usage file.
AIS allocates labor costs to job costs, accumulates direct and indirect labor expenses at the
end of a work period (daily or weekly) on a batch basis, calculates payroll, updates employee
records, and produces payroll registers for accounts payable and cash disbursement
departments.
AIS creates digital journal entries, attaches the original documents to the entries, and
automatically updates the general ledger.

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Illustration 1 HR and Payroll AIS
A regional commercial construction company, BuildPros, completes between 1,500 to 2,000

projects each year, building large-scale apartment complexes, office buildings, and some
residential housing. Many of the employees have expertise that allows them to work across
projects, and turnover is also very high, which makes an integrated human resources and
payroll information system critical.
BuildPros understands this and adopts a system that streamlines onboarding due to the
high frequency of new and terminated employees. The onboarding module requires the
applicant to complete all paperwork prior to becoming an employee, taking the burden of
completing paperwork from BuildPros. This also allows real-time updates by the employees
in case they need to make changes to their W-4 for income tax withholding, elect changes
in benefits, or perform supervisory tasks.
The system also has a mobile app with geo-restricted time clocks that allows employees
to clock in remotely, but only from specific locations. As employees clock in and log their
hours for a job, the payroll system assigns the hours to a predetermined job code that
is associated with a customer list. Then before payroll is run, the payroll administrator
reviews labor allocations to enhance the accuracy that customers are billed accurately.
After payroll is complete, a general ledger export is created, which is automatically fed into
the company’s accounting information system to record payroll expense for the period.
1.3.4 Production Cycles and Fixed Asset Cycles

The key AIS functions of the production cycle include the following:
AIS receives a work order for a production run from the production planning department.
The new production order is input as a new record in the work-in-progress (WIP) subsidiary
ledger.
As labor and materials are added to the production run, documents reflecting these events,
such as material requisitions and labor tickets, are sent to the AIS. AIS automatically updates
the WIP account as production progresses.
AIS tracks standard production costs for labor, materials, and manufacturing overhead
(MOH). AIS records variances between standard production costs and actual costs.
AIS closes the WIP account when it receives the final ticket marking the production move
from WIP to finished goods inventory.
AIS prepares journal entries as changes to the WIP account are recorded and automatically
updates the general ledger.
The key AIS functions of the fixed asset cycle include the following:
AIS has a terminal for fixed asset groups to create a record of the asset subsidiary ledger
that includes each asset's useful life, salvage value, depreciation methodology, and location.
AIS automatically updates the general ledger, prepares journal entries, and creates a
depreciation schedule.
AIS automatically calculates depreciation, accumulated depreciation, and book value at
the end of the period. The system then creates a journal entry file and updates the general
ledger accounts accordingly.
When an asset is disposed of, the clerk records the disposal, prompting the system to
calculate gains or losses of the disposal, prepare journal entries, and post adjusting entries
to the general ledger.
1.3.5 Treasury Cycles

An AIS treasury cycle is integrated with the other transaction cycles. These other cycles provide
much of the capital available to the company (revenue) that is, in turn, used to pay expenses, pay
employees, and purchase fixed assets. This AIS integration allows effective cash management.
The key AIS functions of the treasury cycle include the following:
Various source documents such as deposit slips, checks, stock market data, and interest
data are used to post journal entries affecting cash balances.
The accounting department performs bank reconciliations by using bank statements to
reconcile the cash account balance at the bank with the general ledger. AIS has control
features in place to help prevent fraud.
Journal entries are posted for each change in cash, and the system automatically provides
updated general ledger information.
AIS can provide various reports to assist with cash management. These reports cover cash
receipts and other trends in cash collections and disbursements. AIS can also provide
changes in investments and estimates on interest and dividend payments. These reports
allow the accounting department to effectively predict cash flows.
1.3.6 General Ledger and Reporting Cycles

The key AIS functions of the general ledger and reporting cycle include the following:
AIS updates the general ledger as various transactions (discussed in the previous cycles)
occur and journal entries are posted.
At the end of an accounting period, AIS automatically produces a trial balance showing the
debit and credit balances in each account. The accounting department reviews the trial
balance and related worksheets to determine if any adjustments need to be made.
The accounting department posts any necessary adjusting entries such as entries for
depreciation, prepaid expenses, and unrecorded revenue.
AIS produces final financial statements after adjusted entries are made and the debit and
credit amounts in the trial balance are equal. AIS also produces reports showing variances
and performance over the accounting period.
AIS automatically closes temporary accounts so that a new accounting period can begin. AIS
carries forward balance sheet accounts into the next period.

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2 IT Systems and Process Improvement
2.1 Process Improvement Driven by IT Systems

An organization can improve the performance of its information systems by improving
business processes that provide inputs to those systems. Improving consistency and reliability
in processes results in better data. Better processes lead to fewer errors, more efficient
accounting, and enhanced reporting. Four broad areas of process improvements that can
enhance accounting information system performance are automation, shared services,
outsourcing, and offshore operations. Additionally, there are three specific forms of technology
that are gaining mass adoption in process improvement: robotic process automation (RPA),
natural language processing software, and neural networks.
2.1.1 Automation
Business process automation is a general term for the automation of business processes using
computer programs designed to perform repetitive tasks. Automation allows the company to
deploy human resources to tasks better suited to human skills.
To implement automation, an organization must first examine an existing business process
to describe the steps taken, the exchange of information, the governance of policies for each
transaction, and the knowledge needed to complete each task. The goal of this analysis is to
understand the process thoroughly enough to replace it with business process automation
facilitated by IT systems.
2.1.2 Shared Services

Shared services refers to seeking out redundant services, combining them, and then sharing
those services within a group or organization. The distinguishing feature of shared services
is that they are shared within an organization or group of affiliates and almost always involve
software that is designed to process large batches of data.
Illustration 2 Shared Services
Financial Group Inc. is a financial services company with three distinct lines of business
including accounting, tax, and consulting. Currently, each division operates as a separate
company with its own human resources, payroll, and legal departments. In order to more
effectively manage the organization and reduce costs, the new CEO implements a shared
services plan whereby all human resources, payroll, and legal department services will
be consolidated into one centralized function. The CEO thinks that this shared services
approach will eliminate redundant back-office functions and will reduce annual operating
costs by $750,000.
2.1.3 Outsourcing
Outsourcing is defined as the contracting of services to an external provider. Examples
include a payroll service or a call center that provide support or back-office services for a fee.
A contractual relationship exists between the business and its service provider. With proper
controls in place, cloud-based systems can allow external service providers to work seamlessly
with an organization.
Outsourcing can provide for efficiencies, but there are also risks associated with quality of service,
reduced productivity, and information security.
These risks include:
Quality Risk: An outsourced product or service might be defective. Suppliers might provide
substandard products or services.
Quality of Service: Poorly designed service agreements may impede the quality of service.
Productivity: Real productivity may be reduced even though service provider employees are
paid less.
Staff Turnover: Experienced and valued staff whose functions have been outsourced may leave
the organization.
Language Skills: Outsourced services may go offshore. Language barriers may reduce the
quality of service.
Security: Security of information with a third party might be compromised.
Qualifications of Outsourcers: Credentials of service providers may be flawed. Offshore
degrees may not include the same level of training as domestic degrees.
Labor Insecurity: Labor insecurity increases when jobs move to an external service provider or,
as a result of globalization, out of the country.
2.1.4 Offshore Operations

Offshore operations relate to outsourcing of services or business functions to an external party in
a different country. A computer manufacturer in the United States, for example, might have its call
center in India. The most common types of offshore outsourcing are:
Information technology provided by a managed services provider (MSP)
Business processes (call centers, accounting operations, tax compliance)
Software research and development (software development)
Knowledge processes (processes requiring advanced knowledge and specialized skill sets, such
as reading x-rays, etc.)
2.1.5 Robotic Process Automation (RPA)

Robotic process automation is a specific form of business process automation that refers to the use
of programs to perform repetitive tasks that do not require skilled human labor, such as extracting
information from a user interface (e.g., a customer complaint form or a goods order form) and
inputting that data into a form, moving files, sending payment reminders, and executing other
commands that would be considered clerical work. RPA is different from artificial intelligence in that
it focuses more on doing tasks using simple, rule-based processes rather than learning or providing
analysis.
One manifestation of RPA is in web scraping tools that scour the Web looking for instances of
specified text to collect all material surrounding it. This content may be forms entered by users or
existing web page content. General web scraping tools often collect ancillary data unintentionally,
which introduces noise into the analysis. Robotic process automation uses this as a point of
refinement to yield a more highly curated collection of data yielding a more reliable analysis. Robotic
process automation can mimic human interaction with many kinds of computer systems.

rights reserved.
Another application of RPA is the use of lidar (light detection and ranging), which is one of the
technologies being used in self-driving vehicles. This technology is combined with advanced software
to perform nearly the same function as a human. This technology will presumably be applied to
various other human job roles as it is refined, becomes cheaper, and becomes more widely available
to businesses.
Illustration 3 Robotic Process Automation in Practice
A company is interested in formulating an RPA to collect the data from various inventory
invoices, payment orders, and reconciling documents used in its logistics system (part
of the enterprise resource planning system [ERP]), because it would be more efficient to
have software collect and format this existing information than to train every employee on
using existing or new systems. Because there are a limited number of forms, the company
constructs a library of forms for reference by the RPA. Once the RPA has been trained to
recognize each form, the company directs all forms to the RPA, which scans each form,
applies the parameters set in the program, and sends the appropriate data into the ERP
application database.
2.1.6 Natural Language Processing (NLP) Software

Natural language processing involves the technology developed and used to encode, decode,
and interpret human languages so that the technology can perform tasks, interact with other
humans, or carry out commands on other technological devices. This requires the mapping of
things like pragmatics, syntax, phonetics, pitch, and tone, as well as ensuring the NLP program
determines the proper response or chain of action. This is the technology needed to build
a network embedded on household devices or other Internet of Things (IoT) devices so that
the household has a virtual assistant to turn on the television by voice command. Accounting
applications include parsing text documents or speeches made by executives to extract and
catalog any financially relevant data.
2.1.7 Neural Networks

An artificial neural network is a form of technology that is modeled after neurons that facilitate
the function of human or animal memory. The basic pieces of a neural network involve an
input layer, a hidden layer, and an output (results) layer. Within the input layer are the different
variables that feed into the hidden layer. In the hidden layer, there are a series of weights
applied based on the inputs selected, which then direct the algorithm toward a given output.
There are typically multiple layers embedded within the hidden layer acting as neurons that
guide the input through to its output (result) based on the cumulative value of all weighted
points. Weights may initially be predetermined but the intent of the neural network is to learn
from prior trends in results based on inputs. So just as a human's response changes, its reaction
is refined in the hidden layer by changes to weights, which yields a different outcome. This is the
computing architecture needed to make fuzzy logic decisions for inference engines, commonly
used in fraud detection.
2.1.8 Managing System Changes

Whether implementing automation, outsourcing, or advanced technology to improve business
processes, an organization must manage system changes methodically so that core business
functions are not disrupted. While there is a myriad of methodologies that can be used to
implement system changes, two well-known approaches are the waterfall model and the agile
method. Both of these have phases that focus on system design, testing, deployment, change
review, and maintenance.
3 Detecting Design Deficiencies in Processing Integrity
3.1 Processing Integrity

Processing integrity refers to a system’s ability to initiate and complete transactions so that they
are valid, accurate, completed timely, and authorized to meet a company’s objective. Integrity
also refers to confidentiality and privacy of the details related to transactions involving data
that identifies customers, patient health records, employees, or financial accounts. Additionally,
processing integrity is one of the five trust services criteria.
3.2 Identifying Deficiencies in Suitability or Design

The AICPA defines deficiencies in the design of a control in a SOC 2® engagement as either:
1. necessary controls that are missing; or
2. existing controls that are not designed properly.
Identifying whether a deficiency in design exists related to processing integrity can be
accomplished by applying the trust services criteria. To perform this evaluation, a service auditor
must first obtain an understanding of management’s risk assessment process, evaluate the link
between controls in the system description and relevant trust services criteria, and determine
whether the appropriate controls are in place and whether those controls were implemented.
Examples of how the trust services criteria can be used to evaluate deficiencies are as follows:
Trust Services Use For Detecting Deficiencies in Suitability and Design

Criteria
1 Security
Identify transaction processing methods that compromise confidentiality, privacy, and
availability, and that can be circumvented to allow unauthorized access.
2 Availability
Search for bottlenecks in the flow of data across the organization and identify
other processes that prevent data from being available when needed.
Processing
3 Integrity
Survey processing methods and transactions that do not complete timely or
at all, yield faulty results, or do not meet the company’s objectives.
Evaluate employees and processes that handle transactions with confidential data
4 Confidentiality to identify potential data leakage, mishandling, or other practices that expose
confidential information.
5 Privacy
Analyze methods used to collect, store, use, and dispose of personal data that
are being processed to identify the potential for data breaches or leakage.

rights reserved.
Another way to identify deficiencies is by using the AICPA’s Description Criteria for a Description
of a Service Organization’s System in a SOC 2® Report to compare with an organization’s system
design documentation. The set of benchmarks in this implementation guide serves as a strong
tool for evaluating system descriptions of service organizations and can specifically be used for
detecting deficiencies in the suitability or design of controls related to an information system’s
processing integrity.
Two items the guide recommends to review are the principle service commitment and the
principle system requirements, which are required to be disclosed by management to support
the understanding of the system, the services provided, and the design of the controls.
Understanding how and why management disclosed certain attributes of its system within these
descriptions, particularly related to processing integrity, will help assess the suitability of system
control design.
3.3 Deviations in Operations of Controls

The AICPA defines a deficiency in the operation of a control in a SOC 2® engagement as a
properly designed control that either:
1. does not operate as designed; or
2. is performed by a person who lacks authority or competence to perform the control
effectively.
Controls are suitably designed if they meet, or have the potential to meet, the trust services
criteria because the suitably designed controls provide reasonable assurance that a company’s
system requirements and service commitments were achieved.
3.3.1 Performing Tests of Controls

To test the operating effectiveness of controls based on the trust services criteria, the service
auditor should obtain proper evidence. This will include evidence of how the controls were
applied, the consistency of application, and the personnel responsible for applying them.
Changes to the service organizations should be documented and, if possible, test the controls
both before and after the change to determine whether the modified control meets service
commitments as they relate to the trust services criteria. If deficiencies are already identified,
the service auditor is not required to test the effectiveness of those controls.
The service auditor is responsible for designing and performing the tests of controls, which
may involve making inquiries, reperforming controls, observing service organization personnel
performing the controls, and reviewing documentation. This allows the service auditor to obtain
evidence of how the control was applied, the consistency with which it was applied, and the
person applying it. This also aids the auditor in ascertaining whether controls are dependent on
other controls.
Timing is a critical factor that the service auditor should consider when designing tests of
controls. Relevant factors include understanding the period in which the data will be available
and the potential for data to be overwritten if not obtained timely. Testing can be performed at
interim dates, at the end of an examination period, or after the examination period if controls in
operation do not leave evidence until after the end of the period.
The size and frequency of sampling when testing controls also must be considered. Variables
that influence this include how often a control is performed, the expectation that a control will
actually deviate, the testing period length, and the reliability of the evidence.
3.3.2 Controls That Did Not Need to Operate

Some controls, due to the nature of their operation or circumstance, either can’t operate
during the testing period or are not prudent to operate. For instance, controls that relate to
authenticating a new employee’s identity may not be able to be performed because there was
no new employee to onboard. In these instances, the service auditor does not need to modify
the opinion on operating effectiveness of controls.
3.3.3 Identifying Deviations in Operating Effectiveness of Controls

As deviations in the operating effectiveness of controls are discovered, the service auditor
should accumulate documentation of those occurrences. If a service auditor cannot obtain
reasonable assurance that system requirements or service commitments are being met, then
the deficiency should be considered material.
If the deviations are the result of fraud, the service auditor should assess the risk that the system
description does not accurately reflect the system that was designed, and the operating controls
are not operating effectively. The service auditor should also consider applicable noncompliance
with regulations, and it may be appropriate for the auditor to do the following:
Hold discussions with the appropriate parties.
Request that the appropriate party consult legal counsel, a regulator, or a qualified third
party.
Consider implications related to other aspects of the engagement.
Obtain legal advice about different courses of action that could be taken and their
consequences.
Communicate directly with regulators or appropriate third parties.
Withdraw from the engagement.
If the service auditor identifies other systems not within the scope of the audit that are affected
by a system incident, the auditor should understand the nature and cause of the incident as it
could be the result of ineffective controls of the system being audited.
If the incident is the result of a security breach, then the auditor should determine whether the
inherent risks of the system environment are different than originally assessed, or whether the
system was compromised. This reassessment of risk may require that additional procedures be
performed or new evidence obtained of additional controls that are suitably designed that do
provide reasonable assurance that service requirements and commitments were met based on
trust services criteria.
Ultimately, the service auditor decides whether the identified deviations, either individually
or combined, are material. If they are considered material, then the auditor must modify the
opinion on operating effectiveness.

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4 COSO Internal Control Framework and Blockchain
4.1 COSO Internal Control Framework for IT systems

The Committee of Sponsoring Organizations (COSO) has developed guidance and frameworks
covering the areas of internal control, risk management, and fraud deterrence. Within its five-
point Internal Control—Integrated Framework (“the framework”), there are two categories with
principles that pertain specifically to internal control over information technology.
Within the Control Activities category, principle 11 states that there should be general controls
over technology in order to achieve organizational objectives. To establish these controls,
the company must understand the dependency between general controls over technology
and the use of technology in business processes. The company must also establish controls
over relevant technology infrastructure, security management, technology, acquisition, and
maintenance processes.
Within the Information and Communication category, principle 13 states that organizations
should acquire, create, and use quality information in order to support internal controls.
This includes:
identifying the company's information needs;
capturing both external and internal sources of data;
processing relevant data into useful information; and
maintaining quality when processing that data.
Principle 14 states that effective communication of information is necessary to support internal
controls. This means communicating internal information to the proper stakeholders, including
the board of directors; providing communication lines that are separate from those directly to
management; and selecting relevant methods of communication.
Illustration 4 COSO Principles
Spinal Surgery Clinic (SSC) P.A., a large group of physicians focusing on spinal surgery,
recently had an outside firm perform an IT audit as recommended by SSC's board of
directors. The findings resulted in recommendations that followed the COSO Internal
Control—Integrated Framework principles 11, 13, and 14. As such, SSC invested in new
technology that required user identities to be verified by multiple points of validation
other than just a password in order to access patient accounts (in line with principle 11).
Additionally, SSC adopted a state-of-the-art data cleansing system in an effort to acquire
and use error‑free data to enhance patient outcomes, which aligned with principle 13.
Lastly, to address principle 14, SSC began performing regular reviews of key IT functions
and started issuing monthly reports of internal control to the board of directors.
4.1.1 Blockchain Overview

Blockchain is a control system originally designed to govern the creation and distribution of
Bitcoin. Bitcoin is a digital currency that exists only in electronic form, called a cryptocurrency.
Bitcoin must be "mined" in order to confirm transactions. Mining cryptocurrencies involves
a person or group of people performing cryptography, which is the solving of complex
mathematical equations.
Through cryptography, blocks of a fixed number of transactions are confirmed at a time. The
reward for solving (validating) the equation is both:
the receipt of bitcoin; and
the validation of a new block of transactions.
Because electronic data can be easily copied and altered, the accounting system governing
it must prevent the copying or alteration of the cryptocurrency; otherwise, the currency may
become instantly worthless through counterfeiting. Blockchain technology was developed to
prevent bitcoin from being replicated and to limit its initial creation so that there is only a finite
number of bitcoins.
The value of blockchain is its resistance to alteration, multiparty transaction validation, and
decentralized nature. Alteration is difficult because each block adds to all prior blocks, enabling
everyone to view all blocks in the chain to the beginning of the entire chain. This serves as a
form of audit trail for blockchain users and service auditors performing SOC 2® engagements:
An auditor can use the chain to verify transactions by validating cryptographic signatures,
time stamps, and tracing wallet addresses.
A service auditor could verify the security of nodes on the network and supporting
infrastructure to enhance the physical or virtual integrity of the blockchain.
y Not all data needed to validate transactions is on the blockchain, so service auditors
may need to consider the potential for off-chain data.
y Off-chain data may include personal information tied to an address, or business data
such as a supply chain using blockchain technology to document production updates.
Another key value of blockchain technology, specifically decentralized blockchains like Bitcoin,
is its ability to be partially detached from government control, although many nations regulate
both the trading of certain types of cryptocurrencies and the exchanges on which those
currencies trade. In some cases, cryptocurrencies are banned entirely, while others require
the registration of those currencies as securities and require the exchanges to meet the same
standards as stock exchanges such as the NASDAQ or the London Stock Exchange.
4.1.2 Applying COSO to Blockchain

COSO provides guidance on how the internal control framework should be leveraged to
implement controls to address the risks associated with blockchain technology. Blockchain
creates implications in each of the components of the COSO framework. With blockchain, record
keeping is completely transformed by recording transactions with minimal human intervention.
Transactions are immutable and irreversible, creating record integrity. While certain risks are
eliminated with blockchain, new risks arise.
An organization must manage the control environment where its entity is intertwined with other
entities or people participating in the blockchain. An organization will not have complete control.

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Likewise, blockchain has no centralized management overseeing its activity. That means no
particular entity can be held accountable or responsible if things go wrong. An organization
cannot simply engage a SOC auditor to assess controls. This decentralization is a unique
challenge with blockchain. Organizations must find alternative ways to gain assurance over
blockchain controls.
For financial reporting, blockchain’s attributes increase the visibility of transactions and the
availability of data:
Blockchain’s attributes allow management to support its financial records.
Blockchain’s attributes make audits of blockchain transactions easier because of automatic
audit trails.
Management can provide financial information to stakeholders faster and more effectively.
In the event of a SOC 2® engagement, a service auditor should consider the trust services criteria
(security, availability, processing integrity, confidentiality, and privacy) as it relates to each of the
COSO’s five control components.
For example, the engagement team should determine whether the processing integrity of
transactions processed on the blockchain’s ledger meets standards required in the COSO’s
control environment, such as principle 4’s requirement to demonstrate commitment to
competence.
However, it should be noted that due to the nature of most decentralized blockchains,
certain control components might not be met in the traditional sense, including component 2
concerning oversight responsibility or component 5 covering accountability. This is because
decentralization distributes accountability and oversight so that there is not one individual or
a small group that dictates policies and procedures for the entire blockchain. Service auditors
may need to adjust their perspective on how a control is met or restrict SOC 2® engagements to
organizations with a centralized blockchain.
The following table shows how the COSO’s five control components and 17 principles help
evaluate risks related to blockchain.
How COSO Helps Evaluate

Components Principles Blockchain Risks
1. Demonstrates Outlines actions for a board to make
commitment to integrity regarding a code of conduct to validate
and ethical values integrity, ethical values, and compliance.
2. Exercises oversight Recommends enhancing the board and audit
responsibility committee's understanding of blockchain
potential uses and how to effectively
manage it.
Control
Environment 3. Establishes structure, Gives recommendations on establishing
authority, and cross-disciplinary teams for implementing
responsibility blockchain, and defining responsibility and
authority for blockchain solutions.
4. Demonstrates Recommends reevaluating competencies
commitment to and continuously monitoring the blockchain
competence ecosystem for new developments in its
construct or application.
5. Enforces accountability Gives guidance on identifying who is

Control responsible and who has authority in the
Environment blockchain, including segregation of duties
(continued) and who has access to private keys to
authorize transactions.
6. Specifies suitable Advocates for the establishment of objectives
objectives so that the implementation of a blockchain
supports verifiable and reliable financial
records and reports.
7. Identifies and analyzes Proposes developing robust risk assessment
risk processes prior to implementing a blockchain
Risk Assessment solution.
8. Assesses fraud risk Recommends engaging IT and blockchain
specialists to identify areas of risk and
potential fraud schemes.
9. Identifies and analyzes Endorses using strong change-control
significant change processes when deploying or amending a
blockchain.
10. S
elects and develops Outlines general and specific control activities
control activities for critical aspects of a blockchain such as
11. S
elects and develops nodes, consensus protocols, private keys, and
general controls over smart contracts.
Control
technology
Activities
12. D
eploys control activities Lists considerations for policies and
through policies and procedures addressing internal controls, new
procedures risks, and accounting related to blockchain
applications.
13. U
ses relevant, quality Proposes the use of data analytics
information procedures to get relevant and quality data
from the blockchain to be used to support
management objectives.
14. C
ommunicates internally Recommends educating internal stakeholders
on how blockchain will be used by the
Information and
business; also endorses developing
Communication
communication methods to ensure
operational changes are communicated
appropriately.
15. Communicates Suggests engaging external auditors during
externally development of blockchain applications in a
company's processes.
16. C
onducts ongoing and/ Encourages the use of computerized
or separate evaluations continuous monitoring techniques due to the
volume of transactions being processed; also
recommends ongoing evaluations to detect
Monitoring changes or updates to technology to ensure
Activities controls exist and are still working.
17. E
valuates and Recommends identifying talent that can
communicates identify changes from a company's baseline,
deficiencies correct deficiencies, and then communicate
those deficiencies.

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When implementing the COSO’s controls to a blockchain setting, organizations should consider
the following:
Focus on preventative controls due to volume and speed of transactions being processed.
Increase the frequency of detective controls, also due to the volume of transactions.
Develop controls that use other analytic technology like artificial intelligence tools, such as
large language models (LLM), which are good at quickly identifying bugs in code.
Develop a code of conduct and establish policies that comply with KYC (Know-Your-
Customer) regulations and AML (Anti-Money Laundering) policies.
Create cross-disciplinary teams with segregation of duties in mind and with clear reporting
lines that identify all users participating in the blockchain’s creation and maintenance.
NOTES

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3
MODULE
Availability, Resiliency,
and Disaster Recovery ISC 2
1 System Availability
1.1 Availability Scope

Availability, or being able to perform business functions or meet business objectives, is critical
to a business’s success. The concept of availability has various components. It includes system
availability, which is when business data is accessible and IT systems are operating normally.
Availability also includes availability of an organization’s human capital and personnel being
ready and able to perform in normal operations.
The risk of normal operations failing in part, or as a whole, must be evaluated and mitigated
through business resiliency programs. Even minor periods of paused operations or system
downtime can cause organizations major problems, including loss of revenue, data, trust, and
customers. There are a few key considerations when planning how to maintain availability. The
following graphic depicts the integration of such key considerations:
System Availability
Strategic ability to rebound
Business Business System Crisis Disaster

Resiliency Continuity Availability Management Recovery
Controls
Consideration Ability to continue Overall response Strategic recovery
of continuous delivering products Ability to to a dire situation; after a disaster
operation or quick and services; prevent systems broader than DR
return to operation operations focused disruptions
Physical and IT Uninterrupted Redundancy Incident

Infrastructure Power Supply and Backup Response Plan
Controls
Backup power Ability to restore Specific recovery
Physical and supply in the IT operations after an event; part
virtual controls event of a power from replicated of a DR or CM plan
in place so all outage to sustain environments and
systems continue IT operations backup
to be available for
normal business
operations
© Becker Professional Education Corporation. All rights reserved. Module 3 S2–37 Availability, Res
3 Availability, Resiliency, and Disaster Recovery ISC 2
1.1.1 Business Resiliency

Business resiliency is the integration of system availability controls, disaster recovery plans,
business continuity plans, and crisis management plans into a central set of procedures to
consider whether a business can continue to operate or quickly return to operations without
irreparable harm to its people, information, or assets.
Organizations must identify what activities are necessary to the core operations of their
organization and assess existing threats to those activities. Once critical systems and processes
are identified, management can begin building a business resiliency program to determine
whether these vital functions can quickly be repaired and put back into operation given a
business crisis or disruption.
1.1.2 Disaster Recovery

A major component of a business resiliency program is disaster recovery. Disaster recovery
consists of an entity's plans for restoring and continuing its information technology function in
the event of the destruction of not only program and data files, but also computer processing
capability.
Short-term problems or outages do not normally constitute disasters. If processing cannot be
quickly reestablished at the original processing site (possibly because the original processing site
no longer exists), then disaster recovery is necessary.
The steps in a disaster recovery plan are to:
1. assess the risks;
2. identify mission-critical applications and data;
3. develop a plan for handling the mission-critical applications;
4. determine the responsibilities of the personnel involved in disaster recovery; and
5. test the disaster recovery plan.
In the event of a disaster, an organization has three main options for how to maintain IT operations
through the use of alternative processing facilities:
1. Cold Site: A cold site is an off-site location that has all the electrical connections and other
physical requirements for data processing, but it does not have the actual equipment. Cold
sites usually require one to three days to be made operational because equipment has to be
acquired. Organizations that utilize a cold-site approach normally utilize generic hardware
that can be readily (and quickly) obtained from hardware vendors. Cold sites are the least
costly form of off-site location.
2. Warm Site: A warm backup site falls somewhere between a cold site and a hot site. It is a
facility that already has hardware installed but will fall short of the processing capabilities
typically found in a hot site or at the actual business during normal operations due to
a lack of fully operational computer and office equipment. The warm backup site is the
compromise between the hot backup site and the cold backup site.
3. Hot Site: A hot site is an off-site location that is equipped to take over the company's data
processing as these locations are not only pre-wired for use but also include the necessary
hardware and office equipment to perform the functions of the organization. Backup copies
of essential data files and programs may also be maintained at the location or a nearby data
storage facility. Hot sites are more expensive than cold sites.
S2–38 Module 3 Availability,

© Becker Professional Resiliency, and
Education Corporation. Disaster
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ISC 2 3 Availability, Resiliency, and Disaster Recovery
The following matrix depicts key characteristics of each of these sites:
Connections Equipment Days to Be

Location in Place? in Place? Operational Cost
Cold Site Off-site Yes No 1–3 days Cheapest
Moderately
Warm Site Off-site Yes/No Yes/No 0–3 days
expensive
Hot Site Off-site Yes Yes Immediately Most expensive
1.1.3 Business Continuity Plans

Disaster recovery plans are focused on restoring the IT infrastructure during a disaster while
business continuity plans are focused on keeping the business operational. Business continuity
plans are more comprehensive than disaster recovery plans and contain contingency and
mitigation procedures around all business processes, including relocating facilities, human
resource tasks, and managing relationships with customers and suppliers. The overall goal
of the business continuity plan will be how to continue operations or restore operations in
the most efficient and effective manner possible with consideration given to all aspects of the
organization. Business continuity plans must consider the following:
Identify the organization's key business processes.
Identify the risks that exist in key business processes.
Determine the acceptable downtime for key business processes.
Implement mitigation and contingency plans to address risks and downtimes.
1.1.4 SOC 2® Engagement Consideration of Business Continuity Plan Testing

During the performance of a SOC 2® engagement, service auditors may verify that an
organization’s business continuity plan testing is performed on a periodic basis. The
engagement auditor’s point of focus during the engagement would be to determine whether the
organization’s business continuity plan:
was based on relevant and likely scenarios;
was focused on components that can significantly impair the company;
considered scenarios in which key personnel are lacking; and
was periodically revised based on test results.
Illustration 1 Business Continuity Plan
Health One Inc., a health insurance company serving members nationwide, reviews its
business continuity plan annually. The company’s main office is located in a region where
hurricanes threaten business operations each year. Although most of the company’s
employees work remotely, many lose internet access during natural disasters, making them
unable to work from their homes.
As part of Health One’s business continuity plan, the company relocates a core team of
employees to a safe, operational facility. The facility is secure and has internet access and
telephone services. Additionally, the company moved all critical applications and systems
to the cloud several years ago as part of its business continuity plan. By using the cloud, the
company can determine whether, in the event of a disaster, the relocated core team can
resume necessary business operations on behalf of the company.
1.1.5 Business Impact Analysis

Identifying and assessing risks is a key component in building a business resiliency program. This
assessment can be done by performing a business impact analysis (BIA). This analysis identifies
the business units, departments, and processes that are essential to the survival of an entity as
well as the organizational impact in the event of failure or disruption.
The BIA will identify how quickly essential business units and/or processes can return to full
operation following a disaster. The BIA will also identify the resources required to resume
business operations. For example, a specific department may utilize custom hardware/software,
operate in locations with challenging geographic or weather conditions, or depend on third-
party vendors.
Under a high-impact (H) category, the department:
y cannot operate without this resource;
y may experience a high recovery cost; or
y may fail to meet the organization's objectives or maintain its reputation.
Under a moderate- or medium-impact (M) category, the department:
y could partially function temporarily for a period of days or a week;
y may experience some cost of recovery; or
y may fail to meet the organization's objectives or maintain its reputation.
Under a low-impact (L) category, the department:
y could operate for an extended period of time; or
y may notice an effect on achieving the organization's objectives or maintaining its
reputation.

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The BIA is made up of the following steps:

1. Establish the BIA Approach: Agreement on the necessary approach to performing the BIA
is critical and must first be clearly outlined by the organization. During this phase, executives
and relevant managers define the impact types and criteria, as well as the time frames to
observe and the methodology to use.
2. Identify Critical Resources: Management must clearly define critical functions in the
organization and delineate which IT resources are required to perform them. This will
highlight organizational processes that are the most vulnerable to disruption. This step
involves a combination of interviews with key personnel and documentation review.
3. Define Disruption Impacts: In this phase, the organization must identify and evaluate
the impact of a service disruption by understanding its effects over time and the resources
negatively affected or required to deal with the disruption. Risks can include quantitative or
qualitative effects and may be natural or human-inflicted threats.
4. Estimate Losses: This step involves the management team outlining an exhaustive list of
potential risks and events that could occur that would disrupt operations and assigning each
of those threats a probability of likelihood. This probability is referred to as the annualized
rate of occurrence. Potential losses can be quantified by using the ARO and the variables in
the illustration below to calculate the annualized loss expectancy.
5. Establish Recovery Priorities: Management must prioritize recovery strategies to decide
which tasks personnel should address first. This will vary depending on the maximum
outage time that a particular resource can handle, with those resources that have a lower
tolerance threshold targeted first. For example, resources that can only be down four hours
before a significant impact to the business occurs will be addressed before a resource that
can be down 24 hours.
6. Create the BIA Report: These reports may be completed at the department level, business
unit level, product level, or by any other appropriate means of segregating a business to
evaluate risk, as long as all known risks have been addressed. These individual reports can
then be combined to form a company-wide BIA.
7. Implement BIA Recommendations: This phase involves senior management evaluating
the comprehensive BIA report, determining which risks pose the greatest threat, and
implementing preventative or corrective actions to remediate those threats.
Illustration 2 BIA Estimation of Losses
BuildTech Inc., a manufacturing company specializing in construction equipment, is

conducting its business impact analysis and is estimating its losses from potential risks
and events that may disrupt operations. The organization determined that a key risk area
would be the partial flooding of the southern portion of BuildTech’s $5 million data center,
which processes the analytic workflows pertaining to the company’s proprietary software
embedded in its construction equipment, which makes up 40 percent of the data center,
due to excessive rain or severe weather systems. Based on research and prior knowledge,
it was determined that flooding would occur every 20 years. BuildTech Inc. wishes to
annualize the cost of this risk.
To gain an understanding of the annualized loss expectancy of a flood, BuildTech Inc. would
utilize the following formulas:
1. Annualized Rate of Occurrence (ARO) is the expected frequency of occurrences in
a year.
y Research and historical data of the area show that the occurrence would happen
roughly once every 20 years.
y ARO is calculated by taking the number of occurrences and dividing it by the
relevant year(s):
1 / 20 = 0.05
2. Exposure Factor (EF) is the damage in terms of dollars, expressed as a percentage of
an asset’s value.
y Based on assessments of the areas of the data center subject to damage from
flooding, it was determined that 40 percent of the data center is at risk of damage
if a flood was to occur.
y The EF for this flooding risk to the data center would be 40 percent.
3. Single Loss Expectancy (SLE) is the cost of an individual loss.
y SLE is calculated as the exposure factor multiplied by value of the asset.
y BuildTech’s SLE would be the EF (40%) multiplied by the data center’s value
($5,000,000) = $2,000,000.
4. Annualized Loss Expectancy (ALE) is the cost of a specific loss in a given year.
y ALE is calculated by taking the single loss expectancy and multiplying it by the
annualized rate of occurrence.
y BuildTech’s ALE would be the SLE ($2,000,000) multiplied by the ARO (0.05) =
$100,000.

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1.1.6 Crisis Management Plans

In terms of business operations, a crisis is an unexpected, large-scale incident that can cause
major negative effects on an organization and its stakeholders. Crisis management policies are
vital, as a crisis presents stressful situations that involve important decisions that must be made
quickly. These decisions can be difficult if an organization does not have clearly defined roles,
responsibilities, and procedures. The goals of a crisis management plan should be to lessen
the impact of the crisis, protect people, protect organizational reputation, and return to normal
operations as soon as possible.
Crisis management policies should address the following:
Risk assessment of what potential crises the organization could face and how to properly
respond.
Procedures for implementation include the steps management and employees must
perform to put the plan into operation.
The crisis response command center is where the directives originate during a crisis. This
may be a physical or virtual location.
Crisis management roles and responsibilities must be set so the organization understands
who oversees all final decisions and the roles and responsibilities of each individual.
Internal and external communication lines must be established so parties can communicate
during a crisis.
Employees must be properly trained on the crisis management policies and procedures so
they understand all necessary courses of action during a crisis.
Pass Key
Business resiliency is the overall integration of procedures implemented to keep operations

running smoothly, while disaster recovery, business continuity, and crisis management
plans are different potential components of a business resiliency program. Disaster
recovery focuses on IT functions; business continuity focuses on non-IT, operational, and
personnel functions; and crisis management focuses on large-scale incidents considered
a crisis.
1.2 System Availability Risks

Because technology is critical to the operations of most modern businesses, system availability
may be the largest risk an organization faces. There are many risks that can occur and cause a
loss of data or business operations. Those risks and accompanying threats include the following:
Failure of IT Infrastructure: Availability of systems may directly be affected by failures in
hardware, software, and network applications. These failures can result from:
y Use of outdated infrastructure
y Lack of system maintenance
y System infected with malware
y Physical damage occurring to systems from:
— Natural disasters such as fires, floods, tornadoes, hurricanes, and earthquakes
— Political threats such as terrorist attacks and war
— Accidental or malicious damage from individuals
y Cyberattacks that purposely overload and cause damage to the systems, such as the
use of a denial-of-service attack
Insufficient Capacity and Resources: System availability may be slowed down or disrupted
if an organization’s IT infrastructure is unable to meet the processing or storage needs of
current operational demands. This concept also applies to not having appropriate resources
in the form of staff to operate and maintain the IT infrastructure.
Lack of Business Resiliency: Organizations must have a comprehensive business resiliency
program to recover from system disruptions. If a business resiliency program is insufficient
or nonexistent, organizations may lose critical, confidential, or private data; recover slowly
from a disruption; or potentially never recover.
Specific IT processes exist to mitigate against these risks and provide access to data and IT
systems in the event of a threat.
1.2.1 Mirroring
Data backups, for example, help avoid complete data loss. Mirroring, a process that applies to
data storage and backup, entails copying a database onto a different machine for the purpose of
data redundancy in the event the primary database fails.
1.2.2 Replication
Replication involves copying and transferring data between different databases located in
different sites, such as a geographically different data center or the cloud. Replication allows
operations to resume quickly using data in the secondary site after a system failure.

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1.2.3 Secondary Internet Sources

If an organization experiences an internet outage without a power failure, secondary
internet connections can be used to sustain normal business operations. Having two internet
connections at critical locations helps mitigate this issue. Another mitigation technique would be
internet provided via cellular connection using devices such as smartphone hot spots or stand-
alone wireless hot spots; hot spots can be used temporarily to replace primary internet sources
if only one main connection exists. Alternatively, wireless hot spot adapters can be attached to
existing networking infrastructure and source internet from a cell tower to power the existing
switches and cables.
1.2.4 Metrics for System Availability

Organizations use specific metrics when assessing system availability and risks. When
companies use third-party service organizations to manage IT operations, the service
organization generally must adhere to an agreed service time (AST) and a minimal amount of
downtime (DT) specified in a service level agreement (SLA). The agreed service time refers to
the amount of time that services are operational, expressed in hours or days. Downtime refers
to the amount of time a system or application is not functional. These terms are often used to
calculate a system’s overall availability, to determine whether a service organization is meeting
performance standards outlined in an SLA.
Other key metrics used for measuring system availability include the following:
Maximum Tolerable Downtime (MTD): The amount of time a business can tolerate an
outage without causing long-term significant damage. Typically, managed service providers
have a contractual amount of downtime that cannot be surpassed within a given period of
time, usually monthly.
Recovery Point Objective (RPO): The maximum threshold for data lost, dollars lost,
or inoperability as measured by some metric (such as production in terms of units).
Applications or processes that are less critical may have a higher RPO.
Recovery Time Objective (RTO): The maximum amount of time it should take to restore
business operations to a target state following a system failure. For example, a company
may say that it must take no longer than 12 hours to restore IT operations.
Mean Time to Repair (MTTR): Average length of time it takes to repair a damaged or
inoperable device. This is similar to RTO, but MTTR is the average taken over a period of
time instead of a target or goal.
Recovery Time Actual (RTA): The actual time it takes to restore business operations to its
target state after a system failure.
Recovery Point Actual (RPA): The actual time it takes to recover to a pre-event state, or to
a target state of operability.
2 System Availability Controls
System availability controls include activities to prevent system disruptions and loss of
information as well as procedures to continue operations or provide quick recovery from
an incident. Crisis management, disaster recovery, and business continuity plans are all
components of system availability controls. In addition to these plans, system availability
controls include the following.
2.1 Physical Controls

A major threat to system availability is damage caused to physical hardware components. As a
result, controls must be put in place to deter damage to the IT infrastructure, including:
Physical access controls (i.e., door locks, security guards, cameras, etc.)
Fire alarms and sprinklers
Facility design to protect against flooding and overheating, such as raised floors and
air‑conditioning systems
2.2 IT Infrastructure Controls

Controls around the IT infrastructure, including hardware, software, and network components,
can provide mitigation of malicious attacks and other actions that can compromise systems.
These controls include:
Continuously using anti-malware software and patch management to fix vulnerabilities
Periodic reviews of IT infrastructure components to ensure they are not outdated
Network security controls
Access and authorization logical controls
2.3 Uninterrupted Power Supply

An uninterrupted power supply (UPS) is a device that maintains a continuous supply of electrical
power to connected equipment. A UPS, also called battery backup, is used to prevent a system
from shutting down improperly during an outage. A UPS can prevent data loss and can protect
the integrity of a backup while it is being performed. When a power failure occurs, the UPS
switches to its own power source instantaneously so that there is no interruption in power to
the system. A UPS is not a backup standby generator; the battery will run out eventually.

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2.4 Redundancy
Organizations may choose to have redundant hardware, software, and storage as a normal part
of their operations. This allows them to easily switch from a failed unit, such as a malfunctioning
router or switch, to another unit already in operation. Having redundant IT assets can also apply
to data storage and backup. Redundant arrays of independent drives (RAID) allow organizations
to record data on multiple disk drives at one time for the purpose of data redundancy in the
event one disk drive fails.
2.5 System Backup

When planning a business resiliency program or evaluating system availability risks,
organizations must decide what types of backups to perform to recover lost data.
Full: Exact copy of the entire database. Full backups are time-consuming, so most
organizations only do full backups weekly and supplement them with daily partial backups.
Recovering from an incident using a full backup is generally the least time-consuming
recovery process compared to other backups due to the fact that there is only one copy
of all systems and data that needs to be restored, rather than a full backup plus partial
backups. While time-consuming to create, full backups are the least time-consuming
to restore.
Incremental: Involves copying only the data items that have changed since the last backup.
This produces a set of incremental backup files, each containing the results of one day's
transactions. Restoration involves first loading the last full backup and then installing each
subsequent incremental backup in the proper sequence. Recovery is generally the slowest
of the three because a full backup copy must be restored as well as each incremental
backup. However, initial creation of the backup file for each incremental load is fast. So,
companies must decide if they prefer a faster time to create a backup and slower time to
recovery, or a slower time to create a backup and faster time to recovery.
Differential: Copies all changes made since the last full backup. Thus, each new differential
backup file contains the cumulative effects of all activity since the last full backup.
Consequently, except for the first day following a full backup, daily differential backups take
longer than incremental backups. Restoration is simpler, however, because the last full
backup needs to be supplemented with only the most recent differential backup, instead of
a set of daily incremental backup files. Recovery using a differential backup is slower than
a full backup but faster than an incremental one because only two copies are needed for
restoration—the most recent full backup and the single differential backup.
INCREMENTAL BACKUP
First Full Backup First Incremental Second Incremental Third Incremental Second Full Backup
Backup Backup Backup
DIFFERENTIAL BACKUP
First Full Backup First Differential Second Differential Third Differential Second Full Backup
Backup Backup Backup
FULL BACKUP
First Full Backup Second Full Backup Third Full Backup Fourth Full Backup Fifth Full Backup
= Data Getting Backed Up
= Data Not Getting Backed Up

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Illustration 3 System Backups
The IT director at a university manages the organization’s system backups to help avoid
complete data loss. The university has a significant amount of data requiring backup, so
the IT director, with management approval, decided to implement full backups twice a
month. These backups take several hours to complete. On a daily basis, the IT department
performs incremental backups. In the event of a system failure, the university will have
access to all data through both its full backup files and incremental files.
2.6 Detecting Deficiencies in Control Design

One of the SOC 2® trust services criteria is availability, which covers controls regarding an
organization’s system operation and performance. If an organization’s service commitments or
business objectives necessitate system availability, this trust service criteria should be included
in a SOC 2® audit.
The specific criteria for availability include infrastructure capacity and monitoring, backups and
recovery infrastructure, and testing recovery plans. To detect deficiencies in availability controls,
SOC 2® auditors should consider the following:
Infrastructure Capacity and Monitoring: Observe an organization’s monitoring tool
showing capacity metrics being monitored (e.g., CPU utilization and disk I/O). If proper
monitoring is not in place, an organization risks maxing out infrastructure capacity. If proper
recovery infrastructure is not in place, an organization risks significant downtime and data
loss in the event of a system failure.
Recovery Plans: Request and review an organization’s disaster recovery and business
continuity plans and request evidence showing when the plans were last tested and the
results. If recovery plans are not in place or not properly tested, a disaster could occur,
and the organization would not have a clear procedure to follow to recover efficiently and
effectively.
NOTES

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4
MODULE
Change Management ISC 2
1 Change Management Overview
1.1 Defining Change Management

Change management is a term used to describe the policies, procedures, and resources
employed to govern change in an organization. These changes may be initiated from within the
organization or imposed from sources outside the organization, but they will usually have an
impact on IT infrastructure such as internal hardware, software applications, and governance no
matter the source.
The scope of change to be managed can range from something as routine as implementing
a new software update to an initiative more complex and as infrequent as overhauling
an organization's core switching architecture. Regardless of the scope or size of a change
management project, potential risks need to be mitigated to minimize disruption to core
business functions and operations.
1.2 The Change Management Process

A robust change management process is a key component for successfully ensuring that an
organization can keep up with changing application and hardware needs without losing the
ability to operate or achieve its strategic objectives. The following steps can help a company
chart its path from change inception to implementation:
1. Identify and define the need for system changes.
2. Design a high-level plan including goals to be achieved because of the system change.
3. Obtain approval from management for the change.
4. Develop an appropriate budget and timeline.
5. Assign personnel responsible for managing the system change.
6. Identify and address potential risks that could occur during the change or post
implementation.
7. Provide an implementation road map.
8. Procure necessary resources and train the appropriate personnel.
9. Test the system change.
10. Execute the implementation plan.
11. Review and monitor change implementation and test as needed to verify effective
implementation.

4 Change Management ISC 2
1.3 Types of Environments

Changes should be implemented in segregated environments within an organization so that
normal business operations are not disrupted. The different forms of computing environments
include the following:
Development: In a development environment, software programmers write code to create
application prototypes. There is typically a source code editing tool which is used to create
and modify code syntax, automation tools that have preconfigured code, and a debugging
tool to help fix errors.
Testing: In a test environment, developers test and debug code to identify errors that
need to be corrected. This may be considered the same as the development environment,
but some organizations may keep it intentionally separate so that the focus is solely on
debugging errors in an application that is mostly complete.
Staging: In a staging environment, organizations can test programs that are in their
final phases of development in a production-like environment. This is intended to test
functionality, compatibility, security, and performance prior to deployment.
Production: This is the environment in which an application is deployed and made available
to end users.
Disaster Recovery: Organizations set up a disaster recovery environment to ensure that
applications can be restored quickly, save critical data and systems, notify management, and
recover in the event of an outage or attack.
2 Change Management Risks
A key component of change management is to identify the potential risks that could occur
as a result of the change. These risks are present in all steps of change from acquisition to
implementation and can affect existing systems, processes, and employees. When assessing
change management risks in a SOC 2® engagement, service auditors should refer to the AICPA’s
trust services criterion CC8.1. This criterion recommends service organizations have policies and
practices in place that properly authorize, design, develop or purchase, configure, document,
test, approve, and implement changes to the company’s infrastructure, data, and applications to
meet corporate objectives.
2.1 Selection and Acquisition Risks

Selecting and acquiring new IT resources is a fundamental area in which risks exist in the change
management process. Examples include:
Lack of Expertise: When selecting and acquiring software, there is a risk that the
purchasing agent does not have the expertise or organizational perspective to purchase
software that meets the needs of an organization.
Lack of a Formal Selection and Acquisition Process: There is a risk that an organization
either does not have or does not follow a formal selection and acquisition process as
it pertains to software. This could result in overspending, inappropriate related party
transactions or kickbacks, or software that does not align with the IT governance strategy.
S2–52 Module 4 Change

© Becker Professional Education Corporation. All Management
rights reserved.
ISC 2 4 Change Management
Software/Hardware Vulnerability and Incompatibility: When selecting and acquiring

software and hardware packages, there is the risk that proper safeguards and security
features that are needed to adequately protect an organization from unauthorized use do
not exist. There is also the risk that newly acquired hardware and software are incompatible
with each other or with existing resources that will remain in production.
To help combat selection and acquisition risks, the AICPA’s trust services criterion CC5.1 can
be applied, which recommends that companies select and develop controls that help mitigate
risks to meet business objectives. The AICPA also provides the following illustration in its SOC 2®
guidance to help provide context to the ways in which this control can be met, from both the
service organization’s perspective and the service auditor’s:
Service Organization’s Perspective: Perform annual risk assessments to determine
whether identified risks and the controls linked to those risks are adequate. If new controls
are needed due to new processes, the organization can use the proper change management
process to implement them.
Service Auditor’s Perspective: Obtain and inspect the annual risk assessment performed
by the service organization to determine that new controls were implemented to address
risks not sufficiently addressed by existing controls. The service auditor should inspect
a sample of the system change requests to determine whether the proper change
management process was used.
2.2 Integration Risks

Once the software has been selected and acquired, it must be integrated into existing systems
and processes. This may prove to be one of the most difficult risks to manage, because there
are many nuances that are further complicated by employee perceptions and attitudes toward
accepting change. Examples of integration risks include:
User Resistance: When change occurs (especially technology-related changes), there is
often resistance to adoption of the change by employees. As a result, there is a risk that
employees do not adapt to the change, ignore training, and ultimately do not follow through
with change appropriately.
Lack of Management Support: If management does not provide both resources and
adequate support, this could magnify existing employee resistance.
Lack of Stakeholder Support: The stakeholders involved in the change may range from
employees to suppliers to customers, any of which may have an adverse reaction or
disposition toward change.
Resource Concerns: Frequently, change can be resource-intensive from both financial and
labor perspectives. As a result, appropriate resources may not be made available for the
change, which may lead to ineffective implementation.
Business Disruption: When making major changes to IT infrastructure, there is the
potential for brief or even prolonged information system failures. This could cause
significant disruptions to core functions and could have long-term negative consequences
for the organization.
Lack of System Integration: Due to the ever-changing technological landscape,
organizations may operate many different systems, some of which may be legacy systems
(original or older software programs) that do not effectively adapt or integrate with more
modern systems.

2.3 Outsourcing Risks

When planning a significant IT change or system upgrade, some organizations choose to
outsource the change management process. This may be pursued as a cost-saving approach or
to leverage the expertise of an external agency. Along with the benefits of outsourcing change
management come risks. These risks include:
Lack of Organizational Knowledge: Outsourcing the change management process
could leave the organization vulnerable, because it must rely on the third party to fully
comprehend the organization’s business model and needs so the third party can integrate
that change into the organization without causing disruption.
Uncertainty of the Third Party’s Knowledge and Management: When outsourcing
change management or any IT function, there is a risk that the external party has ineffective
or weak management, inexperienced or underqualified staff, and a lack of technology
expertise. These risks can cause the outsourcing of IT to fail.
Lack of Security: Outsourcing IT functions can lead to transmission of sensitive and
confidential data. As a result, there is a risk that an external organization does not
have sufficient or effective safeguards to make sure that client, customer, employee, or
operational information is kept secure.
3 Change Management Controls
3.1 Change Management and New System Controls

Once all risks in the change management process have been identified, controls are designed
to minimize the possibility that the inherent risks will cause business disruptions or negatively
impact IT systems. Change management controls include the following:
Policies and Procedures: Clear change management guidelines are needed to outline how
the change management process should be executed, from selection to integration and
maintenance.
Emergency Change Policies: Separate contingency policies and procedures provide
direction for emergency change situations that allow for an expedited process that still
maintains an audit trail and appropriate controls. Emergency changes arise when a crisis
or time-sensitive threat requires a quick response, such as an operating system patch that
exposes a company to severe security threats.
Standardized Change Requests: Standardizing change requests by using consistent forms
and request protocols helps complete all required changes in a timely fashion.
Impact Assessment: Analysis documenting the effect a change will have on the
organization’s business activities as well as any potential disruptions will help prepare an
organization for successful change implementation.
Authorization: Requiring designated levels of authorization for changes, including material
modifications to the initial change plan, is necessary to protect against unauthorized
modification to a project’s scope.

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Separation of Duties: Properly separating job roles will help protect assets or information
from being utilized improperly. This would include, for example, distinguishing team
members who develop and design specific components from employees responsible for
placing those components into production.
Conversion Controls: When migrating from an existing system or process to the new ones,
conversion controls help minimize data conversion errors related to the impacted IT assets
and resources.
Reversion Access: Some changes may cause unexpected complications; therefore, it is
important to have the ability to revert to the prior system or process that existed before
the change.
This can be accomplished through parallel implementation in which the organization
maintains two environments at the initial onset of the change, one with the change
implemented (development environment) and one without the change implemented
(production environment).
Pre-implementation Testing: Before moving the change into production, testing will help
determine if the change is functioning properly and there are no irregularities.
Post-implementation Testing: After the change is moved into production, reconciling
transactions processed in the new environment against the same transactions that were
processed in the previous environment will validate whether the change was implemented
properly.
Ongoing Monitoring: Continuous periodic reviews after implementation will promote long-
term success. This may commence at shorter intervals (weekly) but can move to greater
intervals (monthly/quarterly/annually) as the change proves successful over time.
3.1.1 Evaluating the Impact of System Changes on Internal Controls

Trust services criteria for SOC 2® engagements require service organizations to identify and
assess the potential impact that changes could have on a system of internal control. To
accomplish that, organizations should perform an annual risk assessment process that evaluates
the following:
The economic, regulatory, and physical environment in which the company operates.
The business environment, industry, competition, and consumer dynamics.
The effect of how new lines of business, modified lines of business, expanding through
acquisition, or downsizing through divesting can affect internal control.
Management’s attitude toward internal controls.
Changes in the technology environment.
Partnerships with vendors and other businesses.
Service auditors performing SOC 2® engagements should also consider the trust services criteria
when testing controls. This may involve inspecting management’s annual risk assessment to
enhance the likelihood that management identified the need to implement new controls to
mitigate risks that were not sufficiently addressed. The auditor should sample system change
requests to verify that management followed the change management process for new controls
that were identified.

3.2 Documenting System Controls

Documentation can be a form of change management control in that it provides a log of
changes made to a system or process. Good documentation practices can help organizations
track and manage changes in a way that is efficient, effective, and compliant with relevant
regulations and policies.
Documenting system changes allows organizations to better understand how a system functions
and evolves over time, which can be useful for a variety of reasons such as:
troubleshooting;
staff training and education; and
improving system performance.
3.2.1 Baseline Configuration

Documenting changes to a system should start with a baseline configuration, which is
establishing a starting point for reconfigurations so that changes are deployed in a consistent
and secure environment. Baselines can be used as a benchmark to compare current progress
or performance of a system. This is useful when searching for patterns or trends, as it allows IT
teams to better understand the root cause of issues and evaluate the effectiveness of changes
implemented.
The use of checklists is often employed when launching from a baseline. The starting point is the
baseline, and then items on the checklist are marked with time stamps as they are completed.
This provides a linear path so managers can trace preceding steps to understand the changes
implemented.
Creating baseline images is also commonly used. This involves creating an image with a
graphical depiction of a system, which outlines important devices, personnel, and their
interconnectivity. As changes are made to the system and the image is updated, managers can
compare the two for an understanding of the changes.
Baseline configuration metrics used may include system uptime, resource utilization, and
failover time. If system uptime, or the amount of time a system is available for use, decreases
after the implementation, then management would know that the system updates were
detrimental. Similarly, if resource utilization increased so that more computing resources were
required or if failover time increased, which resulted in a delay of backup resources coming
online in a system outage, then the system update may also be considered unsuccessful.
3.2.2 System Component Inventory

A system component inventory is a list of items that comprise a system including hardware,
software, peripherals, and other IT assets. The inventory should include the purpose of
the component, its location, the current status, and whether it is functioning properly. This
information can be used to track the following:
Components that are nearing end of life
Repairs and maintenance that have been made
Component owners
Upgrades and replacements that need to be made
Guidance related to troubleshooting
Specs such as model types and serial numbers

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3.3 Testing and Implementing Change Control Policies

Depending on which change management controls an organization implements, there are
different procedures for testing the controls to enhance the likelihood that they are operating
as intended. The procedures will vary based on the types of applications, infrastructure
components, or system configurations to which the control is being applied. Procedures for
testing change management controls for IT resources include multiple components.
3.3.1 Acceptance Criteria

When evaluating change control policies, management should establish acceptance criteria that
are measurable and specific so that change can be objectively evaluated. Adequately structured
acceptance criteria help enhance the likelihood that changes to systems or processes are clear
and concise, properly tested prior to implementation, adequately documented, approved by
stakeholders, evaluated so that the impact is understood, and reviewed and monitored after
implementation.
Acceptance criteria metrics may be either qualitative or quantitative. Examples include
the following:
Performance: Quantitatively, this may be measured using metrics such as a newly
configured system’s uptime, downtime, or speed in terms of seconds or minutes. If assessed
qualitatively, this could simply be a rating by a testing panel of perceived performance.
Functionality: This metric would be qualitative and assess whether an application or
infrastructure component performs a target function and how efficient or practical it is to
use the system in its intended environment.
Scalability: The ease of the system’s ability to scale up or down would be quantitatively
measured by using such metrics as the maximum number of transactions that can be
processed, users that can be logged on, or customers that a system can handle.
Compliance: This may be measured by an objective qualitative assessment that renders a
yes or no verdict of compliance. Either an application or infrastructure component complies,
or it does not. This would typically be evaluated by an expert in a particular regulation or
standard who would compare aspects of the system to the applicable standard.
3.3.2 Logging
Analyzing logs is also a critical part of testing and implementing change control policies. Logging
is the process of recording events into logs or databases so that an organization can track
activities that occur on a system. By capturing communications and changes, companies can
determine whether change control policies are being followed and investigate known violations
of policy. Frequently used log types include the following:
Application Logs: These logs record application data such as when an employee accesses
or views a table or executes a certain function, or when an error occurs that causes the
program to stop functioning.
Change Logs: This type of log tracks changes that were requested, approved, and
implemented and may be a part of a disaster recovery program. Having a snapshot of these
changes will allow IT administrators to restore a system back to a given point in time prior to
a change.

Event Logs: This broad category of logs records various events that occur on a system
including directory logs, DNS (domain name system) server logs, endpoint logs, security
event logs, and basic system logs.
y Directory logs provide data on events involving Active Directory (AD), which is related
to authenticating users, governing privileges for users and groups, and the devices that
access AD.
y DNS server logs contain information on source and destination IP addresses, query and
response details, time stamps, and errors.
y Endpoint logs record events at the device level such as what devices connect to a
laptop, the files or programs installed on that device, and the networks to which it
connects.
y Security event logs track access to system resources such as shared folders, printers,
and files.
y System logs record events like when a system is started, rebooted, or updated.
Firewall Logs: These logs record all traffic that flows through a firewall such as packet
information containing ports used, IP addresses, protocol used, action taken by the firewall,
the reason for the action, and the time and date the packet was transmitted.
Network Logs: Also referred to as perimeter logs, these provide intelligence from devices
that guard a network’s perimeter such as virtual private networks, firewalls, and intrusion
detection systems. By monitoring this activity, organizations can detect attacks, identify
misconfigured devices, and find other potentially threatening behavior.
Proxy Logs: Proxy servers can control internet access and enhance performance for users.
The logs for proxy servers show details such as which sites a user visits, the time, and how
long the user viewed certain pages.
Illustration 1 Proxy Log Data
The following proxy log shows that a user, John Doe, visited cnn.com at 4:35 p.m. on
October 11, 2026, and stayed on that page for approximately two minutes before visiting
the business news section. John’s IP address is also given, as is shown below.
10/11/2026 4:35:55 PM User-JDoe 192.178.10.10 GET https://cnn.com/
10/11/2026 4:37:32 PM User-JDoe 192.178.10.10 GET https://www.cnn.com/business
3.3.3 Test Results

System administrators should evaluate the results of testing the design and implementation of
change control policies. Such evaluations include the following:
Review written change management policies, confirm policies are kept up to date, and
determine whether the proper acceptance criteria are documented in those policies.
Review documentation for implemented changes and request evidence showing that the
company’s change management policy was followed when implementing the changes.

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Confirm that all necessary authorizations were obtained throughout the project.
Review the change requests made and determine whether the requests were made using a
company’s standardized form.
Request evidence showing which employees or teams performed which duties during the
project to determine whether there was proper separation of duties.
Execute testing of change controls and evaluate the results of those tests.
Perform monitoring activities to review results of all testing performed throughout the
project and post-implementation and confirm that all necessary changes or updates were
made.
3.3.4 Monitoring
Monitoring in the context of testing and implementing change control policies provides
accountability, the ability to troubleshoot, and tools for identifying and solving problems.
Regarding accountability, employees are held responsible for their actions through
authenticating a unique user ID, audit trails, and other methods of surveillance. These are
monitored and reviewed for any violation of policy or breach, with unacceptable occurrences
resulting in disciplinary action or termination.
Monitoring techniques, such as reviewing audit trails and performing log analyses, help
administrators evaluate system events so they can identify, diagnose, and troubleshoot
problems. Log analysis is a form of monitoring that involves analyzing logs to search for
anomalies, patterns, trends, or unauthorized behavior. One difficulty in performing log analysis
is that the volume of data an analyst must sort through is immense. This makes automated tools
critical for this type of analysis.
3.3.5 Testing Using Continuous Adoption

Companies often use continuous software development practices such as continuous
integration and continuous deployment, which are designed to streamline the testing process.
With continuous integration, developers regularly merge changes to their code in a central
repository in which they automate building and testing code. This approach of integrating code
more frequently helps identify bugs faster, enhances application quality, and shortens the time
needed to release software updates.
In continuous deployment, software is automatically created, tested, and then deployed to
a production environment. This minimizes the cycle time for writing code and releasing new
software versions while still maintaining some form of testing so application and system
operations will not be interrupted.
However, continuous software development methods do create some risk in that not all code is
proven, and bugs will occasionally be released to a live environment. Implementing a continuous
mentality can be challenging for coding that is complex or has a high level of interdependencies
between applications.
The cultural shift within an organization from a “build-test-deploy” environment to a continuous
one may be difficult. More work is required up front to determine whether sufficient
standardized testing processes are in place, rather than applying customized testing as products
are developed.

4 Managing Change in Systems
Two of the most common IT change management methodologies are the waterfall model and
the Agile model. While both of these models have historically been used to manage software
development and other technical IT projects, their principles are flexible enough to be applied
more generally to modern change management practices across different organizational
functions. This means the waterfall and Agile methodologies can be implemented in disciplines
such as finance or logistics to optimize managing change. Since the primary difference between
the models is flexibility, some cross-disciplinary change management projects may gravitate
toward one or the other.
4.1 The Waterfall Model

The waterfall model is characterized by different
2 Ana
teams of employees performing separate tasks
Plan
1
in sequence, with each team beginning work
from the pre-written authoritative agreement of
the preceding team and then ending work when
7 Maintain
ly
the business requirements for the team have
ze
been met. The project then passes to the next
3
team. Examples of challenges associated with the
waterfall model include:
Design
Waterfall Model
It requires a great deal of time to complete.
ploy
The benefits of the new system are not

realized until completion.
De
4D
6
There is no customer input and change can be ev
difficult to manage. 5 elo
p
Test
Some employees may be idle before beginning
or after completing their step in the process.
4.2 The Agile Method

The Agile framework was created to address issues with the waterfall model. Agile offers a more
flexible approach to change management and is characterized by cross-functional teams, each
dedicated to particular functions or improvements of a system drawn from a prioritized list of
the customer's remaining needs for the system.
Unlike the waterfall model where teams work linearly, the agile model is characterized by
different teams working on different phases or tasks simultaneously. Teams work with shorter
deadlines to encourage efficiency, which makes communication critical. The Agile model also
allows changes of direction throughout the project, accounting for stakeholder feedback
through consistent communication and any changes in the technology landscape that can occur
over the course of an extensive project. The final outcome of the project can evolve throughout
the project’s life cycle.

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The Agile process can be characterized using the following steps:
Dev
elo
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ng nce
pt and
design Im
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nt
Co en
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an
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Agile Software
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The Agile principles are as follows:

1. Satisfy the customer with early and continuous delivery of the highest-priority features.
2. Welcome change; a change request is an opportunity to be closer to customer needs.
3. Deliver working software frequently; working software is the primary measure of progress.
4. Complete only the work requested by the customer.
5. Conduct short, frequent, and regular meetings to maintain focus and make adjustments.
Illustration 2 Implementing Agile in Software Development
Refraction Realty (RR) contracted with a software development company to develop

an online client portal. The portal will allow RR’s clients to interact with agents, review
documents, and schedule closing appointments. When planning the portal project, RR and
the developers discussed which project management model would serve them best. RR
had a clear vision for the portal and wanted to be heavily involved in the project. The team
ultimately decided to apply the Agile model. Throughout the project, the software group
worked quickly and simultaneously on multiple modules of the portal, giving RR time to
review and test modules as they were completed. Upon each review, RR provided feedback
on functionality and user interface. These reviews helped RR realize they wanted two
additional modules.
The developers applied the feedback and completed the new modules. Because of RR’s
involvement, the teams minimized major changes at the very end of the project. Once RR
was pleased with the portal in developer mode, RR launched the portal to its clients.

5 Patch Management
Patch management is the systematic process of identifying specific vulnerabilities or software

bugs in operating systems or applications and addressing them with patches, or fixes, between
releases. Patch management promotes system security and enhances the likelihood that
systems are running smoothly. An effective patch management process includes:
Evaluating New Patch Releases: As vendors discover new vulnerabilities, they release
patches so that organizations can implement fixes. IT managers must evaluate those
patches, determine how they will impact their company, and then devise plans to implement
them.
Using a Vulnerability Tool: This helps organizations track security controls and identify
weaknesses on their own so that management can identify patches needed, as opposed to
waiting until a vendor or external parties discover a vulnerability.
Testing Patches in a Test Environment: Implementing patches in a nonproduction
environment is critical, if possible, so that they do not negatively impact system
performance. Not all companies have the manpower or technical knowhow to test patches,
so this may only be performed by larger companies in an attempt to prevent company-wide
outages.
Approving and Deploying Patches: After patches have been successfully reviewed and
tested by IT administrators, the updates are deployed to the appropriate system during a
scheduled downtime to minimize disruptions.
Verifying Patches Deployed: Verification of successful patching should be performed after
testing and deployment, which should then be followed by monitoring so that any system
issues can be identified and resolved after deployment.
Many organizations have regular schedules for announcing patches for their clients, such as a
particular day each month or year. This allows companies time to anticipate and prepare for
updates, but it also may be exploited by bad actors. For example, a fraudster may plan an attack
that launches the same day a patch is announced because he or she knows that it will be days or
weeks before that patch is disseminated and implemented by all organizations.
For service organizations subject to SOC 2® audits, the AICPA recommends maintaining a
documented patch management process to meet its trust services criteria regarding properly
authorizing and implementing changes to meet company objectives. For service auditors testing
related controls in SOC 2® engagements, they should inspect the service organization’s policies
and procedures to determine whether they include rules on patch management and change
management.
6 System Conversion Methods
Organizations have various options when converting their computer systems, such as software,
hardware, and data, from one information system to another. The choice will vary for each
company depending on its own unique needs, with smaller companies more likely to select a
more aggressive approach such as the direct changeover method, and larger companies more
likely to take a more cautious path, choosing a parallel or phased approach.

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The different conversion methods are as follows:

Direct: This conversion method involves the organization ceasing the use of the old system
and starting the new one immediately. The risk with the direct changeover method is that if
the new system does not work, business operations could be severely hindered or cease to
function altogether depending on what the system is supporting (such as an online retailer
that relies solely on sales from its platform).
Parallel: The new system is implemented while the old system is still in use for an extended
period of time with this conversion method. The downside with this approach is that it
requires a significant amount of effort from personnel because they must operate two
systems simultaneously.
Pilot: In this method, an organization performs a conversion on a small scale within a test
environment while continuing to use the older system. It allows for validation and testing
before rolling it out to the entire organization so that adjustments can be made prior to full
implementation.
Phased: Also referred to as gradual or modular conversion, this transition plan gradually
adds volume to the new system while still operating the old system. This approach is useful
for businesses with distributed locations as it allows them to implement one site at a time.
Hybrid: These are custom combinations of the above approaches, tailored to the unique
needs of an organization.
CONVERSION
METHOD TIME
DIRECT OLD SYSTEM NEW SYSTEM
NEW SYSTEM
PARALLEL
OLD SYSTEM
(Gradual)
OLD SYSTEM NEW SYSTEM
PHASED
(Modular)
OLD SYSTEM NEW SYSTEM
OLD SYSTEM
PILOT PILOT
NEW SYSTEM

7 Change Management Testing Strategies
Every system within an organization should be subject to ongoing change management testing
to determine whether newly installed systems and updates to existing systems do not lead to
functional issues or security vulnerabilities. This testing should be subject to review and have
mechanisms in place to reverse change, should it be necessary.
7.1 Purpose of Testing

Testing software accomplishes the following:
Testing determines whether the software is operating as expected.
Testing discovers errors, defects, missing components, and gaps in the software.
Testing verifies that the end product meets the business and user requirements.
7.2 Software Testing Process

The software testing process for change management generally follows these steps:
1. Establish a testing plan including roles, responsibilities, and a timeline.
2. Identify and prioritize the key areas of the software to test.
3. Determine which type of test to run and specify the test objectives.
4. Execute the tests.
5. Log the results and identify defects.
6. Report the findings and fix the defects in a timely manner.
7.3 Change Review

A formal change advisory board (CAB) is recommended to be in place so that organizations can
adequately plan for change and respond to unwanted change outcomes. A CAB can approve
changes, document changes, notify users of upcoming or past changes, and deploy resources
for testing and responding to change.
CABs should consider whether proper controls are in place so that there are separate
environments for testing, staging, and production. For instance, developers should not have
access to a production environment and application operators should not have access to a
development environment.
Automatic notifications should also be set up so that changes to code are immediately sent
to the appropriate personnel, removing the need to rely on a human for such changes. Code
repository tools can be established so that potential changes can be aggregated, reviewed,
approved by the CAB or appropriate staff, and then implemented.

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Illustration 3 Change Advisory Board
A large electronic health care billing software provider, Lasso Co., develops, sells, and
supports applications that allow health care companies to bill insurance payors directly
using electronic data interchange (EDI). Health care companies perform services, document
those services in the electronic health record (EHR) system, and then submit those claims
for reimbursement.
Lasso has a separate development environment of its software with a replica of customer
data for its largest clients. This allows Lasso to troubleshoot issues with data that
mirrors its clients’ data so that solutions are quick and client specific. After hiring a new
developer, Lasso temporarily turns off the control that prevents test data from actually
being submitted to insurance companies for payment. As a result, actual claims that were
already sent by the client were unintentionally resubmitted for payment by the new Lasso
developer using the mirrored test claims. Many claims were paid twice, which required the
client to spend hours identifying duplicate claims and it triggered an audit by several of its
payors. Most importantly, this change was not caught by Lasso. Rather, it was identified by
the client after an extended period of time.
If a CAB was established, controls would have been in place so that this would not have
been possible, or at the least a CAB would have alerted Lasso managers of the change. A
CAB would have also alerted users of the change immediately so that productivity could be
saved and then efforts could begin to restore the organization to a pre-event state.
7.4 Rollback
Upon discovery of unwanted changes, an organization’s CAB or IT team should notify users prior
to reversing or rolling back those changes to prevent loss of productivity. Rollbacks require a
complete inventory of system configurations for applications and operating systems so that
systems can be restored to a state that existed prior to the change.
There should also be post-implementation reviews to determine whether a change or rollback
was correctly installed or uninstalled. Depending on the extent of the implementation, this can
either be done through testing each change on all devices or applications, or through validation
sampling in which only a small subset is tested.
7.5 Types of Testing Performed

There are various types of system tests that can be performed to evaluate systems in
development to determine whether they are working as intended. The following are examples of
some of the most common tests:
Unit Testing: This refers to the process of examining the smallest increment, or unit, of an
application. Unit testing can be broken down by function so that developers evaluate units
of code that perform specific tasks as the application is being developed. By focusing on a
single unit, software developers do not have to consider broader system issues like how one
unit may interact with another.

Integration Testing: Also referred to as thread testing or string testing, this assessment is
usually performed after unit testing to enhance the likelihood that different components or
modules within an application will work cohesively once all units are integrated. Integration
testing also helps plan for future system maintenance and updates, allowing managers
the opportunity to identify weaknesses or security vulnerabilities that may require future
patching.
System Testing: This verifies that all combined modules of a completed application work
as designed in totality. System testing focuses on the overall functionality of the program
and may be evaluated by a quality assurance team to discover any material defects prior to
releasing the final product.
Acceptance Testing: In this quality assurance phase, developers assess an application to
determine whether it meets end-user requirements. Acceptance testing may involve beta
testing in which a sample of the target customers tries the application, or it could involve
end-user testing in which employees test the unfinished product.

rights reserved.
Introduction to Data
5
MODULE
Collection and the

Data Life Cycle ISC 2
Data is an essential element for decision making, auditing, and analysis. Data is constantly being
created through transactional systems, artificial intelligence, the Internet of Things, and even
manually. It is critical for companies to understand what data they have access to and how to
use it responsibly to make business decisions. The data life cycle aids in that process.
1 Data Life Cycle
The data life cycle describes the sequential steps all business data must go through from
creation, through its use, storage, and final disposal. This process can be summarized in
eight steps:
1. Definition
2. Capture
3. Preparation
4. Synthesis
5. Analytics and usage
6. Publication
7. Archival
8. Purging
Analytics
Definition Capture Preparation Synthesis Publication Archival Purging
and Usage
1.1 Definition
The first step in the data life cycle is defining what data a business needs and where to capture
or retrieve such data. Determining what data a business needs and where such data would be
retrieved from helps enhance the likelihood that selected data is relevant to the goals of data
collection for the business.
1.2 Capture/Creation
Following the definition stage of the data life cycle, the next step is to obtain the data, either by
creating data internally or capturing data from where it has been created externally.
Internal data is a type of digital asset created by the company manually (e.g., keying
in a sales order), automatically (e.g., system logs, electronic data interchange, etc.), or
semiautomatically (e.g., an employee-reviewed sales order record created through optical
character recognition of a customer’s purchase-order PDF, etc.).
When data is obtained from an external source, there is added complexity such as integrity,
safety, and copyrights. Companies may need to sign contracts regarding usage and privacy
to obtain external data, and/or there may be a cost associated with obtaining external data.

Introduction to Data Coll
5 Introduction to Data Collection and the Data Life Cycle ISC 2
1.3 Preparation
Once the data has been obtained, there are two steps in the life cycle that must be completed
before the data is ready for analysis or use: preparation and synthesis. The purpose of the
preparation step is to determine whether the data is complete, clean, current, encrypted, and
user-friendly.
Enhancing Completeness and Integrity of Data: Any time data is moved from one
location to another (whether that’s from an internal database to a different internal
database or obtaining external data), it is possible that some of the required data could
have been lost during the capture process.
y It is critical to determine whether the data is complete and that the integrity of the data
remains (that none of the data have been manipulated, tampered with, or duplicated
during the extraction).
y The following four steps should be completed to validate captured data:
1. Compare the number of records that you intended to capture to the number of
records in the source database to check for potential missing rows of data.
2. Compare descriptive statistics for numeric fields if you are privy to checksums from
the original data source. Comparing those statistics helps to check for potential
missing data or incorrectly formatted fields.
3. Validate that field formats (e.g., string/text, date, time, double/numbers) are
consistent with the source to ensure that the formatting transferred appropriately.
4. Compare character limits for the attributes in the source file to the new file to
ensure data was not lost due to mismatched character limits.
Data Integration: When data is sourced externally (e.g., foreign exchange rates), it is critical
to design the data architecture to ensure that the data pipeline is integrated with the target
location/database and ensure any ongoing updates of the external source are timely and
accurately loaded in the target location/database.
Cleaning Data: After validating the completeness and integrity of captured data, the data
need to be assessed for quality in preparation for analysis. The following five steps should
be completed to clean captured data:
1. Remove unnecessary headings or subtotals that would otherwise obstruct data
synthesis or analysis.
2. Clean leading zeroes and nonprintable characters to ensure consistency across data
values.
3. Format negative numbers to ensure consistency across numerical values.
4. Identify and correct inconsistencies across data in general. These inconsistencies will
need to be replaced with a common value before analysis if the analysis will require
grouping data based on that attribute.
— For example, if there is a state field, California could be formatted as “CA,” “Cal,” “Ca.,”
and so on.
5. Address inconsistent data types (e.g., datetime, doubles, string, integer, etc.).
Data Encryption: The sensitivity of data and the consideration of integrity would generally
require encryptions both in data transit and data storage.
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Professional Education Collection and the Data
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ISC 2 5 Introduction to Data Collection and the Data Life Cycle
1.4 Synthesis
The synthesis step is a bridge between preparation and usage—once you have determined how
you intend to use the captured data, you can create calculated fields to prepare that data for
quicker usage and analysis. While synthesis is not always a necessary stage, if there is data that
can be synthesized, this is the step in which such field creation would occur.
An example of data that can be synthesized would include the creation of a calculation for net
sales based on existing gross sales and sales returns, allowances, and discounts fields.
1.5 Analytics and Usage

Once the data has been prepared for use through capture, preparation, and synthesis, the data
is ready for practical use in the organization to create reports and inform decisions. The stage of
analytics and usage lasts for as long as the data is useful to analysts in the company.
The stage of analytics and usage focuses on the data being useful to the internal company—not
being shared with external users or stakeholders. If the data will be shared externally, that is
addressed in the next step of the data life cycle, publication.
1.6 Publication
After data is prepared for internal use, the data may also be shared with external users.
Examples of sharing data externally are sending monthly statements to clients, publishing
financial statements, and sending quotes to customers. When data is shared externally, the data
is considered published and the internal company no longer has sole control of how that data
will be used, further shared, archived, or purged. For those reasons, it is critical for companies to
take care regarding what data they share with external users.
1.7 Archival
Following the decline in need of specific data sets (e.g., financial data past the relevant analytical
period set by the company or data sets not accessed/utilized for an extended period of time),
data sets are moved from active systems to passive systems for archiving to free up storage
resources for the active systems, enhance active system performance, and reduce security risks.
Optimally, archived data will be tested for accuracy and completeness prior to removal from
active systems.
1.8 Purging
The end of the data life cycle occurs when the data is completely removed (purged) from the
company’s storage systems (archived and otherwise). It is critical to ensure that the data has
truly reached the end of its use and there is no requirement (legal or otherwise) to maintain the
archived data, and once it is time to purge the data, it is critical to ensure the data is completely
purged.

Introduction to Data Coll
5 Introduction to Data Collection and the Data Life Cycle ISC 2
2 Types of Data Collection
Creating or capturing data is the first step in the data life cycle, and data can be collected
through a variety of methods. Three such methods are:
Extract, transform, and load (ETL)
Active data collection
Passive data collection
2.1 Extract, Transform, and Load (ETL)

When data already exists, whether that data is internal or external, the data must be extracted
from its original source, transformed into useful information, and loaded into the tool you
choose to use for analysis. The steps of ETL are similar to the steps discussed in the data
life cycle section (capture, preparation, and synthesis), but ETL is a more specific method for
collecting existing data in order to answer a specific data analysis question.
2.2 Active Data Collection

On the other hand, when you need to collect new data from your employees, customers, users,
etc., you need to actively collect that data. When you directly ask your users for data, you are
participating in active data collection. This can occur from survey or interview results as well as
forms gathering personal information such as users’ emails, phone numbers, or addresses.
2.3 Passive Data Collection

As our employees, customers, users, etc. become increasingly connected to each other and
to the companies they interact with through the Internet of Things and artificial intelligence,
it is possible for companies to gather information without direct permission from their users
through tracking web usage via cookies or gathering time stamps of when users interact with
your website or online store.
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6
MODULE
Data Storage and

Database Design ISC 2
1 Storage Processing and Repositories
Data storage is a type of technology specifically designed for retention of information and help
with accessibility for authorized users to perform business activities effectively and efficiently.
Common types of data storage include the following:
Operational Data Store (ODS): An ODS is a repository of transactional data from multiple
sources and is often an interim area between a data source and data warehouses.
y Captured transactional data could be related to operational activities such as customer
orders, sales, or vendor payments. It could also be system-related, measuring available
storage, system latency, or the number of records processed by a given system.
y ODS data sets are smaller and are frequently overwritten as transactions are modified,
processed, and reported.
Data Warehouse: Data warehouses are very large data repositories that are centralized
and used for reporting and analysis rather than for transactional purposes.
y A data warehouse pulls data either directly from enterprise systems with transactional
data or from an ODS.
y This data is then combined into a single repository that can be used for reporting, to
create data marts, or for a variety of other purposes.
Data Mart: A data mart is much like a data warehouse but is more focused on a specific
purpose such as marketing or logistics and is often a subset of a data warehouse.
y Different departments within a company may need tailored data marts to operate more
effectively, so they select highly relevant data points from a data warehouse to create
their own data mart.
Data Lake: A data lake is a repository similar to a data warehouse, but it contains both
structured and unstructured data, with data mostly being in its natural or raw format.
y A data lake is different from data warehouses because it does not have a predefined
data structure or schema. Alternatively, the data stored in the data lake is not indexed
or prepped and can be access by a user in its original form.
y This contrasts with a data warehouse, which has a predefined schema that is in place to
enable quick processing and analysis.
© Becker Professional Education Corporation. All rights reserved. Module 6 S2–71 Data
6 Data Storage and Database Design ISC 2
1.1 On-Premises Storage vs. Cloud-based Storage

Traditionally, all data that a company created or captured has been stored in physical drives or
servers in the company's data centers. These on-site data repositories (ODS, data warehouse,
data mart, and data lake) are referred to as "on-premises storage." However, with improving
cloud computing technology and the exponential growth in data volume, maintaining the
repository infrastructure on-premises becomes costly and cumbersome.
Cloud technologies allow data to be securely stored in (or migrated to) the cloud.
Cloud-based storage is highly scalable, allowing companies to store as much or as little data
as they need and consume the data with agility.
Extract Data Transform and Load Data Analyze Data
Data Lake
End Users
Data Source
1000110001010100000101010100000111000111000010
10001100010101000001010101000001110001110000
10001100010101000001010101000001110001110000 Marketing Data Mart
10001100010101000001010101000001110001110000
10001100010101000001010101000001110001110000
Cleansing and Normalization ODS Warehouse
Purchasing Data Mart
Sales Data Mart
2 Relational Database Design
2.1 Relational Databases

Within an organization, data can be stored in a variety of ways; however, one of the most
efficient and effective methods is to store data in a relational database.
Repositories such as data warehouses and operational data stores are often designed and built
according to a relational database design. Relational databases are the most common method
for storing structured data because of the benefits the data model provides.
Storing data in a normalized, relational database helps to reasonably assure that data are
complete, not redundant, and that business rules and internal controls are enforced; it also
aids communication and integration across business processes. This differs from less complex
methods of storage such as “flat files," which are files that contain plain text with no structural
interrelationships within that file (such as an Excel or CSV file).
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ISC 2 6 Data Storage and Database Design
The benefits associated with relational databases are detailed here:

Completeness: Relational databases assist with the goal that all data required for a
business process are included in the data set.
No Redundancy: Storing redundant data is to be avoided for several reasons:
y it takes up unnecessary resources (which can be expensive);
y it takes up unnecessary processing to run reports to check whether there are not
multiple versions of the truth; and
y it increases the risk of data-entry errors.
It should be noted that normalized relational databases require there to be one version of the
truth and for each element of data to be stored in only one place.
Business Rules Enforcement: Relational databases can be designed and used to aid in the
placement and enforcement of internal controls and business rules.
Communication and Integration of Business Processes: Relational databases should be
designed to support business processes across the organization, which results in improved
communication across functional areas and more integrated business processes.
Relational databases store data across a series of related tables. Each table contains columns
(attributes) and rows (records) that are made of data. Each column in a table must be both
unique and relevant to the purpose of the table. There are three types of columns:
primary keys;
foreign keys; and
descriptive attributes.
Each column must be designated a specific data type. These data elements are described in the
sections below.
2.1.1 Tables
The existence of more than one table in a relational database is the first differentiator between
flat files and relational databases; relational databases are made up of at least two tables that
are related. Tables are organizational structures that establish columns and rows to store
specific types of data records. Tables in relational databases are also referred to as entities,
particularly while the database is being designed.
Each table represents an object in the database; for instance, a database that contains data
relevant to a sales process would contain a table dedicated to the customers, the employees,
the sales orders, and the inventory. The customers table would store the data relevant to each
customer in the company's customer list, along with their descriptive information such as their
names, addresses, and phone numbers.
2.1.2 Attributes
Columns in relational database tables are also referred to as attributes. Attributes describe the
characteristics or properties desired to be known about each entity. For example, an attribute
(column) in the customers table may be "Last Name."
Attributes in a table must be unique to that table and relevant to the purpose of the table. There
are three types of columns: primary keys, foreign keys, and descriptive attributes.
2.1.3 Records
Rows in relational database tables are also referred to as records. Each record contains
information about one entity within the table. For example, a record in the customers table
would provide certain information about a single customer.
2.1.4 Fields
A field is space created at the intersection of a column and row in a table in which data is
entered. The information placed inside the field is a "data value."
2.1.5 Data Types

Each attribute (column) in a table has a designated data type. Data types specify how the data
is stored and indicate how the data in a given attribute can be analyzed. Examples of data types
are numerical, text, or date/time. Attributes that have meaningful numerical value, such as cost
or quantity, should be classified as numerical data types to ensure that the data in those fields
can function in mathematical equations such as sums or averages.
2.1.6 Database Keys

As mentioned above, attributes are either primary keys, foreign keys, or descriptive attributes.
While each attribute in a table must be uniquely named, each row is not inherently uniquely
named without a database key. Database keys help to uniquely identify each record in a table
(and thus, uniquely identify each field at a cross section of attribute and record) and facilitate the
relationships between related tables.
Primary Key: A primary key attribute is required in every table. The primary key is typically
made up of one column. The purpose of the primary key is to help solidify that each row in
the table is unique, so it is often referred as a "unique identifier."
y The primary key is rarely truly descriptive; instead, a collection of letters or simply
sequential numbers are often used.
y Students may already be familiar with a unique identifier—a student ID at the university
is the way student information is stored as a unique record in the university's data
model.
y Other examples of unique identifiers may include online order numbers, invoice
numbers, account numbers, social security numbers, and driver's license numbers.
Composite Primary Key: Sometimes a table does not have one single attribute that can
uniquely identify each record in a table, so more than one attribute can combine to uniquely
identify each record in the table. When more than one attribute is necessary to function as a
unique identifier, that is referred to as a composite primary key.
Foreign Key: Foreign keys are attributes in one table that are also primary keys in another
table. For example, "Customer ID" may be the primary key in the customers table; however,
it is a foreign key in the sales orders table.
y The same customer ID may appear multiple times in the sales orders table because a
single customer can place more than one order.
y The link between a primary key in one table and a foreign key in another table is what
creates a relationship between tables. In other words, foreign keys exist to implement
relationships between tables. Whenever two tables are related, one of those tables
must contain a foreign key to create the relationship.

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Customers
Sales Orders
Customer ID
Sales Order ID
Customer First Name
Sales Order Date
Customer Last Name
Customer ID
Customer Street Address
Employee ID
Customer State
SKU
Customer ZIP
Products Quantity_Sold
Customer Phone
SKU
Product Description Customer DOB
Sales Price
Cost
Employees
Employee ID
Department ID
Employee First Name
Department
Department ID Employee Last Name
Department Description Employee Street Address
Employee State
Employee ZIP
= PK
Employee Phone
= FK Employee DOB
2.2 Data Dictionary

Once processes come together to be supported in one database, the amount of data can be
massive. Understanding the processes and the basics of how data are stored is critical, but even
with a sound foundation, it would be nearly impossible for an individual to remember where
each piece of data is stored, or what each piece of data represents.
Creating and using a data dictionary is paramount in helping database administrators maintain
databases and analysts identify the data they need to use.
Data dictionaries are a type of metadata—data about data.
Data dictionaries provide and summarize information about the data in a database to make
it easier to work with the data and understand how it can be used to inform decisions and
build meaningful reports.
Depending on the structure of how data is stored, a data dictionary can be as simple as detailing
the attribute names and a description of each attribute. The description helps solidify that the
data in each attribute are used and analyzed in the appropriate way—it's always important to
remember that technology will do exactly what it is told to do, so the user must be intentional!
For example: If a user runs analysis on an attribute thinking it means one thing when it
actually means another, the user could make some material mistakes and inaccurate
decisions even when the user is working with data validated for completeness and integrity.
It is critical to get to know the data through database schemas and data dictionaries
thoroughly before attempting to perform any data analysis or reporting.
When working with data stored in a relational database, more attributes are available to keep
track of in the data dictionary, such as whether the attribute is a database key (primary or
foreign), whether the field is required, the data type, if there is a default value (and if so, what
the default value is), the field size, and any notes necessary to further understand each field.
2.3 Database Redundancy

Normalization is a database design technique that reduces data redundancy and eliminates
undesirable characteristics like insertion, update, and deletion anomalies. Normalization rules
divide larger tables into smaller tables and link them using relationships. The purpose is to
eliminate redundant (repetitive) data and reasonably assure data is stored logically.
2.3.1 Normalization
First Normal Form (1NF): The first step to normalizing data is to determine whether the
data conforms to the first normal form, which will make sorting and filtering data easier.
First normal form has two criteria:
1. Each cell (field) in a table must contain only one piece of information. In other words,
only one value may be in a column.
2. Each record in every table must be uniquely identified. This can be accomplished with
a primary key (PK), which can be either single-valued or multivalued. Recall that a
multivalued primary key is a composite primary key.
Second Normal Form (2NF): Once a table is in 1NF, the next normalization step is to
conform the data to 2NF, which requires all non-key attributes in a table to depend on the
entire primary key. 2NF is particularly meaningful for tables that have composite primary
keys. If a table has a composite primary key, every non-key attribute needs to describe each
component of the PK, not just one piece of it.
y For example: in a Sales_Order_Detail table that has a composite primary key of SO_ID
and Inventory_ID, every additional (non-key) attribute must depend on both the sales
order and the inventory item.
y An attribute such as Quantity_Ordered would pass the 2NF test. However, an attribute
such as Inventory_Name would not pass the 2NF test, because Inventory_Name only
describes Inventory_ID—it is unnecessary to understand anything about the SO_ID to
gather what the Inventory_Name is based on Inventory_ID.
Third Normal Form (3NF): Finally, once a table is in both 1NF and 2NF, the next
normalization step is to ascertain that each column in a table describes only the PK. This is
subtly different from 2NF, which requires every attribute to depend on the entire PK. In this
instance, 3NF wants to establish that none of the non-key attributes depend on other non-
key attributes (also known as transitive attributes).
y For example: a SalesOrder table that has a primary key of SO_ID and a foreign key
of EmployeeID is permissible—the EmployeeID fields indicate which employee was
responsible for each sale.
y If the Sales Order table also had an attribute labeled EmployeeName, that would violate
3NF, because EmployeeName depends on the foreign key of EmployeeID, but not on
the primary key of SO_ID.
y Attributes that violate 3NF are referred to as transitively dependent columns, which
means that the attribute depends on not just the PK but on another non-key attribute,
as well.

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A common way to describe normalization is to take the quote from A Few Good Men, "the
truth, the whole truth, and nothing but the truth," and adjust it to describe tables in a relational
database and the attributes within a given table—"the key, the whole key, and nothing but
the key."
The first part of that phrase—"the key"—refers to having a primary key in the first place,
which is established by 1NF.
The second part of the phrase, "the whole key" refers to the necessity of every attribute
relying on the entire composite primary key (2NF).
The third part of the phrase, "nothing but the key," refers to the necessity for every attribute
to rely only on the primary key, not any other non-key (transitive) attributes.
Pass Key
Remember, the forms are progressive, meaning that to qualify for 3NF, a table must first
satisfy the rules for 2NF, and the 2NF form must adhere to those for 1NF.
3 Database Models and Schemas
Relational databases must be designed with normalization in mind, and databases are supported
by data models and database schemas. Data models are conceptual representations of the data
structures in an information system and are not restricted to relational databases only.
A database schema is a set of instructions to tell the database engine how to organize data to be
in compliance with the data models. It defines the actual structure of the database, including the
tables, columns, and relationships between the data entities. A database schema specifies how
the data will be stored and ultimately accessed in the database.
While a data model and a database schema may be related, they are not the same thing. A data
model is a high-level design of the data structures in an information system, while a database
schema is the actual implementation and execution of that design in a specific relational
database.
3.1 Data Models

Data models describe the high-level design of data structures in an information system. There
are different aspects to data models, including conceptual, logical, and physical. These models
are created in stages. They start with conceptual (least complex), moving through logical and
into physical (the most complex). These models are appropriate for different audiences.
The vast amount of detail provided in the physical data model is not necessary for someone
only seeking a high or abstract level of understanding of the system. However, a database
administrator needing to fine-tune performance issues would require the details of the physical
data model. The physical data model will contain many of the items that are included in the data
dictionary, such as attribute names and their data types.
3.1.1 Conceptual
A conceptual data model is a high-level, big-picture representation of the data structures in an
information system. It defines the main entities and relationships of the data, without going into
the details of the attributes or the physical implementation of the database. A conceptual data
model is used to understand the overall structure and meaning of the data in an information
system, and it is useful for communicating the design of a data model to stakeholders.
It is possible for conceptual data models to have additional detail, up to and including attribute
values, but conceptual data models are typically kept to a minimal level of detail. The simplest
version of what a conceptual data model could be is showcased in the below graph. This model
contains five entities. The sales orders entity is related to four tables—customers, employees,
and products—and the products table has one additional relationship to the department entity.
This model provides a high-level overview of how five entities may be stored in a relational
database to support a sales process.
A conceptual data model is an excellent place for discussion to begin with stakeholders and
potential system users to determine that what needs to be stored in the system has been
captured without providing overwhelming or unnecessary details.
Conceptual models are relatively easy to create without requiring advanced software—
or any software at all, for that matter. Simple paper and pencil can be used to create
conceptual models, which can then be easily modified.
Once the conceptual model has been approved, additional details can be added in through
the logical and physical models.
Customers
Sales Orders
Products Employees
Department
3.1.2 Logical
A logical data model is a more detailed representation of the data structures in an information
system at the level of the data itself, thus providing more detail than a conceptual data model.
It defines not only the entities and relationships for the data that will ultimately be built into an
information system, but also the attributes of each entity. Logical data models are useful for
data-oriented projects, such as designing a data warehouse or system development.

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If the initial conceptual data model is more detailed to include attributes (as mentioned above),
then the two key differences between the logical and the conceptual models will include:
the logical model will identify the primary and foreign keys in each entity; and
the logical model adjusts any entity-relationship issues related to first normal form or
second normal form.
In this model, the difference is showcased between the conceptual model of entities and
relationships and the logical model adjustment to include attributes, including primary key and
foreign key designations (similar to the database keys model). In the graph below, the same five
entities and relationships from the conceptual model are showcased. However, each entity has
not only attributes but also a primary key designated in the logical model.
The relationships between the entities also exhibit more details to show the connection between
related foreign keys and primary keys. This provides more detail about how normalization
works—for example, in the sales orders table, the product description is not included (even
though it may be meaningful in data analysis to know the names of the products that have sold
the most or least, etc.).
It is not necessary to list the descriptive attribute of product description in the sales orders table
based on the relationship between Products.SKU  Sales_Orders.SKU. A user of the system
could look up the corresponding SKU from the sales orders table in the products table to identify
the descriptive attribute of product description (also, the sales price, cost, and department ID).
While a logical data model provides additional information as compared to a conceptual data
model, it is still not detailed enough to inform how to build a complete, normalized database.
3.1.3 Physical
A physical data model is the most detailed representation of data structures compared to
conceptual or logical data models. Physical data models specify how the data will be stored in
the database. In a physical data model, entities can be referred to as tables and attributes can
be referred to as columns because this model should be complete enough that the database can
be built based on the description in this model.
In addition to including entities (tables), relationships, and attributes (columns—including
primary and foreign key identification), the details often included in a data dictionary for each
attribute can be included in this data model—most specifically the data type of each attribute.
The character limit (if applicable) can be included, as well as if the field is required and any
default values for fields.
The increased level of detail provided in physical data models makes these models useful as a
guide for database implementation and system performance improvements once the database
is implemented.
The relationships and five entities from the conceptual and logical data models are exhibited
in this model, along with the attributes and the primary and foreign key designations where
applicable, but in this physical model the data type can also be seen. The character limit can be
seen in this physical model in places where it is meaningful.
There are many data types, but the data types represented in the model below are detailed in
the following table:
Data Type Description

Int Whole number values—these allow the system to perform
mathematical calculations on the figures, although that is not always a
required component of integers (for instance in primary key values, it
would not be meaningful to sum or average those values. If the fields
are represented as whole numbers, they can be stored as data type
"int" or text).
Char(#) String or number values; the number in parentheses in the character
limit.
Date/time Date/time values are special versions of numerical values that allow
the system to perform mathematical calculations based on the
calendar year and 24:00:00 time.
Decimal Decimal values—different from integers because decimal values are
not limited to whole numbers. Decimal values are also numerical and
allow the system to perform mathematical calculations.
Text Sometimes also referred to as "string" values, text or string values
represent any value that is non-numeric (this can include strings
of numbers that appear numeric to the human eye but are not
interpreted as numerically or mathematically meaningful).
Customers
Sales Orders
Customer ID int
Sales Order ID int
Customer First Name text
Sales Order Date Date/time
Customer Last Name text
Customer ID int
Customer Street Address text
Employee ID int
Customer State char(2)
SKU Int
Customer ZIP char(5)
Products Quantity_Sold int
int Customer Phone char(7)
SKU
Product Description text Customer DOB char(8)
Sales Price decimal
Cost decimal Employees

Employee ID int
Department ID int
Employee First Name text
Department
Department ID int Employee Last Name text
Department Description text Employee Street Address text
Employee State char(2)
Employee ZIP char(5)

= PK
Employee Phone char(7)
= FK Employee DOB char(8)

rights Design
reserved.
The following table provides a summary of how conceptual, logical, and physical models differ.
It is worth noting how each data model builds on the previous model—so an effective logical
model that lacks any characteristics of the conceptual model will not be seen, and an effective
physical model that lacks any characteristics of the logical model will also not be seen.
Feature Conceptual Logical Physical

Table name X X X
Table relationships X X X
Primary keys X X
Foreign keys X X
Column data types X
3.2 Database Schemas

Once the data model is set and the database is prepared to be implemented, the actual
implementation of the data model will follow a schema. Prior discussions included modeling
databases using the first, second, and third normal forms, which is typically used for
transactional, relational databases. For data warehouses and data marts, there are two
additional popular schemas, star schema and snowflake schema. Star and snowflake schemas
have two types of tables: fact tables and dimension tables.
Fact Table: Fact tables contain measures or metrics, which are referred to as facts. These
facts measure the business, such as sales, cost of goods, or profit. Fact tables do not contain
descriptive elements about the business, but they do contain foreign keys to the dimension
tables. These foreign keys relate each row of data in the fact table to its corresponding
dimensions to provide context.
Dimension Table: Dimension tables contain descriptive or contextual data for measures
such as dates, product names, and customer names. These descriptive attributes describe
a dimension; for example, a time table stores the various aspects of time such as year,
quarter, month, and day.
3.2.1 Star Schema

The Star schema is the most common schema for dimensional modeling, and it is also the
simplest schema for dimensional modeling.
Data in a star schema is organized into a central fact table with associated dimension tables
surrounding it, hence why the schema is called a "star," because the diagram of the schema
looks like a star, with the fact table in the center and the dimension tables arranged around it.
3.2.2 Snowflake Schema

A snowflake schema is similar to a star schema, but with the dimension tables further
normalized. In a snowflake schema, the dimension tables are broken down into multiple related
tables, rather than a single table.
The snowflake schema can be more complex than the star schema, as it requires more
tables and more foreign keys to link the tables together. However, it can also be more
flexible, as it allows for more detailed information to be stored about the dimensions.
A snowflake schema strikes a balance between the benefits of a normalized schema and a
star schema.
Dimensional modeling using star or snowflake schemas is typically easier for business users to
understand, which results in easier reporting. Most business intelligence tools, such as Tableau
or Power BI, work very well with star and snowflake schemas.
However, since dimensional modeling does not result in normalized databases, the advantage of
having "one version of the truth" across the tables in a system is lost. Data will be redundant in
a denormalized data model, so whenever a change is necessary in the system, that change will
need to be updated in every area where it has been duplicated.

rights Design
reserved.
7
MODULE
Data Extraction,
Integration, and Process
Documentation ISC 2
1 Data Extraction With SQL Queries
Structured query language (SQL) is a computer language to interact with data (tables, records,
and attributes) in a relational database. Through SQL statements, records and entire tables
can be created, updated, deleted, and viewed (and ultimately extracted). For data analytics, the
focus should be on viewing and extracting data that match the criteria of our analysis goals. SQL
statements used to view and extract data are called SQL queries, which can be thought of as asking
the database a question and receiving an answer based on the criteria placed in the SQL query.
Using SQL, data can be retrieved from one or more tables and organized in a way that is
more intuitive and useful for data analysis and reporting than the way the data are stored in a
relational database. It is critical to understand the data the user has access to in a database—the
tables, how they are related, and their respective primary and foreign keys—in order to write SQL
queries. This is why understanding data dictionaries and data models is integral to data analysis.
SQL queries are written to indicate which subset of data is intended for extraction—including the
intention to filter results based on any criteria (such as filtering by a particular date, customer, or
location) or aggregate existing data (such as sum total sales or sum quantity sold). SQL queries
are made up of SQL commands and database elements, which make up SQL clauses.
SQL Commands: SQL commands are language-specific words, such as SELECT, FROM, JOIN,
GROUP BY, HAVING, WHERE, and ORDER BY. Case does not matter for SQL commands;
however, uppercase is commonly used for SQL commands to differentiate them from
database elements.
Database Elements: Database elements are references to table names, attribute names, or
criteria. Database elements must be spelled exactly the same as the table names or record
names in the database, however case does not matter. It is common to use proper case for
database elements to improve readability and to differentiate the database elements from
the SQL commands.
1.1 SQL Clauses

SQL clauses are phrases that begin with SQL commands and include database elements (such
as attribute names or table names). There is a required order for SQL clauses, and SQL queries
typically begin with two clauses: SELECT and FROM.
1.1.1 Introduction to SELECT

SELECT indicates which attributes the user wishes to view. For example, the Customers
table contains a complete customer list with several descriptive attributes for each of the
company's customers. If a user would like to see a full customer list, but only the three
columns of FirstName, LastName, and State, the user can just select those three attributes
in the first line of the query:
SELECT FirstName, LastName, State
SQL string functions are used in the SELECT clause to adjust string (categorical or text)
values to combine or remove characters from a set of attributes.
© Becker Professional Education Corporation. All rights reserved. Module 7 Data

S2–83
Extraction, Integration
7 Data Extraction, Integration, and Process Documentation ISC 2
1.1.2 Introduction to FROM

FROM lets the database management system know which table(s) contain(s) the attributes
that the user is selecting. For instance, in the previous query, the three attributes in the
SELECT clause come from the Customers table. So that query can be completed with the
following FROM clause:
FROM Customers
1.1.3 Using SELECT and FROM together

Placing the two clauses from the Introduction to SELECT and Introduction to FROM sections
together, a query is ready to run:
SELECT FirstName, LastName, State
FROM Customers
If the same three columns are to be reviewed, but the LastName column needs to be seen
as the first column so that the results more closely resemble a phone book, the order of the
attributes listed can be changed in the SELECT statement. This query will return the same
number of records but with a different order of attributes (columns).
If the need arises to select every attribute in the same order as they exist in the table, a
shortcut can be used to select all:
SELECT *
FROM Customers
1.1.4 Introduction to WHERE

A simple SELECT FROM query is not complex on its own, but when additional clauses are
added, the focus can expand on the particular data necessary for the questions needing an
answer or analysis requested to run.
WHERE behaves like a filter in Excel. The syntax of a simple WHERE clause is the following:
y WHERE [attribute_name] = [criteria]
y The attribute_name needs to be spelled exactly the way it is in the database without any
formatting (for example, do not place the attribute name in quotations).
More information on formatting the WHERE clause:
y Each attribute in a database table is stored as a specific data type. These data types can
be generally categorized into three groups: text, number, and date. The WHERE criteria
will be formatted differently depending on the data type of the attribute being filtered.
y Most text data types are descriptive or categorical elements in the database. When
filtering for criteria from a text attribute, the criteria must be surrounded in quotes.
y Attributes that contain meaningful numerical data that could be summed or averaged
are number data types. When filtering for criteria from a number attribute, there is no
need to format the criteria at all.
y Attributes that describe the day a transaction was created (or shipped, returned, or any
other meaningful date) are date data types.
S2–84 Module 7 Data

© Becker Extraction,
Professional Integration,
Education and Process
Corporation. Documentation
ISC 2 7 Data Extraction, Integration, and Process Documentation
1.1.5 Expanding the Usage of SELECT: Aggregates

SQL aggregate functions are used in the SELECT clause of an SQL query to create grand total
or subtotal values in a query output. Common SQL aggregate functions are SUM(), COUNT(),
AVG(), MIN(), and MAX().
To aggregate means to form a group or a cluster. In SQL, aggregated data represents grand
totals or subtotals of data. For example, if the intent is to not simply view all of the individual
orders in a Sales Orders table, but rather to see a total count of how many orders were in
a table, or to see the grand total quantity of products ever sold, the data would need to be
aggregated.
The following functions are commonly used in the SELECT clause to aggregate data:
y SUM(attribute)
y COUNT(attribute)
y AVG(attribute)
The following query uses an aggregate function that would result in a total count of orders
in the Sales_Orders table:
SELECT COUNT(Sales_Order_ID)
FROM Sales_Orders
1.1.6 Introduction to GROUP BY

Aggregates are extremely useful to return grand totals of the data that are stored in a
database. But sometimes it is preferable to view those data by subtotals instead. When that
is the case, two modifications must be made to the SELECT FROM query that returns a grand
total.
y Step 1: Determine which field to aggregate.
y Step 2: Determine which field is preferred to group the aggregate by.
y Step 3: Place the descriptive attribute and the aggregate function in SELECT.
y Step 4: Indicate which table contains the attributes and place that table in FROM.
y Step 5: Add a third clause, GROUP BY, which will also contain the descriptive attribute
that is preferred to group the aggregate by.
Example:
SELECT CustomerID, COUNT(Sales_Order_ID)
FROM Sales_Orders
GROUP BY CustomerID

S2–85
1.1.7 Introduction to HAVING

When running a query to gather subtotals using a GROUP BY clause, the results can be
filtered in a similar way to using WHERE. SQL cannot filter aggregate measures in the WHERE
clause, though, so the appropriate filter clause for aggregate measures is HAVING.
The format of the HAVING clause is similar to WHERE:
HAVING aggregate(attribute) = Criteria
y The aggregate can be any aggregate value, SUM(), AVG(), or COUNT()
y The attribute is the field being aggregated, COUNT(Sales_Order_ID) or SUM(Quantity)
y The = can be replaced with any operator, =, <, >, =<, =>, <>
y In SQL filtering clauses (WHERE and HAVING), SQL operators are required to describe
the type of filtering that is necessary
y Common SQL operators are =, <, >, =<, =>, <>
y The criteria are the number values that the results are being filtered on
1.1.8 INTRODUCTION to JOINs and ON

The power of SQL extends beyond relatively simple SELECT FROM WHERE clauses. Since
relational databases are focused on reducing redundancy, there are often important details
that may be used for analysis stored across two or three different tables.
For example, there may be an interest to know the phone number of each customer
associated with their different sales orders. Each order is stored in the Sales Orders table,
but the details about the customers (including their phone numbers) are stored in the
Customers table. To retrieve data from both tables, it is important to first make sure that the
tables are related. This is accomplished by looking at the database schema and identifying
the matching primary and foreign keys.
Customers
Customer ID int
Sales Orders Customer First Name text
Sales Order ID int
Customer Last Name text
Sales Order Date Date/time
Customer Street Address text
Customer ID int
Customer State char(2)
Employee ID int
Customer ZIP char(5)
SKU Int
Customer Phone char(7)
Quantity_Sold int
Customer DOB char(8)
= PK
= FK

By reviewing an excerpt of the above database schema, the Sales Orders and Customers
tables are related by the common keys of Customer ID. In order to retrieve data from more
than one table, use SQL JOINs. The two most common join types are INNER JOINs and
LEFT JOINs.
The template for using an INNER JOIN is:
FROM table1
INNER JOIN table2
ON table1.matching_key = table2.matching_key
y In an INNER JOIN, the order of the tables does not matter; the user could place the
Customers table in either the FROM or the INNER JOIN clause, and the order of the
tables does not matter in the ON clause. What matters is that both tables are indicated
when intending to retrieve data, and that the two different tables are indicated with
their matching keys in the ON clause.
y To select all of the matching data from the Customers table and the Sales_Orders table,
the following query can be run:
SELECT *
FROM Customers
INNER JOIN Sales_Orders
ON Customers.CustomerID = Sales_Orders.CustomerID
y INNER JOINs not only work to retrieve data from two tables but, more specifically, an
INNER JOIN will retrieve only the data for which there is a match in both tables. That is, if
there is a Sales_Order recorded without CustomerID information, the INNER JOIN query
would not return that sales order—it would only return sales orders that have verified
customers recorded. The same goes for the other table in an INNER JOIN; if there are
any customers in the Customers table that have not yet participated on a Sales Order,
the INNER JOIN query would not provide any data on those customers. It will only
provide data on customers who have a CustomerID listed in the Sales Order table.
Unlike INNER JOINs, a LEFT JOIN will provide data for which there is not a match. If it is
important to see all of the data from the Customers table, even if there isn't a match in the
Sales_Orders table, then instead of running an INNER JOIN, replace the word INNER with the
word LEFT. The template for a LEFT JOIN is:
FROM table1
LEFT JOIN table2
ON table1.matching_key = table2.matching_key
y In a LEFT JOIN, the order of tables listed in the FROM and LEFT JOIN clauses does matter.
The table listed in the FROM clause is the "left" table; data that does not have a match
will be returned from this table.

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1.1.9 Summary of SQL Commands

Common SQL commands are SELECT, FROM, WHERE, GROUP BY, HAVING, and JOIN, ON. A
summary of each of these commands is in the following table:
SQL command Purpose Example

SELECT Required as the first clause Ex. 1: SELECT Product_Description,
in most SQL queries. SELECT Sales_Price
indicates which attributes are
Ex. 2: SELECT *
requested to view.
Ex. 3: SELECT Customer_ID,
SUM(Quantity_Sold)
FROM Required as the second clause
in most SQL queries. FROM
indicates which table the FROM Products
attribute(s) requested to SELECT
are located in.
WHERE The WHERE clause is used Ex. 1: WHERE Sales_Price > 10
to filter results. The syntax
of a simpler WHERE clause
is: WHERE [attribute name] = Ex. 2: WHERE State = 'AR'
[criteria].
GROUP BY When needing to aggregate
data into subtotals based
on categories (such as state,
GROUP BY Customer_ID
customer, or product), the
GROUP BY clause is necessary
to create subtotals.
HAVING Similar to the WHERE clause,
the HAVING clause is used
to filter data, but instead
HAVING SUM(Quantity_Sold) > 200
of filtering attributes, the
HAVING clause is used to filter
aggregated data.
JOIN, ON When needing to retrieve data FROM Customers
from more than one table,
JOIN Sales_Orders
the JOIN and ON clauses are
required to indicate the second ON Customers.Customer_ID = Sales_
table and how the tables are Orders.Customer_ID
related (via the related primary
key and foreign key)

2 Data Integration
Data stored in relational databases are stored across many different tables, but often reports
and decisions need to be made based on data stored across several different tables; and
sometimes reports and decisions require data not just across different tables in the same
database but even from different data sources altogether.
Most popular data analysis and data visualization tools such as Excel, Microsoft Power BI,
Tableau Desktop, and Alteryx have built-in integrations with an abundance of common
applications, data warehouse tools, and databases. When retrieving data from a large data
source such as a database or data warehouse, it can be useful to couple SQL with the built-in
integrations in order to limit the data required to only the data that is necessary.
2.1 Application of Data Integration

For financial analysis, it is common to combine an internal company's financial statements with
external market data from an online financial database such as Bloomberg or Yahoo Finance.
More specifically, an analyst may collect external data to compare the company's financial
performance relative to its industry peers, including other companies' financial statements and
generally interest rates, inflation rates, and gross domestic product to help place their own
company's financial performance into context.
For operational analysis, it is common for relevant data to be stored across different
databases or spreadsheets that need to be integrated to make operational decisions or assess
performance. For example, combining data from a production database or the production
plans with supply chain data can help analysts identify areas of inefficiency such as over- or
underproduction so that production schedules can be optimized.
3 Visualizing the Flow of Processes and Data
Organizations are made up of many complex processes, and those complex processes are
supported by an abundance of data. Visualizing the steps of processes across roles in an
organization and the flow of data that supports processes can explain how a business works and
help users understand when data is created and how it is used.
Flowcharts are common tools for depicting process or data flows that help analysts understand
processes and analyze those processes for improvement—whether that improvement is based
on effectiveness, efficiency, or improved internal controls. There are a variety of templates for
flowcharts, including the Business Process Modeling Notation (BPMN), which is used to create
flowcharts referred to as activity models and data flow diagrams (DFD), which are used to
describe the flow of the data through a process.

S2–89
3.1 BPMN Activity Models

BPMN is a standardized tool for creating diagrams, with set symbols and rules to depict
business processes. This tool enables users to use a common set of concepts and principles to
communicate business processes so that they can be documented, improved, and managed.
BPMN activity models can not only be used to improve effectiveness and efficiency of processes
among human participants in a process—they can also be examined to identify process areas
that could be automated. A rule of automation is that the more rule-bound a process is, the
easier it is to automate. Once BPMN activity models are created, they can be analyzed for how
rule-bound the steps and decisions associated with the process are. There are significant cost
savings associated with automating repetitive processes.
While there are numerous notations within different categories, the following describe the most
common symbols and rules.
3.1.1 Flow Activities

A primary purpose of a BPMN activity model is to describe which organizations are involved
in a process, and within those organizations to describe how the process is separated across
roles/duties. The metaphor of "swim pools" and "swim lanes" is used to visualize the different
organizations and roles.
Pools: Pools are used to quickly showcase how many organizations are involved in a given
process. Every BPMN model should include one pool at a minimum—that pool will indicate
the internal organization involved in a process. For instance, in a sales process, the internal
organization will be the selling organization, and a separate external organization will be the
customer. However, there are occasionally processes that are fully internal, such as payroll.
In this case, a BPMN activity model may have only one pool.
Selling (Internal)
Organization
Customer (External)
Organization
Swim Lanes: Swim lanes are more granular than pools. Swim lanes indicate the segregation
of duties within an organization. If there are different roles within one organization involved
in a process, then the pool will be separated into separate pools to indicate which role is
responsible for which step in the process. For example, in the selling (internal) organization,
there might be a sales representative role that is separate from a cashier role. In the
following model, the pool for the internal organization has now been split into two lanes—
one for the sales representative and another for the cashier, while the pool for the customer
remains one pool (without separate lanes).

Representative
Selling (Internal) Organization
Sales
Cashier
Customer (External)
Organization
3.1.2 Events
Events describe how a process begins or ends. Events are not actions; they simply indicate when
a process kicks off (think of it as a trigger) and when a process is complete. Events are circles.
The thickness of the circle depends on whether the event is a start, intermediate, or end event.
Start Events: Every pool within a BPMN model must begin with one and only one start
event. Remember: start events are based on pools, not swim lanes—regardless of how many
swim lanes there are in a pool, there should only be one start event per pool. Start events
are smooth circles:
End Events: Every pool must end with at least one end event. However: end events are not
based on swim lanes—regardless of how many swim lanes there are in a pool, a process may
still end with only one end event. Additional end events only indicate the potential that a
process is cut short early or has multiple ways to end. End events are bold circles:
Intermediate Events: Intermediate events are not a required element of every BPMN
diagram, but they exist to indicate when something changes the course of a process, such
as a time delay or an error. Intermediate events are two-lined circles.

S2–91
3.1.3 Tasks
Every action in a process is documented as a task, which is a rectangle with rounded edges.
Consider every step a person or a system must take to complete a task, and each of those
steps must exist as its own task. For example, in a sales process, the first task might be "Input
Customer Name," followed by "Select Product," then "Select Quantity."
It is worth revisiting the model shared previously with the two separate pools for the selling
and customer organizations. To simplify the new objects, the tasks will be kept in the selling
organization to three tasks, all of which are completed by only one role (so there are not
separate swim lanes). At this point, the BPMN activity model (including only the internal
organization) would appear as follows:
Selling (Internal)
Organization
Input Customer Select Product Select Quantity

Name
Other than recognizing that the sales process is not complete (and lacking segregation of duties
or separate organizations marked by lanes or pools), it can be noted that the BPMN objects are
not yet connected to one another. The next step is to connect them.
3.1.4 Connecting Objects

Sequence Flows: Every object within one pool must be connected with sequence flows.
BPMN activity models are traditionally read from left to right, with the start event as the
left-most object and the end event(s) as the right-most object(s) in a pool. Start events kick
off the process, with a sequence flow extending to the right from the start event to the first
task, then each object continues receiving sequence flows and extending sequence flows
to the next object until the process culminates in the end event(s) that receives a sequence
flow, then the process ends. Sequence flows are smooth-lined arrows.
Adding the sequence flows to the above model (still only considering the internal
organization with three simple tasks) will enhance the model:
Selling (Internal)
Organization
Input Customer
Select Product Select Quantity
Name

Message Flows: When a BPMN model requires more than one pool (for instance, in the
previously examined sales process in which there is also a customer, or when there is a
purchasing process where there is also a supplier/vendor/manufacturer), there will be
occasional required communication between the internal and external organizations. In this
case, the communication will not be indicated by a sequence flow but by a message flow.
Message flows look similar to sequence flows, shown as dashed arrows, but they only
function to indicate communication between two separate pools—they should never be
used within one pool to indicate communication between lanes in the same pool. The
direction of the message flow should indicate the direction of communication; whoever
is answering a question and/or providing information should "send" information to the
other pool.
Selling (Internal)
Organization
Input Customer Select Product Select Quantity

Name
Customer (External)
Organization
Provide Indicate
Indicate Product
Information Quantity
3.1.5 Gateways
So far, the models have been simple and have easily flowed from the start event—through
tasks—and ultimately to an end event. An important step in process analysis is to question
the drafts continuously during the analysis phase of a project to determine that all of the
requirements have been documented and expectations have been discussed.
For this example, each task should be questioned and analyzed to determine if the tasks
can move from start event to end event effectively, and that nothing could go wrong in any
of the steps (be it error, fraud, etc.). Gateways help provide analysis opportunities for when
a task shouldn't result in only one possible sequence flow but rather more than one—be it
two, three, or more.
A task (such as "indicate product" and "indicate quantity") can occur mundanely enough, but
then as soon as the system recognizes that it is possible that there is not sufficient inventory
for the product and quantity mix that the customer ordered, there needs to be a gateway to
provide all of the possible directions a sales representative might go in.
The gateway (shaped like a diamond) is a question, not a task. There should not be any
active verbs in the annotation of the text of a gateway, only a question. In this instance,
the gateway label could read, "Is there sufficient quantity of this product?" (or, if that is too
wordy, simply "Sufficient quantity?").

S2–93
There is an abundance of rules that relate to gateways, but the most important regard
sequence flows exiting a task object. Task objects should always have one and only one
sequence flow "exiting" the task, so if there are two potential exits or flows away from a
sequence flow, then an opportunity is identified to use a gateway.
3.2 Data Flow Diagrams

A data flow diagram is a standardized tool for creating diagrams that describe the way data
moves through an organization. While there are BPMN objects that can be used in BPMN activity
models to indicate data stores, data flow diagrams offer a more granular level of detail about
how data moves through a process or system that BPMN activity models alone do not provide.
While data flow diagrams are more granular than BPMN activity models, there are fewer objects
used in data flow diagrams. The four objects in a data flow diagram are similar in shape to the
objects in a BPMN activity model.
3.2.1 Process
A process indicates any action that results in data changing and producing a new output. The
labels for processes are similar to the labels in BPMN activity model tasks; they are formatted
as a short sentence such as "Input Customer Information." The shape of a process object is
depicted as either a rectangle with rounded corners or a circle.

3.2.2 Data Flow

A data flow indicates the direction that data flows through processes. Data flows are labeled to
indicate the data that is flowing between processes—for example, "Customer Contact Details."
The shape of a data flow object is an arrow, either curved or straight.
3.2.3 Data Store or Warehouse

A data store object indicates where data is stored for later use—for example, a database,
a SharePoint folder, or even a physical filing cabinet. The shape of a data store object is an
open‑ended rectangle.
3.2.4 External Entity or Terminator

An entity object indicates the external entity (organization, group of people, or different
department) that receives the data at the end of a set of processes represented in a data flow
diagram. The shape of an entity object is square.
Example: Simple Data Flow Diagram
Customer
Relationship System
Customer Details
Process
Customer Customer Details Cash Receipt
Orders Payment Details Database
Process
Payment
Payment Deposit
Bank

S2–95
NOTES

ISC
3
Security and Confidentiality
Module
1 Threats and Attacks 3
2 Mitigation of Threats and Attacks 17
3 Security Testing 39
4 Confidentiality and Privacy 47
5 Incident Response 61
NOTES

1
MODULE
Threats and Attacks ISC 3
1 Cybersecurity Risk Management Overview
Cybersecurity is the practice of protecting an organization's IT infrastructure and critical data

from bad actors by deploying a variety of technologies, internal control processes, and best
practices to mitigate the business impact of these attacks. The goal of a cybersecurity program
is to manage the cybersecurity risks by securing and enhancing confidentiality, data integrity,
and availability.
Successful cyberattacks can cost an organization monetary and nonmonetary losses to restore
its ability to work with customers, vendors, and partner organizations. These attacks are
threats to both individuals and organizations. Breaches of data, theft, service interruptions, and
regulatory noncompliance are the highest of security concerns for senior executives and others
who are charged with IT governance.
Data Breaches: Data breaches occur when information is compromised and utilized
without the authorization of the owner. Examples of attacks that can result in data breaches
include ransomware, phishing, malware, and compromised passwords.
Service Disruptions: Service disruptions are unplanned events that cause a general system
or major application to be inoperable for an unacceptable length of time. Some examples
of the causes of service disruptions include malware, distributed denial-of-service (DDoS)
attacks, SQL injections, and password attacks.
Compliance Risk: Regulators can require organizations to comply with cybersecurity
regulations. The failure to comply with these regulations can result in fines and financial
penalties. Examples of areas involving compliance risk include HIPPA, GDPR, PCI-DSS, and
ISO/IEC 27001.
To combat these threats, organizations should develop a program to mitigate cybersecurity
risks and constantly develop innovative security measures that keep up with the ever-changing
technology landscape.

1 Threats and Attacks ISC 3
2 Cyberattacks
A cyberattack is any kind of malicious activity that targets computer information systems,
infrastructures, computer networks, or personal computer devices, and attempts to collect,
disrupt, deny, degrade, or destroy information system resources or the information itself.
The impacts of such attacks can directly or indirectly affect the organization, its customers, its
vendors, or potentially its partner organizations. The method of execution of an attack can be
grouped into one of the following categories: network-based attacks, host-based attacks, social
engineering attacks, application-based attacks, physical attacks, and supply chain attacks.
Types of Cyberattacks
Network-based Attacks Application-based Attacks Host-based Attacks Social Engineering Attacks Physical Attacks Supply Chain Attacks
2.1 Types of Threat Agents

A threat agent is an internal or external attacker that could negatively impact data security
through theft, manipulation, or control of sensitive information or systems.
There are several types of threat agents (i.e., people who build malware and perform attacks on
infrastructure and applications). There is usually a particular goal, such as financial gain or the
destruction of data.
Examples of the types of different threat agents include:
Attacker, Threat Actor, or Hacker: These are individuals, or groups of individuals known
as hacking rings or advanced persistent threats (APTs), that target people or organizations
to gain access to systems, networks, and data. This classification of threat agents is broad
and has a wide range of objectives which include stealing property, destabilizing businesses,
spying on governments, disseminating true or false information, or attempting to achieve
some form of financial gain.
Adversary: These are actors with interests in conflict with the organization. They are
incentivized to perform malicious actions against the organization's cyber resources such as
intercepting purchases, theft of data, tampering with hardware prior to installation, social
engineering attacks, and more.
Government-sponsored/State-sponsored Actors: These threat actors are funded,
directed, or sponsored by nations. They've been known to steal and exfiltrate intellectual
property, sensitive information, and even funds to further their nations' espionage causes.
Hacktivists: These are usually groups of hackers that operate to promote certain social
causes or political agendas. Likewise, there are also groups of hackers that operate on a self-
proclaimed relatively moral basis by staying away from certain targets, such as hospitals,
churches, and other organizations that have altruistic purposes or missions.
S3–4 Module 1 © Becker Professional Education Corporation. AllThreats and Attacks

rights reserved.
ISC 3 1 Threats and Attacks
Insiders: Insiders are employees that either organically developed into a person with
malicious intentions or intentionally infiltrated an organization to achieve nefarious
objectives. These individuals represent a significant internal threat to any organization's
cybersecurity because of the amount of access they have working from within a
company's safeguards.
External Threats: Threats that occur from outside of the organization, entity, or individual
that is the target of the cyberattack.
2.2 Types of Cyberattacks

Network-based Attacks: These attacks target the infrastructure of a network, including
switches, routers, servers, and cabling, with the intent to gain unauthorized access or
disrupt operations for users.
y Backdoors and Trapdoors: These are methods to bypass security access procedures
by creating an entry and exit point to a network that is undocumented. Trapdoors
are often installed by system owners so they can bypass security measures to gain
quick access, whereas backdoors may be intentionally installed or unintentionally left
available due to product defects. While neither of these are an attack on a network,
they facilitate entry into the network that can be used to execute attacks.
y Covert Channels: These are mechanisms used to transmit data using methods not
originally intended for data transmission by the system designers. These channels
violate the entity's security policy but do not exceed the entity's access authorization,
so they can communicate data in small parts. Based on the method of hiding the
information, there are two types of covert channels:
—Storage Channels: Data is transmitted by modifying a storage location, allowing
another party with lower security permission to access the data.
—Timing Channels: The delay (or gap) in transmitting data packets is used to hide a
transmission.
y Buffer Overflows: Attackers overload a program's buffer, the temporary storage, with
more input than it is designed to hold. This may cause the program to overwrite the
memory of an application or crash. The attacker can then inject malicious code or take
control of a system.
y Denial-of-Service (DoS): An attacker floods a system's network by congesting it with
large volumes of traffic that are greater than the bandwidth it was designed to handle.
This excess volume consumes the network's resources so that it cannot respond to
service requests, leaving it vulnerable to network protocol or application exploitation.
y Distributed Denial-of-Service (DDoS) Attacks: These occur when multiple attackers
or compromised devices are working in unison to flood an organization's network with
traffic. These attacks manipulate the operation of network equipment and services in
such a way that they may be more powerful than a traditional DoS attack.
y Man-in-the-Middle (MITM) Attacks: The attacker acts as an intermediary between two
parties intercepting communications, acting as a legitimate entity within a typical secure
session. As information is passed between the two parties, the attacker can read or
redirect traffic.

y Port Scanning Attacks: Scanning networks for open ports is frequently done by
attackers to find vulnerabilities that can be exploited so that they can gain unauthorized
access to a company's network.
—While ports can be physical (e.g., HDMI, USB, Ethernet ports), this attack focuses on
logical ports that are used for protocols such as TCP (Transmission Control Protocol)
port 80, which is one of the most common ports used on the internet.
—It is normal for companies to have open ports, but misconfigured open ports with
vulnerabilities create weaknesses that allow unauthorized access.
—Common vulnerabilities include unsecured protocols, unpatched protocols, poor
login credentials, and poorly configured firewalls.
y Ransomware Attacks: These are attacks that typically come in the form of malware
that locks a user or a company's operating systems, applications, and the ability to
access data unless a ransom is paid.
y Reverse Shell Attacks: Also referred to as "connect-back shells." A victim initiates
communication with an attacker from behind a company's firewall so that the attacker
can bypass the firewall and any other network safeguards and remotely control the
victim's machine. Since the original contact is not established from outside of the
company's network, normal filtering and firewall protection are bypassed.
Firewall
Attacker 1. Connection initiated by target Victim
2. Attacker bypasses firewall
y Replay Attacks (Eavesdropping): These are a type of MITM attack in which a

cybercriminal eavesdrops on a secure network communication, intercepts it, and
then "replays" the message at a later time to the intended target to gain access to the
network and the data that is behind the firewall. Hackers don't need the added skill of
decrypting a message because they have already tapped into the company's network.
y Return-Oriented Attacks: Also known as "return-oriented programming attacks,"
these use a sophisticated technique that utilizes pieces of legitimate original system
code (each a gadget) in a sequence to perform operations useful to the attacker. Each
gadget ends with a "return" instruction, causing the next gadget to execute and carry
out complex operations.

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y Spoofing: The act of impersonating someone or something to obtain unauthorized

system access by using falsified credentials or imitating a legitimate person or entity by
using fake IP addresses, domains, or email addresses.
—Address Resolution Spoofing (ARS): This spoofing attack involves a fraudulent act
of falsifying the mapping of media access control (MAC) addresses on a network to IP
addresses. All devices on a network have MAC addresses that map to IP addresses.
By using ARS, the attacker links its MAC address with the target's IP addresses so that
devices can communicate with each other point to point (IP address to IP address).
Manipulating the mapping of the ARS means fraudsters can channel messages to
alternate destinations.
—DNS Spoofing: A spoofing attack that involves a perpetrator modifying the
domain-name-to-IP-address mapping known as the domain name system (DNS). A
company's DNS server translates domain names to IP addresses. For instance, www.
MyCompany.com might be converted to 111.100.1.10. If this mapping is tweaked
by an attacker to redirect someone to another IP address that leads to a mimicked
website, the victim could potentially enter usernames, passwords, or sensitive
information, or download a malicious application from the fake site.
—Hyperlink Spoofing: The alteration of hyperlink URLs that redirect the victim away
from their intended destination and send them to a nefarious location.
Application-based Attacks: These forms of attacks target specific software or applications
(desktop or web) such as databases or websites to gain unauthorized access or disrupt
functionality.
y Structured Query Language (SQL) Injection: An application attack in which an
attacker injects malicious SQL code into existing SQL code on a company's website to
gain unauthorized access to a company's data.
—Attackers may not have direct access to a company's database server that contains
company data, but it can gain access through the company's web server, which may
connect directly to a company's database server.
—By injecting malicious SQL code into the web server directly from the internet, the
attacker is able to access the database server by manipulating the web server.
Direct Connection
X
Database Server
Contains:
SQL Injection - Usernames
- Passwords
- Credit Card Numbers
- Bank Account Numbers
Attacker Web Database
Server Server
y Cross-Site Scripting (XSS): Similar to an SQL injection, but these attacks inject code to
a company's website that attacks users visiting the company's website. When a user
visits the site, the user's browser executes the malicious code and performs the attack,
which may compromise the user's data, such as usernames, passwords, and other
sensitive information.

y Race Condition: An attacker exploits a system or application that relies on a specific

sequence of operations. By forcing the application to perform two or more operations
out of order or simultaneously, an attacker may gain unauthorized access or execute a
fraudulent act.
y Mobile Code: Any software program designed to move from computer to computer
to "infect" other applications by altering them in some way to include a version of the
code. Malicious mobile code is commonly referred to as a "virus." Viruses can come in
many forms, including the following:
—Overwrite Virus: These viruses delete or overwrite information in the infected file.
Typically, removal of the virus requires deletion of the file.
—Multi-Partite Virus: This type of virus uses a mixture of infection methods to infect
files, trying different ways to infect a file if others fail.
—Parasitic Virus: These viruses launch when an application that has the virus launches
and the same rights held by the program being launched are given to the virus.
—Polymorphic Virus: This form of virus mutates by changing its structure so that it can
avoid detection.
—Resident Virus: These viruses install a copy of themselves on a computer's memory.
Host-based Attacks: These attacks target a single host such as a laptop, mobile device, or a
server to disrupt functionality or obtain unauthorized access.
y Brute Force Attacks: These are password-cracking schemes in which attackers use an
automated program that attempts to guess a password. The program tries all possible
combinations of potential passwords based on a preset algorithm, which can be as
simple as starting with the first letter of the alphabet for each character and trying
all possible combinations, or it may first try common phrases and password/number
combinations before advancing to other permutation algorithms.
y Keystroke Logging: Keystroke logging is a scheme involving tracking the sequence of
keys pressed by a user on a keyboard to collect confidential data such as usernames,
passwords, and personal information. These are often delivered as Trojan horses.
y Malware: Malware is software or firmware intended to perform an unauthorized
process that has an adverse impact on the confidentiality, integrity, or availability of
an information system. Common examples are viruses, worms, Trojan horses, adware,
spyware, and other code-based programs that infect a host.
y Rogue Mobile Apps: These attacks involve the use of a malicious app that appears
legitimate. A fraudulent party creates a mobile application that is installed by a victim
unsuspectingly and that app then steals information, gives the attacker unauthorized
access, or executes some other malicious act.
Social Engineering Attacks: These attacks involve the use of psychological manipulation
or deception to get employees to divulge sensitive information, provide unauthorized
access, or assist an attacker in committing fraud. Human interaction through email, text,
direct messaging, or social media is the primary medium through which perpetrators gain
confidence and trust.
y Phishing: Phishing is a form of digital social engineering that uses authentic looking—
but bogus—emails that request information from users or direct them to a fake website
that requests information.

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y Spear Phishing: This form of phishing targets employees in a corporate entity by

posing as a legitimate department or employee, such as human resources or the IT
director. The goal is to obtain confidential information such as usernames, passwords,
or personal data that can be used for exploitation.
y Business Email Compromise (BEC): This is a form of phishing that targets executives
and other high-ranking individuals. It typically involves schemes to get the executive
to transfer money through a wire, pay fake foreign suppliers, or send sensitive data to
someone impersonating an attorney or other employee. This scheme has also been
called whaling.
y Pretexting: This attack is similar to BEC and spear phishing, but it involves creating a
fake identity or scenario so that the employee has a sense of urgency to act. By using
this form of pretext, or false reason, the attacker is able to obtain sensitive information
or manipulate the victim into performing some other fraudulent act.
y Catfishing: This scheme involves the creation of a fake online persona that is used to
lure a victim into a personal relationship with a fraudster. The person conducting the
scheme then appeals to the emotional nature of the victim and requests money, gifts,
or other items of value.
y Pharming: This attack is often used in combination with phishing as it involves a
victim entering personal information into a website or portal that imitates a legitimate
website. The link to the fraudulent site may be in a phishing email. The scheme may
even involve the manipulation of Domain Name System (DNS) servers so that the
website's URL replicates the correct address.
y Vishing: This technique involves fraudulent schemes using the telephonic system Voice
over Internet Protocol (VoIP). Schemes normally involve a spoofed or fraudulent caller
ID that is tied to a legitimate business or person. Attackers often use incoming recorded
messages that may be interactive and use key tones or voice recognition to convert
information input by the victim into numbers or letters.
Physical (On-Premises) Attacks: This is a security breach carried out on an organization's
premises or performed in some way that physically involves a bad actor gaining control of
sensitive data, hardware, and/or software.
y Intercepting Discarded Equipment: By obtaining access to outdated or discarded
equipment in the trash or through companies that accept discarded equipment,
fraudsters can steal sensitive data stored on such devices.
y Piggybacking: This method of attack involves an attacker using an authorized person's
access to gain entrance to a physical location or electronic access.
y Targeted by Attackers: On-premises infrastructures are often targets of hacking
groups or attackers because they know that many organizations lack sophisticated
cybersecurity defenses. This lack of protection may be due to the cost of
implementation or a lack of awareness of potential cyber threats.
y Tampering: This involves gaining physical access to a company's IT infrastructure and
modifying the way its network collects, stores, processes, or transmits data. This can
be done by physically rewiring cabling, plugging in directly to network equipment, or
adding an unauthorized device to the existing network.
y Theft: This refers to the act of physically stealing data, hardware, or software.

Supply Chain Attacks: These attacks use cyber tactics to target the production and
distribution of goods within a supply chain so that there are larger disruptions in the normal
operations of a company, government, or other entity.
y Embedded Software Code: This form of attack involves inserting code into
prepackaged software or firmware being sold to a company that later installs the
software after purchase.
y Foreign-sourced Attacks: In many countries, governments have deep and widespread
control of companies in the private sector. Those governments may use products sold
to other countries to conduct surveillance or deliver malicious code.
y Pre-Installed Malware on Hardware: This method of attack involves installing
malware on devices that will be used by companies in a supply chain, such as USB
drives, cameras, or phones. Once the company acquiring the devices connects them to
the company's network, the malware executes.
y Vendor Attacks: This attack is perpetrated upon key vendors of a target company so
that the normal production of goods or business operations is disrupted.
y Watering Hole Attacks: In this method of attack, fraudsters identify websites of
suppliers, customers, or regulatory entities that are known to be used by several
companies or even entire industries. The attackers then look for weaknesses
at that third party that can be used to deliver malware, steal data, or obtain
unauthorized access.
Illustration 1 The Invasive Impact of Cyberattacks
Given the interconnections of organizations with their customers, vendors, and partner
organizations, the impact of a cyberattack upon one organization could have a profound
impact on other organizations. Below are examples of how these attacks could impact
stakeholders outside the organization.
Partner
Customer Organization's
Example Attack Impact Vendor Impact Impact
Ransomware Attack: The Unable to deliver Vendors are unable Financial losses due
attacker encrypted the products to to communicate to ransom payment to
company's servers and customers, causing with the company support the victim of
databases, preventing the interruption of through electronic the attack
company from accessing the company's data interchange
customer data and customers' channels to fulfill
processing orders fulfillments purchase orders
Mobile Code: The attacker The customer's The vendor's The partner must
infected the company with ordering systems systems were reallocate resources to
a virus that deletes critical are infected by infected, causing support the company
contact data and spreads the virus causing the vendor to under attack, causing
the virus through the data loss lose critical disruptions in its
business network production data main operations
Malware: The attacker Confidential Vendor banking Reputation loss
infected the company's customer data information and potential
servers and exposed is exposed to is exposed to class‑action lawsuit
confidential customer data the attacker the attacker

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2.3 Stages in a Cyberattack

While there are a variety of cyberattacks, they all share some of the following steps or phases:
Reconnaissance: In this first stage, attackers discover and collect as much information
about the target IT system as possible. Information obtained may include the location of
facilities, the type of network and infrastructure deployed, security measures in place, and
the names of employees as well as the management hierarchy. During this phase, attackers
may also search for specific vulnerabilities, such as open ports that are not adequately
protected or known software applications that have not been sufficiently patched.
Gaining Access: This is the step in a cyberattack when the information collected in the
previous steps is used to gain access to the target of an attack using a variety of techniques.
Escalation of Privileges: Once unauthorized access into a system is obtained, attackers
attempt to gain higher levels of access in this stage. This may be done by obtaining the
credentials of a user with higher privileges.
Maintaining Access: In this stage, the attacker remains in the system for a sustained period
of time until the attack is completed and looks for alternative ways to prolong access or
return later.
Network Exploitation and Exfiltration: In this stage, attackers proceed with the objective
of disrupting system operations by stealing sensitive data, modifying data, disabling access
to systems or data, or performing other malicious activities.
Covering Tracks: This step occurs while the attack is in progress or after the attack is
completed and involves the attacker concealing the entry or exit points in which access was
breached. This can be done by:
y Disabling audit functionality
y Clearing logs
y Modifying logs and registry files
y Removing all files and/or folders created
3 Risks Related to Cloud Computing
Cloud computing is a way for organizations to store, use, process, and share data, software,
and applications without the need to own or manage the resources required to perform those
functions on company premises. Companies access the needed computing power using the
internet. The data and software applications used in a cloud computing environment are often
stored and managed by third-party providers, which causes a significant amount of sensitive
information and user applications to be at risk.
Despite this risk, most cloud providers are seen as being more secure than a company managing
its own IT infrastructure on its own premises (referred to as on-premises). This is because most
cloud providers are required to maintain high levels of security protocols and procedures, and
upgrade to the latest versions with security patches and internal controls due to regulations
such as GDPR and HIPAA.

It is also common for third-party cloud providers to have SOC 2® engagements, which are
independent audits of management's attestation regarding the cloud service provider's controls
and other claims made by management regarding security over their customer's data, privacy,
and confidentiality. Information to be included within the SOC 2® engagement report may
include how controls at the service organization address the Cloud Security Alliance's Cloud
Controls Matrix, whereas the engagement team would consider relevant established criteria
related to the security of a system.
Below are some risks specific to cloud computing for which a firm should be aware:
Additional Industry Exposure: By nature of design, organizations subscribing to a cloud
provider may be exposed to other subscribing organizations and their unique industry
risks. Cyber threats that one company might not be exposed to become a risk to the other
companies that share the same cloud computing provider.
Cloud Malware Injection Attacks: An attack specific to cloud computing-based systems in
which an attacker gains access to the cloud environment and then injects malware so that
data can be stolen, services disrupted, or further access gained.
Compliance Violations: Cloud computing relies on third-party hosts, and there is the
compliance risk that these hosts or service providers do not have the security protocols and
procedures in place to meet regulations on privacy and confidentiality (i.e., HIPPA and GDPR
regulations).
Loss of Control: Not having physical or logical access to computing equipment means
an organization using cloud computing services will relinquish some control over its
infrastructure. As a result, changes or upgrades to the cybersecurity measures may not be
timely or up to the standard that the subscribing company prefers.
Loss of Data: The third-party cloud computing services provider is susceptible, albeit less
likely than most businesses, to data breaches, losing data, or exposing data.
Loss of Visibility: Loss of full visibility of the company's IT infrastructure comes with a
loss of control. The only entity that has full visibility is the cloud provider, which means the
subscribing organization does not know all of its risks.
Multi-Cloud and Hybrid Management Issues: A company subscribes to various
cloud‑based solutions and/or maintains some on-premises IT infrastructure. While having
a hybrid or multi-cloud setup can be part of a good cybersecurity diversification plan, it
may prove challenging to integrate and monitor multiple environments, which could make
detecting a cyberattack difficult.
Theft or Loss of Intellectual Property: Cloud applications store various types of data
for companies, including proprietary information, and there is the risk that the service
provider lacks sufficient controls over the data, which results in theft or loss of intellectual
property (IP).

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4 Risks Related to Mobile Technologies
Mobile devices such as smartphones, tablets, and wearables that can access the internet all have
risks for both users and their employers. While these devices have evolved to become a regular
part of corporate life and enhance productivity, their mobility and lack of oversight introduce
cybersecurity risks that should be addressed.
Most mobile devices are similar to computers in terms of functionality and the type of
information they access. As such, they face similar security threats as an organization.
However, some of their differences are at the root of mobile device cybersecurity issues, such as
the fact that mobile device operating systems are different than their computer counterparts.
A separate set of patches and updates must be maintained so that operating systems can be
updated. Another difference is that immobile desktop computers are not constantly exposed to
public networks like mobile devices are. As a result, companies must install software on every
mobile device to monitor and protect users from potential attacks. If protective software is not
used, policies should be in place that provide guidelines for safe usage.
Other risks and cybersecurity threats specific to mobile devices include the following:
Application Malware: This threat occurs when a user downloads an application that
appears to be legitimate but gives an unauthorized user access to the device. For example,
when a user visits a site, malware could be installed that steals private information without
the user's knowledge.
Lack of Updates: There could be uninstalled patches and security fixes that have yet to
be installed at a given point in time that leave the device vulnerable. Devices that go long
periods of time without updates are at risk.
Lack of Encryption: Many mobile devices are not encrypted and only rely on a passcode
for secure access. Once access is gained, passwords can be reset on the web by using the
victim's email on the mobile device.
Physical Threats: Examples of physical threats include loss or theft of a mobile device. If
the device does not have sufficient access controls, theft could lead to an unauthorized user
gaining the ability to access sensitive information and applications.
Unsecured Wi-Fi Networks: Users of mobile devices often connect to public unsecured
networks which means anyone on the same network could potentially access that device,
steal sensitive information, or infect the device with malware.
Location Tracking: Unauthorized tracking is a risk that involves a threat actor using Global
Positioning System (GPS) technology to locate people, devices, or other assets. With this
knowledge, attackers can devise plans that use the victim's location to perpetrate an attack.
Threat actors can also use mobile storage devices such as USB drives, memory cards, or optical
discs to infect other devices. For instance, USB drives can be easily plugged into a laptop or
desktop and quickly install software that can compromise the device.
Mobile devices can also be monitored or surveilled for the purpose of eavesdropping.
Equipment such as cell-site simulators, Bluetooth scanners, and international mobile subscriber
identity (IMSI) catchers can be used to intercept calls or text messages within a specific radius.

5 Risks Related to the Internet of Things
The Internet of Things (IoT) is a class of smart devices connected to the internet that provide
automation and remote control for other devices in a home or office setting such as cameras,
tablets, wearable devices, phones, and alarm systems. Organizations continue to integrate
IoT devices into normal business operations. As such, companies must consider cybersecurity
implications that this technology introduces.
Relevant cyber threats specific to IoT technology include:
Device Mismanagement: Insufficient password controls and device mismanagement can
increase the risk of a cyberattack. This can lead to the loss of critical information or access to
the devices on the IoT network.
Device Spoofing: This is when an attacker creates an illegitimate or phony device and
introduces it to a company's network, posing as an actual device, to gain information or
access to that network.
Escalated Cyberattacks: IoT devices can be used as an attack base to infect more
machines, or as an entry point for access into a connected network.
Expanded Footprint: IoT devices paired with other devices that are directly connected to a
company's core network expand the footprint of total devices under a company's purview,
thus increasing the number of points subjected to attack.
Information Theft: Since IoT devices are connected to the internet, they have the potential
for sensitive data to be stolen or exploited because that data is either stored in the cloud or
on other devices that can be accessed
Outdated Firmware: Attackers can intercept IoT firmware updates or manipulate firmware
with known weaknesses to gain access and control a device. Firmware is software that is
pre-installed on a device that controls its local functions, much like the software that comes
installed on a printer or scanner. Since employees often wear IoT devices or bring their own
into a company's office without alerting IT personnel, they are often missed as a part of the
organization's cybersecurity defenses.
Malware: IoT networks and devices are susceptible to cyberattacks due to the often-limited
computing power among the individual devices connected to the network. A common
example of malware attacks for IoT technology is ransomware, where the malware code
denies access to the devices without a financial consideration paid by the user.
Network Attacks: Threat actors can launch DoS attacks on IoT networks and devices just as
they can with traditional networks. These types of attacks overburden a network with traffic
via IoT devices and render it useless.

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6 Threat Modeling and Overall Threat Landscape
Threat modeling is the process of identifying, analyzing, and mitigating threats to a network,
system, or application. The goal is to understand all risks a system could face and develop
controls and countermeasures to minimize the impact of a risk or to try and prevent it
from happening. Developing a threat model forces companies to identify weaknesses and
vulnerabilities that need to be addressed.
Part of threat modeling involves evaluating the threat landscape, which is the total range of
potential threats that an organization and its IT infrastructure may face. Organizations should
regularly assess the threat landscape because new threats are continuously evolving. One way
to do this is by using threat intelligence platforms, which help organizations get information on
the latest threats and vulnerabilities so companies can prioritize their cybersecurity efforts.
Elements that should be considered when evaluating the threat landscape include different
attack vectors or methods, the magnitude of impact of a threat, existing vulnerabilities, and the
types of threats (social engineering attacks, insider threats, network attacks, etc.).
6.1 Phases of Threat Modeling

Threat modeling typically involves the following phases:
Identify Assets: This involves inventorying all assets that need to be protected against threats.
Identify Threats: This includes identifying the threat types and characteristics, such as
intent, targeting, and potential method of attack. Realistic threat scenarios should also be
discussed and used for planning.
Perform Reduction Analysis: This phase involves decomposing the asset being protected
from the threat. The intent is to gain a greater understanding of how the asset interacts with
potential threats whether they are systems, applications, or networks. The decomposition
process involves understanding trust and security changes, the flow of data, where input
can be received, security clearances, and any related policies and procedures.
Analyze Impact of an Attack: Quantifying the impact of an attack in terms of dollars will
help prioritize solutions. Understanding other qualitative effects should also be considered.
Develop Countermeasures and Controls: This may include implementing security controls
like intrusion detection systems, contingency plans, and security protocols in the event of a
successful attack. Responses should be prioritized based on the threat with the greatest risk.
Review and Evaluate: Periodically evaluating the threat model should be done so that
updates can be made based on new risks in the threat landscape.

6.2 Threat Methodologies

There are three commonly used methodologies for threat models known as the Process for
Attack Simulation and Threat Analysis (PASTA) threat model; the Visual, Agile, and Simple
Threat (VAST) threat model; and Spoofing, Tampering, Repudiation, Information Disclosure,
Denial‑of‑service attack, and Elevation of privilege (STRIDE) threat model.
6.2.1 PASTA Threat Model

The PASTA threat model has seven stages that focus on risks and countermeasures that are
prioritized by the value of the assets being protected. The seven stages are:
1. definition of the objectives (DO) for the analysis of risks;
2. definition of the technical scope (DTS);
3. application decomposition and analysis (ADA);
4. threat analysis (TA);
5. weakness and vulnerability analysis (WVA);
6. attack modeling and simulation (AMS); and
7. risk analysis and management (RAM).
6.2.2 VAST Threat Model

The VAST threat model is based on the Agile project management methodology. Its goal is to
integrate threat management into a programming environment on a scalable basis.
6.2.3 STRIDE Threat Model

STRIDE is a threat model developed by Microsoft that is used for assessing threats related to
applications and operating systems. Its six threat concepts listed in its name are broad enough
to cover threat concerns other than applications, such as network threats or social engineering.

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2
MODULE
Mitigation of Threats
and Attacks ISC 3
1 The COSO Framework and its Relationship With Cyber

Risks and Controls
COSO is the Committee of Sponsoring

Organizations, an advisory group that provides
guidance on internal controls, fraud deterrence,
and risk management. The organization is
known for the COSO internal control framework
Function
that was created in 1992 and became an Control Environment
Operating Unit
industry-wide benchmark for internal control
Division
practices. The most recent version of the Risk Assessment
Entity Level
framework, titled COSO 2013, often refers to
the COSO cube, a three-dimensional diagram Control Activities
showing how the various elements of an
internal control system work together.
Information & Communication
COSO has also published a companion
framework to COSO 2013 for enterprise risk Monitoring Activities
management. This framework, titled COSO
2017 Enterprise Risk Management, can be
Internal Control—Integrated Framework, © 2013
used as a reference for organizations to assess Committee of Sponsoring Organizations of the
risks and to develop strategies around risk and Treadway Commission (COSO). Used with permission.
business performance.
The COSO framework classifies internal control objectives into three groups: operations,
reporting, and compliance. These groups are applicable to cybersecurity as follows:
Operational Objectives: These include performance measures and safeguards that
can help increase the likelihood that an organization’s IT assets are protected against
cybersecurity threats and fraud. They focus on the effectiveness and efficiency of
business operations.
Reporting Objectives: These objectives are related to increasing the likelihood that
cybersecurity controls are in place so that they do not affect internal and external financial
and nonfinancial reporting. The objectives have a focus on transparency, reliability,
timeliness, and trustworthiness as determined by standard-setting bodies, regulators,
and an organization’s own policies.
Compliance Objectives: These are based on adherence to governmental laws and
compliance regulations. As it relates to cybersecurity, this includes compliance with industry
standards such as those issued by NIST, U.S. regulations like the Health Insurance Portability
and Accountability Act (HIPAA), and international laws like the General Data Protection
Regulation (GDPR).
Material from Internal Control—Integrated Framework, © 2013 Committee of Sponsoring Organizations

of the Treadway Commission (COSO). Used with permission.
© Becker Professional Education Corporation. All rights reserved. Module 2 S3–17 Mit
2 Mitigation of Threats and Attacks ISC 3
There are also five components of the COSO internal control framework. These can be applied
to cybersecurity efforts to prevent, detect, and respond to cyber threats as follows:
Control Environment: The control environment is often referred to as the tone at the top
and sets ethical values for an organization by creating a top-down approach to push forward
the COSO framework throughout the organization.
y Senior management and those charged with governance should act as champions to
raise awareness of cyber threats; guide the development of key IT policies, processes,
and procedures; provide guidance on incident response management; and educate the
workforce regarding the roles of safeguarding a company’s digital assets and resources.
Risk Assessment: This component involves performing risk assessments to evaluate
internal and external factors. It can be applied to cyber threats by tailoring the organization’s
risk assessment procedures to analyze cyber risks, their likelihood of occurrence, and the
magnitude of their impact. Assessments provide reasonable assurance that organizations
are managing their cyber risks to an acceptable risk tolerance.
Control Activities: Control activities are the policies and procedures put in place to help
determine whether the tone at the top set by the control environment is being implemented
at all levels of the organization.
Information and Communication: This component focuses on using consistent and
relevant language, following best practices for sharing information, and communicating
internally and externally with the right stakeholders all to support internal controls. Sharing
information about company policies on cyber threats, how to detect potential cyber threats,
and how to respond to cybersecurity events is critical for any organization. Examples of
effective communication include:
y Business impact analysis reports reviewed by management that outline the impact of
interrupting key business functions
y Employee meetings on policies regarding cybersecurity
y Periodic emails addressing cybersecurity internal controls to the entire company
y Mandatory annual training of cyber threats and company policies
Monitoring Activities: Monitoring internal controls is the component that should be
practiced on an ongoing basis to identify areas of risk vulnerability and to determine
effectiveness and efficiencies. This is especially important for cybersecurity threats because
attacks are always evolving. Examples of monitoring practices and controls that should be in
place, evaluated, and adjusted include:
y Penetration testing
y Vulnerability scanning and assessments
y Periodic phishing reports
Looking at cyber risk through a COSO lens can allow management to better communicate
their risk tolerance levels and objectives for the business. If clear priorities are established by
management, then the employees tasked with cybersecurity can focus on assessing the risk
associated with systems most likely to be attacked, and the points of potential vulnerability in
the IT system.
S3–18 Module 2 Mitigation of

© Becker Professional Education Corporation. AllThreats and Attacks
rights reserved.
ISC 3 2 Mitigation of Threats and Attacks
2 Security Policies, Standards, and Procedures
To enhance cybersecurity defenses and enhance IT infrastructure resiliency, security rules must
be carefully coupled with technology at multiple levels of an organization. At the uppermost
level is a collection of security policies, which serves as an overview of an organization’s security
needs and strategic plan for what should be implemented.
At the next level is a set of standards that organizations use as a benchmark to accomplish
the goals defined by the security policies. At the bottom level, there are standard operating
procedures that are typically detailed documents that specifically outline how to perform
business processes. Security policies, standards, and procedures are subject to review by service
auditors in a SOC 2® engagement when the organization is a service organization.
2.1 Security Policies

Security policies are the foundation of an organization’s security framework, which serves as
a comprehensive guide for its implementation. This document outlines the extent to which
security measures are applied to various company resources. It provides clear terms, definitive
roles and responsibilities, and acceptable levels of risk. Security policies are also evidence of due
care by senior management against intrusions, attacks, and natural disasters.
Organizations often have domain-specific policies that help partition different organizational
focus points. For instance, policies may be divided into user policies that govern employee
behavior relative to IT, regulatory policies to comply with applicable laws, and system-based
policies that cover network or software. Organizations often create acceptable use policies to
govern these domains and carry out security policies.
Further examples of security policies and related processes in place by a service organization
may include the following:
Data classification and business impact assessment
Selection, documentation, and implementation of security controls
Assessment of security controls
User access authorization and provisioning
Monitoring of security controls
2.1.1 Acceptable Use Policy

An acceptable use policy (AUP) is a control document that is created by an organization to
regulate and protect technology resources by assigning varying levels of responsibilities to job
roles, listing acceptable behaviors by employees and vendors, and specifying consequences of
those who violate the AUP. Users are often asked to sign and agree to the terms of an AUP prior
to being granted access to systems, applications, and devices issued by the organization. An AUP
will generally cover the following:
Definition, scope, and purpose of the policy
Acceptable use of personal devices for business activities
Acceptable mobile devices approved for use
Device maintenance
Confidentiality
Monitoring and enforcement of actions on company devices

Restricted activities and software downloads on company devices
Software that must be installed for security purposes
Security requirements
Terms about termination if policy is violated
2.1.2 Mobile Device Security Policies

One of the greatest threats to an organization is poor management of the way mobile devices
are used by employees. As such, strict policies should be developed along with the proper
technological safeguards to channel mobile device use and interaction with a company’s
network. Having AUPs specific to mobile devices helps accomplish this.
An AUP for a mobile device is a subset of a company-wide AUP that defines policies for tablets,
smartphones, smart watches, and other similar mobile devices. Using these devices gives users
access to the same data, systems, and applications as traditional hardware such as laptops
and desktops. Mobile device AUPs usually stipulate password protection rules, multifactor
authentication requirements, any required encryption, web browsing rules, parameters for
connecting to public networks, and policies regarding other applications or file downloads on
the devices.
2.1.3 Bring-Your-Own-Device Policies

Another common mobile device policy is a bring-your-own-device (BYOD) policy, which allows
employees to use their personally owned devices for work-related activities and for connecting
directly to a company’s network. BYOD policies may include some of the same elements as
an AUP but will address the following items that are only relevant to personal devices used
for work:
Monitoring and Enforcement of Actions on Personal Devices: The extent of an
organization’s purview over an employee’s activity on personal devices will vary by company,
along with the balance of privacy and surveillance. Companies must enforce an appropriate
level of monitoring to prevent intrusion from malicious actors but also set standards for
respecting employee privacy.
Ownership of the Data on the Device: Companies will have varying stances on this but
generally they will assume that all information pertaining to company records, clients,
vendors, and contacts are property of the organization, not the employee. Rare instances
may exist in which the employee has more ownership than the company.
Personal Liability and Indemnification: BYOD policies may stipulate when an employee is
personally liable versus when liability is placed on the company. The policy may also cover
indemnification, defining who is responsible for compensating someone for losses in the
event the employee or company is assigned blame.
Restricted Activities and Application Downloads on Personal Devices: While personal
devices are property of the employee, company policies may be written so that certain
applications are disallowed to prevent data breaches, data leakage, or access to a
company’s network.
BYOD policies also apply to nonmobile devices. By allowing these in addition to mobile devices,
various risks to the organization are created. These risks include the possibility of leaking
sensitive data, breaking compliance with regulations, and providing another inlet for bad actors
to access company data.

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2.2 Security Standards

Security standards are organizational requirements that are either mandatory by law or adopted
by companies as guidelines for best practices. Standards are the next level of security rules
beneath policies that serve as a course of action to achieve security policies. Standards also
might define a minimum level of performance and may provide recommendations on how to
implement policies.
Examples of common standards include:
frameworks issued by the National Institute of Standards and Technology (NIST);
privacy laws like the General Data Protection Regulation (GDPR) issued by the European
Union; and
industry standards like the Payment Card Industry Data Security Standard (PCI DSS) issued
by the PCI Security Standards Council.
2.3 Security Standard Operating Procedures

Standard operating procedures (SOPs) are the lowest level of documentation that provide
detailed instructions on how to perform specific security tasks or controls. These SOPs usually
involve a combination of systems, software, and physical actions so that the goals of the security
policy and standards are achieved.
It is recommended to segment SOPs so that they are not all in a single document. This prevents
one person from having access to instructions for every security practice in the company.
Rather, policy owners in separate departments can own SOPs relevant to their job roles and
company functions. When policies are adjusted or need updating, policy owners can make
adjustments accordingly.
3 Network Protection Methods
3.1 Network Components

A network is a system of physical and virtual devices that are connected using wired cables or
wireless technology that communicate using a mixture of different protocols so that users can
send, receive, and store data. Protocols are sets of rules that govern how a device communicates
with other devices in a network. Some of the hardware used in a network includes:
Access Point (AP): A wireless connection point for users to directly connect to a wired
network using wireless-enabled devices.
Bridges: A bridge connects separate networks that use the same protocol, even if those
networks have different topologies or transmission speeds. Bridges operate at the data link
layer of a network.
Computers: Desktop and laptop computers are user endpoint devices that are the primary
means of user interaction with a network.
Gateway: Gateways connect multiple networks that use different protocols, translating one
protocol to another so that the two networks can interact. Gateways can operate in all layers
of a network but frequently operate in the application layer.
Hubs: Hubs are connection points that link multiple systems and devices using the same
protocol within a single network. Hubs receive data packets and forward them to all
other devices.
Mobile Phones and Tablets: Devices that are another primary means through which users
connect to a network.
Modems: Devices that modulate between digital information and an analog signal to
support networks. They are most commonly used to connect computers to the internet.
Proxies: A form of gateway that does not translate protocols but rather acts as a mediator
that performs functions on behalf of another network using the same protocol instead of
just connecting the networks.
Routers: Devices that control data flow on a network using the same protocol by
receiving incoming data packets and forwarding those to the correct destination based on
IP addresses.
Servers: Devices that support computers and networks by performing different core
functions such as running applications with application servers, storing files with a file
server, or storing data using a database server.
Signal Modifiers: Devices such as amplifiers, concentrators, and repeaters receive signals
and then modify them by increasing the signal strength, combining multiple signals, or
simply regenerating the signal. The types of signals could be electrical, radio frequency,
audio, or optical.
Switches: Similar to hubs, but instead of broadcasting received signals to every other
networked device, switches only route traffic to target destinations, connecting various
devices within a network for most modern organizations.
3.2 Network Security

There are a variety of security methods available to companies that focus specifically on network
security to defend against cyberattacks, including the following:
Network Segmentation or Isolation: The process of controlling network traffic so that
it is either inaccessible or separated from outside communications or other segments
within an organization’s own network. This form of pocketed isolation improves overall
network security.
Firewall: Firewalls are physical devices, software, or both that filter and monitor incoming
and outgoing network traffic to a public network to block malicious activity from attackers.
Service Set Identifier (SSID): The name assigned to a wireless network is known as an SSID
and is broadcast by a wireless access point within a certain range so that wireless-enabled
devices can connect. One way to improve wireless network security is to make networks
less visible by disabling SSID broadcasting so that the broadcasting device, usually a router,
stops acting as a beacon that transmits a signal to nearby devices giving the SSID name,
reducing visibility.
Virtual Private Network (VPN): A virtual network built on top of existing physical networks
that provides a means of secure communications using encryption protocols such as
tunneling or Internet Protocol Security (IPsec).
y Tunneling is a process in which the data, or packets, in one protocol are encapsulated in
packets within a different protocol, which creates a tunnel of protection.
y IPsec uses cryptography to encrypt communications, provide access control, and
authenticate using IP protocols. IPsec operates similarly to tunneling, but it can also be
used to only encrypt certain pieces of data, the payload, rather than an entire IP packet.
This level of protection gives VPN users secure remote access to company applications,
data, and systems.

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Wi-Fi Protected Access (WPA): A security protocol that encrypts traffic between a wireless
access point, such as a switch, and a mobile device. However, it does not encrypt traffic that
travels through a wired connection once it is out of the wireless access point.
y WPA’s first successor, WPA2, is a similar protocol that provides an additional layer of
data encryption using the Advanced Encryption Standard (AES) to provide even more
security for a network.
y WPA3 provides even stronger security through more sophisticated encryption, secure
handshakes (the process of establishing a connection between computers or devices),
and stronger password protections.
Endpoint Security: The notion that every device, also called hosts, connected to a network
should have some form of local security that is separate from any other security measure in
place on the network or communications channel. The following safeguards are examples of
endpoint security that should be implemented on local hosts:
y Antivirus and malware screening software
y Authentication and authorization mechanisms
y Auditing software
y Local host firewalls
y Host-based intrusion detection
y Prevention systems
System Hardening: System hardening is a multipronged comprehensive security approach
that reduces risk by minimizing the number of access points through which a company can
be attacked. These access points are referred to as attack vectors and include all aspects
of IT infrastructure, including applications, databases, operating systems, servers, and
networking equipment. This gives attackers fewer opportunities to access and infiltrate an
IT system.
y Examples of system hardening in the context of potential recommendations after a
vulnerability scan by an IT consulting agency may include:
—Database Hardening: Create different privilege levels so that there is a clear
delineation between admin users and users that have tiered need-to-know access.
Also, data at rest needs to be encrypted.
—Endpoint Hardening: Remove administrative rights for users on local devices so
that endpoint users can only perform authorized functions. Restrict users from
downloading certain files from the internet or email. Implement local firewalls and
malware screening on all laptops. These hardening adjustments make it harder for
users to inadvertently compromise the network.
—Network Hardening: Revise the rules for the firewall so that it is configured to
remove unused ports and block unnecessary protocols. This provides attackers with
fewer options to infiltrate the network.
—Server Hardening: Physically segregate servers in a secure facility, further separating
backup servers geographically. If one server or group is attacked, not all will be
compromised. Develop test procedures for servers connecting to the network for the
first time, to increase the likelihood that administrative rights are set up properly.
Perform tests on servers in operation after business hours to minimize functionality
and service disruption.
Media Access Control (MAC) Filtering: This is a form of filtering in which an access point
blocks access to unauthorized devices using a list of approved MAC addresses. A MAC
address, also referred to as a physical or hardware address, is a unique identifier found on
devices in a network that is used as an address for communicating with other devices on
that network.
3.2.1 Service Auditor Consideration of Logical and Physical Access

Service auditors conducting a SOC 2® engagement may consider a company’s organization
controls related to network components in a scenario where the organization permits remote
access by authorized employees only with multifactor authentication over an encrypted virtual
private network connection. The service auditor would observe a remote login session to
determine that the multifactor authentication over the virtual private network was required to
access the network.
4 Authorization and Authentication
4.1 Authorization and Authentication in Security Operations

In addition to employing advanced cybersecurity applications and devices, organizations must
also implement practices that complement these defense tools to thwart evolving threats. Some
of the more prevalent practices include zero trust, least privilege, the need-to-know principle,
and whitelisting. These concepts can be engineered into the architecture of an organization’s
IT and embedded in its policies.
4.1.1 Zero Trust

The concept of zero trust assumes that a company’s network is always at risk, even after a user
has been authenticated, and it shifts a company’s cybersecurity focus away from one-time
authentication to continuous validation at every point of a user’s interaction with a network.
The National Institute of Standards and Technology (NIST) established the Zero Trust Network
Architecture (ZTNA) model to help organizations implement continuous authentication principles
through a zero-trust architecture (ZTA).
ZTA is designed to prevent data breaches and limit internal lateral movement by implementing
a set of system design principles and a coordinated cybersecurity and system management
strategy based on an acknowledgment that threats exist both inside and outside traditional
network boundaries. The zero-trust security model eliminates implicit trust in any one element
and instead requires continuous verification by focusing on users, assets, and resources in real
time to determine access and other system responses.
While there are variations of ZTA outlined by NIST, the overarching tenets include the following:
All devices and data sources are considered resources, even those not directly managed by
the organization.
All communications must be secure regardless of a network’s location.
Access to company resources is granted on a per-session basis.

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Access is determined by using dynamic policies and other environmental or behavioral

attributes.
The company monitors and measures the integrity and security of all assets.
All authorization and authentication mechanisms are dynamic and strictly enforced prior to
granting access.
Detailed information is collected about the current state of a company’s assets,
infrastructure, and communications to improve security.
NIST provides the following assumptions to implement the ZTA tenets:
An organization’s private network is not considered an implicit trust zone.
Some devices on a company’s network might not be owned or configurable by the company.
No resource is inherently trusted.
Some devices connecting to a company’s infrastructure might not be company resources.
Remote users should not trust local network connections.
Workflows and assets involving several components of a company’s infrastructure should
have consistent security policies and structure.
4.1.2 Least Privilege

Least privilege is the notion that users and systems are granted the minimum authorization
and system resources needed to perform a function. IT administrators should put safeguards
in place so that privileges do not become excessive or allow privilege creep in which access to
systems gradually increases over time as a person’s job role evolves. This is common when an
employee gets promoted or changes positions within the same company. System permissions
are granted with the new role, but access from the prior role is never removed. This violates the
concept of least privilege.
4.1.3 Need-to-Know
The need-to-know principle follows the idea that employees are only given what they must know
to perform their job. The difference between need-to-know and least privilege is that need-
to-know focuses on the data itself that is needed to perform the job, whereas least privilege
focuses on the access needed to perform the job.
4.1.4 Whitelisting
Whitelisting is the process of identifying a list of applications that are authorized to run on an
organization’s systems and only allowing those programs to execute. Similarly, blacklisting is
identifying a list of applications not authorized on a network and preventing those from running.
These rules are enforced by automated software programs designed to prevent applications
from executing unless they are on the whitelist.
5 Identification and Authentication Techniques
5.1 Identification and Authentication

Identification and authentication are two separate concepts that occur in one multistep
process when users validate their right to access systems, applications, or physical locations.
Identification is the process of claiming or asserting one’s identity, through means such as a
username or identification card, and authentication is the process of validating that identity
claim, which could be done by using a password or scanning identification cards with proprietary
technology. First, a person’s identity is claimed, and then it is authenticated.
Prior to establishing an identity to later be validated, a user must go through an initial
registration process in which the user creates the identity. This is typically done by submitting
the most foundational form of identification, such as social security cards in the United States,
driver's licenses, or passports. Then secondary forms of identity can be created using that
foundational identification.
5.2 Authentication Technologies

The most common forms of identification and authentication are usernames and passwords,
respectively. However, there are various authentication technologies available to secure access
to confidential data, applications, and networks, including the following:
Context-aware Authentication: This form of authentication is used to identify mobile
device users by using contextual data points such as time, geographic location of the user,
point of access (mobile app, desktop browser, call center, etc.), or IP address.
Digital Signatures: A digital signature is an electronic stamp of authentication that is
usually encrypted and attached to a message for non-repudiation (proof of identity). These
utilize cryptography, with the sender encrypting the message with a private key and the
receiver decrypting the message with the sender’s public key.
Single Sign-On (SSO): A single sign-on (SSO) is a technique that allows users to authenticate
one time for a single session using multiple resources or devices.
y For instance, logging into an app on a smart TV may only require entering a one-time
code displayed on the TV on an approved smartphone. This authenticates the user
without requiring them to authenticate again during the session.
Multifactor Authentication: This is an authentication method that uses two or more
factors to validate someone’s identity. It often combines knowledge with possession. For
instance, a password is knowledge and a security fob with a changing PIN is a possession.
Personal Identification Numbers (PIN): A PIN is a numeric code that a cardholder
memorizes and uses as part of authenticating their identity. PINs are most effective when
combined with other authentication factors, with the PIN serving as the factor the user
knows and a physical device, token generator, or other factor as something that the user
possesses. PINs should be changed regularly, not be duplicated across applications, be at
least six characters, and have limited entry attempts.
Smart Cards: These are plastic cards containing a microprocessor that enables the holder
to process data or that acts as a certificate that can be used to purchase goods and services,
enter restricted areas, or execute other activities that only the holder of the smart card
can perform.

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Token: These are devices that generate fixed-digit passcodes that are carried with users as
a form of multifactor or secondary authentication mechanism. The passcodes generated
by the token are also stored on an authentication server so that when a passcode is
entered for validation, it is confirmed against the server. Tokens may be synchronous
or asynchronous.
y Synchronous tokens are time-based and require the token and server to be
synchronized so that they register with the same number at the time of validation.
y Asynchronous tokens do not use clocks, but rather they create passcodes based on the
same algorithm.
Biometrics: This is an authentication technique that uses human physical characteristics or
impressions to verify identity.
y Common physical characteristics used for validation include facial recognition,
fingerprint or palm scans, hand dimensions, voice recognition, iris or retina scans, heart
or pulse patters, keystroke patterns, and handwriting or signature dynamics.
5.3 Password Management

Strong password management is critical because it is both the most common form of
authentication and the most common method of attack for attackers. Passwords can be in the
form of a string of letters, numbers, or special characters. Despite being the most common form
of authentication, passwords have the following weaknesses, some of which can be avoided.
People often use passwords that are easily guessed, reuse passwords for multiple accounts,
share passwords with others, never change passwords, or write down passwords because
they are difficult to remember.
Short passwords can be easily guessed by brute-force attacks, which are attacks used
by attackers that perform rapid-fire password entry attempts that use all possible
combinations of words and letters until the right combination is reached.
Passwords saved by companies in databases accessible by the web are frequently breached
by attackers.
To counter these weaknesses, password complexity standards are recommended.
5.3.1 Password Complexity

The longer a password is, the more secure it is. This is based on the notion that guessing the
correct combination of characters in a password becomes exponentially more time consuming
when the number of characters is increased due to the number of potential combinations. For
instance, a password that has only four characters can use all 26 letters (both upper and lower
case) and digits zero through nine would result in 14,776,336 potential combinations. Increasing
the number of characters to eight results in 218,340,105,584,896 combinations, which displays
the added security of adding just four characters to a four-digit password.
NIST recommends having at least eight characters in a password per its standard, NIST Special
Publication 800-63B, but many companies require 12 or more characters. Changing passwords
frequently is also recommended and passwords are encouraged to be changed every 45 to
90 days.
5.3.2 Password Managers and Storage

Password storage and management applications are programs that store a user’s passwords
by using hashing rather than storing them as plaintext. Hashing is the process of converting
passwords into illegible text using hash algorithms such as secure hash algorithms (SHAs).
Hashed passwords are then stored in databases, and when a user enters a password, the
hashing algorithm is computed using that word. The computed hash value is compared to the
hash value stored in the database. If the two match, access is granted.
Hashed passwords are one-way, meaning they are not intended to be reversed, although it is
possible. So, if an attacker gains access to a password database that only has hashed passwords,
they must first determine which hashing algorithm was used. Then they can begin guessing,
typically by using brute-force guessing software, which can then be converted to hash values
and compared to the hash values in the database.
5.4 Provisioning
Provisioning is the process in identity management when an organization creates a user’s
account and provisions it with privileges based on their job role. This is often an automated yet
protected process but it is critical in creating a valid identification that can be authenticated. It
may be part of the employee onboarding process when other identification and background
checks are performed, and no rights should be provisioned to individuals that do not meet
company standards.
Prior to issuing system credentials and granting system access, the organization may register
and authorize new internal and external users whose access is administered by the organization.
For those users whose access is administered by the organization, user system credentials need
to be removed when user access is no longer authorized.
In the context of a SOC 2® engagement, service auditors may inspect access request forms
for a sample of new employees who received access to in-scope system components during a
specified period. This procedure would be performed to determine that an access provisioning
request was approved prior to access being provisioned.
5.5 Device Authentication

Validating a user’s identity by verifying the device making a connection request is known as
device authentication. The emphasis is not placed on the credentials or identity of the user, but
rather the identity of a device, such as a unique IP address or MAC address. This technique is
weak as a standalone authentication method but strengthens a multifactor approach in which a
user is required to enter login credentials and use a valid device.

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6 Definition and Purpose of Vulnerability Management
6.1 Vulnerability Management

Vulnerability management is a proactive security practice designed to prevent the exploitation
of IT vulnerabilities that could potentially harm a system or organization. The practice
involves identifying, classifying, mitigating, and fixing known vulnerabilities within a system.
It is an integral part of computer and network security and plays an important role in IT
risk management.
To meet its objectives, an organization may use detection and monitoring procedures to
identify changes to configurations that result in the introduction of new vulnerabilities and
susceptibilities to newly discovered vulnerabilities. An organization may also conduct periodic
vulnerability scans designed to identify potential vulnerabilities or misconfigurations after any
significant change in the environment. Subsequently, the organization should take action to
remediate identified deficiencies on a timely basis.
6.2 Vulnerability Tools

Vulnerability management can be administered using tools such as vulnerability assessments
and vulnerability scanners, as well as through the application of frameworks, such as the
National Institute of Standards and Technology (NIST) Cybersecurity Framework.
6.2.1 Applying the NIST Cybersecurity Framework

The NIST Cybersecurity Framework (CSF) is often used in implementing vulnerability
management solutions to achieve desired security results. The framework can be applied using
its five functions as follows:
Identify: Use the CSF to identify resource vulnerabilities that are present in systems, data,
assets, and employees. Apply the framework to understand the business environment
in which those assets operate, and understand the policies established regarding those
resources to define how governance is executed.
Protect: Apply the framework to create safeguards against vulnerabilities by establishing
measures to manage identity and access controls, keep assets secure, and inform
employees of threats.
Detect: Use the framework to define relevant activities that can identify vulnerabilities
quickly. These activities may include searching for anomalies, performing continuous
monitoring, and verifying that the results of protective measures are effective.
Respond: Use the CSF to put activities in place that will react to discovered vulnerabilities.
This may include analysis of the issue so that the appropriate response is delivered,
executing mitigating activities to prevent the vulnerability from affecting other parts of
the organization, and communicating to the organization what the issue is as well as the
chosen response.
Recover: This function of the framework can be used to help an organization transition
from its current state in which the vulnerability exists to a state where the vulnerability is
mitigated. Relevant activities may involve implementing a recovery plan, improvements, and
delivering internal communications to the appropriate staff about the recovery.
6.2.2 Vulnerability Scanners

Vulnerability scanners are applications that test a company’s systems for known security risks.
The scanner works by checking results against a database of known threats. This database
is periodically updated so that it is current with the most recent threats. Scanners work by
scanning for open network ports that can be exploited, analyzing data packets transmitting
across systems, identifying protocols being used, and fingerprinting, which identifies the type of
operating system and application running on the victim’s systems.
These same scanners can also be used against organizations by attackers to identify weaknesses
and then exploit those weaknesses. Attackers often wait to launch attack campaigns after
databases are updated and rolled out to customers. With some larger companies, updates are
predictable, which makes this form of attack more dangerous because attackers can plan and be
ready as soon as the update is announced.
6.2.3 Vulnerability Assessments

Vulnerability assessments are typically done as a part of an initial risk analysis, and then
subsequently performed quarterly or annually after that. Vulnerability scanners are often used
in these assessments and observed over time to determine whether certain threats still linger.
In some cases, a company may not be able to implement a solution because it could hinder
operations. Instead, the company continues to operate exposed until there is a solution that
allows the company to both mitigate the vulnerability and operate in an efficient manner.
While there is significant value in the results of the assessment, there are also other ancillary
benefits to the organization from going through the assessment process. This is because
assessments involve observations of multiple IT processes and interviews with employees across
the organization that may not normally be evaluated collectively. This aggregate view of the
company allows management the opportunity to see how systems or processes in one part of
the organization create vulnerabilities in other parts.
6.3 Common Vulnerabilities and Exposures Dictionary

The Common Vulnerabilities and Exposures (CVE) dictionary is a database of security
vulnerabilities that provides unique identifiers for different vulnerabilities and risk exposures.
As new vulnerabilities are discovered, they are added to the dictionary by the MITRE
Corporation, which is the organization that maintains the dictionary.
The CVE dictionary helps standardize the recognition and naming of vulnerabilities that were
once identified by various companies using differing names or descriptions. This made it difficult
to manage security gaps because, prior to the CVE, there was often no effective vulnerability
dictionary that companies could use in the effort to fight cyber threats. Now, CVE identifiers are
used by various cybersecurity products and denoted as “CVE-Compatible” so that customers
know the vulnerabilities that have been mitigated.
6.4 Patch Management

Patch management is an important part of minimizing security threats that works in conjunction
with vulnerability management solutions. As bugs are discovered in applications, software
vendors release updates, called patches, so that customers can correct those vulnerabilities.
Effective patch management involves IT administrators assessing the update for applicability to
their company, testing the patch on isolated systems, planning with management to implement
the patch, deploying the patch, and validating that it was successfully implemented.
Service organizations may be expected to maintain a change management log and the
patch management process is normally subject to inspection by service auditors during a
SOC 2® engagement.

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7 Layered Security in Cyberdefense
The purpose of layered security is to protect an organization by using a diversified set of security
tactics so that a single cyberattack or security vulnerability does not compromise an entire
system. Layered approaches typically combine physical access controls, logical and technical
controls, and administrative controls to provide control redundancy. These redundancies
are implemented to offset possible security defects that could arise in the event of a
multipronged breach.
7.1 Defense-in-Depth
One of the most common layered security solutions is the defense-in-depth cybersecurity
strategy. It focuses on a multilayered security approach that does not rely on technology alone,
but rather it combines people, policies, technology, as well as both physical and logical access
controls. These layers contribute to the defense-in-depth strategy as follows:
Personnel: Organizations must have experts that can operate security functions and tools
effectively to attempt to make sure multilayered defenses are effectively implemented.
In some cases, only specific IT professionals will have the expertise to understand how all
layers interact holistically.
Policies: While technology is critical, policies governing how that technology should be used
must also be created, implemented, and monitored over time to determine whether tools in
place are working as designed.
Technology: Technical controls applied in a defense-in-depth strategy include security
solutions like intrusion detection and prevention systems, antivirus software, firewalls, and
endpoint security.
Physical Access Controls: This includes security measures like cameras, gates, locks,
fences, badge-controlled access, and restricted access to climate-controlled devices.
Logical Access Controls: These are rule-based controls that are carried out by software
and hardware designed to prevent unauthorized access. Such controls are embedded
in user authentication systems and software that require validation of identity through
login credentials, multifactor authentication, and different permission-based logical
access methods.
7.2 Redundancy and Diversification

Regardless of the type of layered security solution chosen, using two or more means of security to
protect the same resource offers organizations additional, yet different, protective measures in the
event that one layer fails. This eliminates having a single point of failure. Redundancy and diversity
also help organizations counterattacks that target different weaknesses an organization might have.
Having duplication within duplication introduces even more security. For instance, a company’s
layered security solution may have a single process that is coupled with one access control.
By further bifurcating either the process or the access control by introducing another person to
perform one function, the overall security becomes more diverse and potentially more effective.
This form of redundancy can be administered through:
layering processes;
isolating processes;
concealing data; and
segmenting hardware.
7.2.1 Process Layering and Isolation

Layering processes adds redundancy by breaking up an operation into smaller chunks that can
be managed by different people, performed by a machine or computer, or completely isolated
from other parts of the process. This may be done to protect critical pieces of an operation or
sensitive information so that certain components are more protected than less important pieces
of the process.
For instance, a bank may have one person grant access to a vault remotely, while another
person physically removes the contents of the vault, while yet another person transports the
contents to another branch, with all participants counting or reconciling the contents with the
other employees.
Process isolation using a machine or computer involves segmenting processes using logical
controls to form memory access constraints. Each process is allocated a portion of memory, or
space, on that machine so processes run separately. This is done so that one process cannot
influence another.
7.2.2 Abstraction and Concealment

Abstraction is the process of hiding the complexity of certain tasks so that only the relevant
information to a specific person performing a function is presented. The primary intent of
abstraction is to simplify complex tasks, but it also plays an important role in cybersecurity by
limiting user access so they are only given access to the level of detail needed to perform the
job. For instance, access controls and user rights may be assigned to a particular object, group
of objects, or a type of privilege allowing a user to only access and perform certain functions.
This allows security administrators to easily create and assign different levels of privileges to
each user. Abstraction can be applied to both applications and networks in either cloud-based
environments or locally managed environments.
Concealment is similar to abstraction, but its primary focus is on hiding data, whereas
abstraction focuses more on removing underlying details so that only essential information is
available to help the user manage a task more efficiently and more securely. Concealment is
implemented by assigning users to a security level that must align with the same security level
assigned to specific sets of data, sections of applications, or certain objects so that only those
who need access get it.
7.2.3 Hardware Segmentation

Hardware segmentation achieves the same goal as process isolation, but instead of enforcing
separation logically, it is enforced physically with separate machines. This form of segmentation
is not as common, but when it is used, it is typically applied to large organizations with a network
that is distributed geographically.

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8 Common Preventive, Detective, or Corrective Controls
Well-designed cybersecurity controls include policies, procedures, and technology that mitigate
threats at all points of discovery and all stages of a counterattack. These controls can be
grouped into the following categories: preventive controls, detective controls, and corrective
controls. Authorization is defined by SOC 2® engagement guidance as the process of granting
access privileges to a user, program, or process by a person who has authority to grant
such access.
8.1 Preventive Controls

Preventive controls are designed to thwart malicious activity from ever occurring. They attempt
to prevent attackers from accessing devices, applications, and networks by employing some of
the following tactics:
Safeguarding Practices: Strong preventive software and hardware controls should be
coupled with well-designed policies and procedures, such as requiring strong passwords,
using multifactor authentication, performing background checks, locking devices if
unattended, and following strict guidelines regarding sensitive data.
Education and Training: Informing employees about cybersecurity risks and the corporate
tools in place to mitigate those risks serves as a preventive control that complements
technical safeguards that have been deployed.
Regular Security Updates: Broad and comprehensive security enhancements should
occur regularly in order for an organization’s physical and logical security measures to be
protected against the latest cybersecurity threats.
Encryption: Encrypting data both at rest and in transit involves the process of converting
the data into an illegible format based on industry standards so that if the data is
comprised or stolen, the hackers will not be able to decipher and use the data for any
nefarious purposes.
Firewalls: A firewall monitors and filters traffic based on a set of predefined rules so that
only trusted parties and networks can connect or interact with an organization’s network,
which prevents threat actors from compromising the network.
Patches: A patch is an update or modification to an existing software program that is
typically released by an application’s creator and serves as both a preventive and corrective
control that is intended to resolve newly discovered design flaws, operating errors, or gaps
that pose cybersecurity risks.
Physical Barriers: Tangible barriers, or physical obstructions, are controls that are
designed to both deter and prevent unauthorized physical access to an organization’s IT
infrastructure. Examples include locked doors and cabinets, access controls such as a badge
entry system, security guards, fences, gates, and surveillance systems.
Device and Software Hardening: Hardening refers to implementing security tools so
that the totality of vulnerable points, or the surfaces that can be attacked, are reduced.
Minimizing the number of vulnerabilities across hardware devices and software applications
prevents some attacks from occurring.
Intrusion Prevention Systems (IPS): An IPS is a network security solution that is intended
to detect and stop a cyberattack before it reaches the targeted systems. It does this by
receiving a direct feed of traffic so that all data coming into a network pass through the IPS,
similar to a firewall.
8.1.1 Access Controls—Authorization Models

Access controls are security measures organizations put in place to allow access only to
authorized employees. These controls can be applied as discretionary access controls, role-
based access controls, rule-based access controls, policy-based access controls, and risk-
adaptive access controls.
A discretionary access control (DAC) is a decentralized control that allows data owners,
custodians, or creators to manage their own access to the data or object they own or created.
With discretionary controls, owners can grant access to others based on their own judgment or
delegate tasks to other custodians as the owner sees fit. Some other functions that a data owner
enforcing a DAC can enforce include the following:
Control the passing of information to other users or objects.
Grant or change the security attributes of users.
Choose the security attributes to be associated with newly created or revised objects.
Change the rules governing access control.
In contrast, mandatory access controls are nondiscretionary controls that allow administrators
to centrally manage and enforce rules consistently across an environment. This means access is
not based on identity but rather on a general set of rules that governs the entire system. While
nondiscretionary systems may be easier to manage, their limited set of rules makes them less
flexible in terms of customization.
Role-based access controls administer access based on a user’s job role instead of individually
assigning permissions. Job roles are placed in categories that correspond with a specific level
of access or privilege. If a user changes positions, the access level is then modified based on
preexisting rules for that job role.
A rule-based access control manages access to areas, devices, or databases according to a
predetermined set of rules or access permissions independent of the user’s role or position
within the organization. An administrator is tasked with setting the security permissions to allow
access based on defined criteria.
The steps in the rule-based access control are:
Access rules are created by the system administrator.
Rules are integrated throughout the access control system.
A user presents their access credentials.
The control mechanism checks their credentials against the access rules.
The user is either granted or denied access.

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A policy-based access control (PBAC) uses a combination of user roles and policies consisting
of rules to maintain and evaluate user access dynamically. PBAC is more like a framework to
evaluate a user’s access based on what is known about that user, such as their identity, role,
clearance, operational need, and risk.
Policy-based controls are generally more flexible than rule-based controls because they allow
for the analysis of theoretical privileges based on actual privileges. As organizations grow and
policies change, PBACs can better accommodate the needs of a wider range of access control.
Smaller organizations may be better suited to apply rule-based controls if there are only a few
simple and fixed rules that need to be applied.
Risk-based access controls apply controls based on the risk level of the asset being accessed,
the identity of the user, the intentions of accessing the asset, and the security risk that
exists between the user and the system or asset being accessed. If high-risk systems are
being accessed, they usually will have stricter security measures in place such as multifactor
authentication, whereas lower-risk scenarios may only require a password.
8.1.2 Access Controls—Authorization Model Controls Used for Implementation

There are different control mechanisms that can be used to implement authorization model
policies, including access control lists, access restrictions, and physical barriers.
An access control list (ACL) is a list of rules that outlines which users have permission to access
certain resources, such as a file, folder, directory, or other IT resource. An ACL also administers
account restrictions, which govern what type of action the user can execute using those
resources, such as the ability to edit a file, apply read-only status, or execute a program. Access
and account restrictions are enforced by controlling network traffic based on the rules defined
in the ACL.
ACLs can be broad and filter all of an organization’s network traffic, or they can be more focused
and only filter access to specific files or directories for different users. These two types of ACL
are defined as follows:
Filesystem ACL: These ACLs grant or deny privileges in an operating system by restricting
access to certain files, folders, and directories.
Networking ACL: These ACLs are used to regulate the type of network traffic that is allowed
to flow across a network by configuring routers, switches, and other network devices with
an array of lists to enforce. Networking ACLs are not only used for controlling access, but
also for improving network performance by restricting or channeling the flow of data.
Filesystem and networking ACLs can operate by identifying and controlling traffic using a variety
of mechanisms and technologies.
ACLs are similar to firewalls in that they both filter traffic on a network, but the two are different
in terms of their purpose and the way they function. ACLs are generally used to manage
user access and permissions, whereas firewalls are intended to protect an organization from
malicious attacks. Unless an ACL is “stateful,” meaning it monitors the state of network traffic
to evaluate details such as source and destination addresses, it does not have the ability
to recognize where a data packet originated or other details about the connection to apply
restrictions, whereas a firewall does. Stateful ACLs track the status of network connections as
well as distinguish between legitimate packets that it allows to make connections and illegitimate
packets that do not match known connections.
8.2 Detective Controls

Detective controls are designed to detect a threat event while it is occurring and provide
assistance during investigations and audits after the event has occurred. Examples of detective
controls include:
Network Intrusion Detection System (NIDS): An NIDS is a security solution that monitors
incoming traffic on all devices on a network by matching specific elements of that traffic to a
library of known attacks and sending system alerts when events meeting predefined criteria
are detected.
Antivirus Software Monitoring: Antivirus software works by scanning files in real time and
comparing them to a library of known viruses. Scheduled scans of systems should occur
automatically and be performed on a regular basis. If viruses are detected, they should be
removed, or at least quarantined, immediately. Viruses that can only be quarantined and
not removed will require further action by the responsible IT personnel.
Network Monitoring Tools: There are various tools available to monitor a network, such
as packet sniffers, which analyze data packets being transmitted on a network; network
performance monitoring (NPM) tools that measure network statistics (such as packet loss,
system uptime, and availability); or Simple Network Management Protocol (SNMP), which is
also used to measure network statistics and error rates.
Log Analysis: Performing a log analysis involves the recording and monitoring of data to
analyze it so that anomalies, trends, or patterns can be detected that may indicate that
unauthorized events have occurred. This can be a manual or automated process.
Intrusion Detection Systems (IDS): An IDS is a security solution that scans the
environment to monitor and analyze network or system events for the purpose of finding
and providing real-time or near real-time warnings of attempts to access system resources
in an unauthorized manner. The key difference between an IDS and an IPS is that an IDS
only detects an attack after it has started, but it is unable to prevent it.
Intrusion detection systems are used by organizations to provide continuous monitoring of the
client’s network and prevention of potential security breaches. A service auditor within the scope
of a SOC 2® engagement may inspect intrusion detection system configurations to determine
that continuous monitoring of the client’s network was in place and that early prevention of
potential security breaches was also in place.

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8.3 Corrective Controls

Corrective controls are intended to fix known vulnerabilities as a result of recent security
incidents, security self-assessments, or changes in industry practices. These controls become
preventive or detective once they are put in place and operating effectively. Examples of
corrective controls include:
Reconfigurations: Modifying an application or system configuration to rectify known
vulnerabilities can restore affected operations and prevent further damage. Examples
include revamping firewall rules, retooling an operating system’s settings, and altering
access control settings.
Upgrades and Patches: Security patches and software or application upgrades may be
implemented to accomplish objectives such as enhancing system performance, adding new
features, and plugging holes in a company’s security.
Revised Policies and Procedures: Periodically reviewing and revising organizational
practices can eliminate some security issues without requiring the purchase of new
technology or the modification of existing systems. Revisions may be as simple as splitting
one job into two, adding an additional level of review, or changing the way in which sensitive
data is handled.
Updated Employee Training: Gaps in employee knowledge about the risk of certain
cyberattacks and other forms of IT exploitation can be reduced or even eliminated by
training employees to recognize the hallmarks of common fraud schemes, educating them
on how to react when suspected fraud occurs, and teaching them how to change existing
behavior to prevent future incidents.
Recovery and Continuity Plans: Organizations should have a robust plan in place that
quickly allows them to recover from a disaster or attack and continue operating so that the
period in which normal business operations are interrupted is minimized.
Antivirus Software Removal of Malicious Viruses: Most modern antivirus programs are
designed to not only identify actual or potential viruses but also to expunge those viruses so
that they are no longer a threat to the organization.
Virus Quarantining: Isolating actual or suspected viruses removes the threat from the
rest of a company’s network and is usually accomplished in an automated manner via
antivirus software or manually after suspicious activity has been flagged from the review of
system logs.
NOTES

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3
MODULE
Security Testing ISC 3
1 Security Assessments
Protecting the organization against cyberattacks is a critical part in achieving the goals of internal
control. To effectively manage cyber risks, it is critical to follow the established risk management
framework and assess and respond to threats on a continuous basis.
1.1 Risk Management Framework

Managing risk in an organization requires intricate planning and participation at all levels, from
senior management to frontline employees. The National Institute of Standards and Technology
(NIST) provides a framework for managing this risk in NIST Special Publication 800‑39.
The framework outlines a comprehensive process to manage risk by applying the following
four components:
Risk Framework: This involves defining, or framing, the environment in which
risk‑based decisions are made. The purpose of this component is to form a strategy that
enables a company to assess, respond, and monitor risk. The framework requires that
companies identify:
y Risk assumptions
y Risk constraints
y Risk tolerance
y Priorities and trade-offs
Assess Risk: This component addresses the way companies assess risk in the context of the
risk framework. The goal is to identify:
y Threats to nations, organizations, individuals, assets, or operations
y Vulnerabilities internal and external to organizations and entities
y The harm that may occur given the potential for threats exploiting vulnerabilities
y The likelihood that harm will occur
Respond to Risk: The purpose of this component is to provide a consistent,
organization‑wide response based on the risk assessment results by:
y Developing alternative courses of action for responding to risk
y Evaluating the alternative courses of action
y Determining appropriate courses of action consistent with organizational risk tolerance
y Implementing risk responses based on the selected courses of action

3 Security Testing ISC 3
Monitor Risk: The purpose of this component is to evaluate and monitor risk over time by:
y Determining the ongoing effectiveness of risk responses
y Identifying risk-impacting changes to organizational information systems and the
environments in which the systems operate
y Verifying that planned risk responses are implemented and that information security
requirements derived from, and traceable to, organizational missions/business
functions, federal legislation, directives, regulations, policies, standards, and guidelines
are satisfied
1.2 Security Assessment Engagements and Reporting

Security assessment engagements involve organizations addressing the second component
of the risk management framework, which includes performing a risk assessment and
testing controls to obtain data on the company’s current state regarding information security
capabilities. These engagements often result in the issuance of a Security Assessment Report
(SAR) to management.
The fundamentals of how to perform an assessment as well as the key elements presented in a
SAR are outlined extensively by the NIST in Special Publications 800-39 and 800-53A Rev 5.
1.2.1 Security Assessment Engagement Procedures

The first step in a security assessment engagement is defining assessment procedures, which is
a set of objectives that have assessment objects and methods. An assessment object identifies
the items being assessed as part of a specific control such as security specifications or job roles,
whereas the methods define the nature of the actions to take. Assessment methods include
the following:
Examination: This is the process of analyzing, observing, and reviewing one or more
assessment objects (job roles, security specifications, security activities, or relevant
operational activities).
Interviewing: This method involves having individual or group discussions to better
understand, collect, and evaluate evidence.
Testing: This method is the process of testing assessment objects that reflect how the
object performs in its current state compared to a target or expected state.
Organizations must support these assessment methods by identifying the following:
Tools, techniques, and methodologies needed to assess risk
Risk assessment assumptions
Constraints
Roles and responsibilities
Assessment data collection and processing methods
Communication methods to the organization
How assessments are conducted
Frequency of assessments
Sources and methods of collecting data on threats
S3–40 Module 3 Security

© Becker Professional Education Corporation. All rights Testing
reserved.
ISC 3 3 Security Testing
1.2.2 Security Assessment Reports

Security assessment reports (SARs) are issued as evidence of controls complying, or not
complying, with stated security goals and objectives. The NIST defines a security assessment
report as a report that provides a disciplined and structured approach for documenting the
findings of the assessor and the recommendations for correcting any identified issues or
vulnerabilities in the security controls.
Assessment reports generally include detailed assessment findings as well as a summary
that are used to determine the effectiveness of privacy and security controls. Determination
statements are made throughout the report that assign a grade to each procedure performed
by an assessor resulting in either a “satisfied (S)” or “other than satisfied (O)” rating.
A "satisfied” rating indicates the assessment objective was met and yielded an acceptable result.
An “other than satisfied” rating indicates that an assessor could not obtain sufficient information
that met the statements in the assessment procedure. This may be the result of either an
anomaly in the operation or the implementation of a control.
SARs generally include the following key items:
Summary of Findings: This introductory portion of a SAR has a synopsis of key findings and
recommended actions to address weaknesses or deficiencies.
System Overview: The overview of a SAR outlines the information management system
being assessed, including hardware, software, personnel, and other relevant resources.
Assessment Methodology: This part of a SAR explains the techniques and procedures
utilized to perform the assessment.
Security Assessment Findings: The findings section of a SAR discusses the gaps and
deficiencies discovered during the assessment.
Recommendations: This portion of the report provides prescriptive direction to remediate
the deficiencies that were discovered.
Action Plan: This final section of a SAR is a roadmap that covers the steps that should be
taken to remediate the deficiencies.
Illustration 1 SAR Findings: Issue Documentation
Reference: IA-XXX1
Risk Level: (Risk Level is High, Moderate, or Low)
Moderate
Ease-of-Fix: (Ease-of-Fix is Easy, Moderately Difficult, Very Difficult, or No Known Fix)
Easy
Estimated Work Effort: (Estimated Work Effort is Minimal, Moderate, Substantial, or
Unknown; or a time estimate based on level of commitment and an adequate skill set)
Moderate
(continued)

(continued)
Description
ABC Co.’s “Identify and Access Management Policy,” specifically Appendix A, establishes
password management standards for authenticating ABC’s system users based on level
of assurance, system interface type, and impact to the company.
Scope
Operating systems
Microsoft 365 Suite
Accounts payable automation
Enterprise resource planning
Human resources information system
Project management
Billing system
Aurora databases
Findings: Other than satisfied (O)
The assessment team continued to identify multiple password management
vulnerabilities. For example, we continued to find a significant number of weak
passwords on major databases, applications, and networking devices at most of ABC’s
facilities.
Additionally, password parameter settings for network domains, databases, key financial
applications, and servers were not consistently configured to enforce the company’s
password policy standards. Even though some improvements have been made, we
continue to identify security weaknesses that were not remediated from prior years.
Many of these weaknesses can be attributed to ABC’s ineffective enforcement of
its company-wide information security risk management program and ineffective
communication from senior management to the individual offices. The use of weak
passwords is a well-known security vulnerability that allows malicious users to easily gain
unauthorized access to mission-critical systems.
Recommended Corrective Action(s):
The assessment team recommended the chief information manager implement
mechanisms to enforce company password policies and standards on all operating
systems, databases, applications, and network devices.
Status: Corrective action needs to be executed
1.3 Security Assessment Evaluators

Security assessments are conducted by system auditors, developers, assessors, inspectors
general, system integrators, or other system owners. If an assessment is being performed so
others can have assurance regarding the operations and assertions made by a company, it
usually means the AICPA’s Service Organization Control (SOC) standards apply. For instance, a
managed services provider (MSP) that provides information technology as a service may get a
SOC report issued to give its clients assurance that its operations meet the standards claimed
by management.

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1.4 Security Assessment Process

The focus of the assessment process is to gather information to make objective conclusions
about an organization’s security and privacy controls in a cost-effective manner. This is done by
considering the quality and maturity of a company’s risk management process, and then tailor
the assessment using the concepts, methods, and control objectives available in standards such
as NIST 800-53A Rev 5.
The results of the assessments help organizations:
Identify potential deficiencies in their risk management processes
Identify security and privacy-related deficiencies in the security system’s environment, then
determine the appropriate responses
Prioritize the responses to risks
Support monitoring activities and system authorization decisions
Inform budgeting and investing decision makers
1.5 Security Assessment Evidence

During the assessment process, evaluators obtain evidence from various sources, including
previously conducted product and system assessments, documentation of system
developmental activities, and documentation of operational activities. Product and system
assessments are examinations, often conducted by third parties, to evaluate the security
functions of an organization’s products and their related configuration settings. Such
assessments may have been performed to demonstrate compliance with regulations or with
developer and vendor claims, but they can also be used as evidence to validate assertions in
a SAR.
Evidence obtained from system developmental activities include artifacts produced by
developers, operators, assessors, and other system owners during the system development life
cycle. This may be in the form of design specifications, testing and code analysis, interviews with
related employees, and other forms of documentation conducted by the company or third-party
assessor that help provide evidence that the security function is trustworthy and reliable.
Similarly, evidence from the operational environment also contributes to the assurance of the
security function by providing records of remediation efforts, incident reports from events such
as a breach, and the results of continuous organizational monitoring. Specifically, this evidence
helps an assessor determine the effectiveness of the following security functions and activities:
Privacy and security controls currently deployed
Change management practices regarding systems and operations
Compliance with policies, regulations, and standards
The level of detail available from all sources of evidence can affect the type of testing, analysis,
and evaluation performed. Artifacts with less coverage and depth provide a lower level of
assurance and may require more rigorous, comprehensive, or focused testing. Conversely,
artifacts with more depth may require less testing and may provide evidence that the security
function is implemented correctly and completely, which indicates strength for a given
system component.

2 Communication of Security Knowledge and Awareness
All employees play an important role in protecting a company’s digital and physical assets, not
just the IT department. As such, the need for educating and training programs is critical as the
sophistication, scope, and number of cyberattacks increase each year. Organizations must
prioritize and invest in these security awareness programs to minimize the cyber risk and the
damages that cyberattacks can inflict upon an organization.
Conducting regularly scheduled security awareness training is encouraged or mandated by
various information security frameworks and regulations. For instance, the information security
standard-setting body, NIST, as well as GDPR, HIPAA, and SOC2®, emphasize the need for
conducting regular security awareness and training programs for employees.
2.1 Security Awareness Delivery Methods

The source of IT security education and training content will vary by organization, but methods
of communicating relevant security awareness information range from being fully outsourced to
being managed solely in-house, or some combination of the two. Training provided in-house will
require teaching tools, which will typically require resources acquired from a third party, unless
content can be created internally.
Methods of course delivery can be individual or group sessions, as well as live or on-demand
sessions. Live sessions may be in conducted in-person or remotely. Assessments of education
content may include quizzes, examinations, case studies, or simulations. It is recommended
that training methods be revised over time to optimize benefits. Adequate documentation
of course planning and delivery methods should also be performed for consistency and
evaluation purposes.
2.2 Organizational Job Roles Specific to Security Awareness

While every employee will have a unique role to play with respect to education regarding
security awareness, there are generally three relevant categories of personnel with differing
levels of responsibility:
Management: Tasked with designing and evaluating security awareness programs or
coordinating with third-party vendors hired to develop and/or perform the security
awareness training.
Specialized IT Personnel: Tasked with carrying out the policies set forth in security
awareness programs. Specialized jobs include network security engineers, penetration
testers, incident response analysts, and compliance analysts.
All Other Employees: Tasked with following the security procedures based on their specific
job roles.
Training should be provided at all stages of an employee’s job, beginning with security training
at new hire orientation, followed by refresher training courses that occur at least annually.
Training should also be tailored to an employee’s job role. Employees other than management
and specialized roles should only be responsible for security practices relevant to a basic user
role, such as training on identifying phishing emails or best practices on connecting remotely via
a virtual private network.
Specialized roles may need initial and recurring training specific to certain functions like disaster
recovery procedural training or content related to new regulations with which the organization
must comply.

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2.3 Components of a Successful Security Awareness Program

Hallmarks of a successful security awareness program include phishing simulations, program
supporters and champions, regular employee engagement, and metrics to measure program
success, such as the amount of money allocated to the program, the number of resources
dedicated, and corrective action plans for any deficiencies discovered.
2.3.1 Phishing Simulations

Phishing simulations are designed to teach employees to recognize phony emails by sending
messages that mirror actual phishing emails and other communications. When employees
click a link or download an attachment in these simulated emails, the employee will receive
a communication informing them they performed an action in violation of standard security
protocols. The communication is designed to teach the person about phishing scams and may
be in the form of a follow-up email or a direct communication from human resources or the IT
department. The employee will often be required to complete additional security training.
Results of the phishing simulation programs are summarized with metrics and analyzed over
time to evaluate employee awareness. Examples of those metrics may include the following:
Click Rate: The percentage of employees who clicked on a phishing email link.
Re-click Rate: The percentage of employees who failed the first campaign who click again.
Report Rate: The percentage of employees who report phishing emails.
Non-responder Rate: The percentage of employees who ignored the email and did not
respond in any way.
Reply Rate: The percentage of employees who replied to the phishing emails.
2.3.2 Security Program Champions

A program champion leading the effort of implementing a security platform is often needed.
Preferably, a full task force would be ideal to lead such efforts. Key metrics for assessing the
effectiveness of program champions include the following:
Employee Consultations: This metric reports the number of times employees consult with
a security program champion.
Security Behaviors (With and Without Champions): This would involve capturing and
comparing security awareness measures in departments that have champions versus those
that do not.
Champion Density vs. Security Behaviors: This would measure the degree of correlation
and linear relationship of champion activity, or “density,” among different departments and
security behaviors. An example metric capturing this would be a correlation coefficient.

2.3.3 Employee Engagement

Measuring the level of employee engagement is yet another critical barometer for assessing a
security training program. Some popular metrics include the following:
Percentage of employees who completed training
Average time taken per training session
Count of employees who attended each training session
Likelihood an employee would recommend the training to others
Count of employees attending due to referrals
Count of questions from employees about training content
Count of employees requesting security information or visiting a related company
intranet website
Quantitative and qualitative metrics on social media interactions

reserved.
4
MODULE
Confidentiality
and Privacy ISC 3
1 Confidentiality vs. Privacy
While both confidentiality and privacy are terms that are often used interchangeably, the two
terms are independent when it comes to cybersecurity.
Privacy protects the rights of an individual and gives the individual control over what
information they are willing to share with others.
Confidentiality protects unauthorized access to information gathered by the company.
Alternatively, privacy requirements dictate the types of authorization granted to information.
After the information is gathered adhering to the privacy requirements, confidentiality
is required so that the information is only accessed by systems or individuals with the
appropriate authority.
1.1 Confidentiality
The National Institute of Standards and Technology (NIST) defines confidentiality as preserving
authorized restrictions on access and disclosure of data, including means for protecting personal
privacy and proprietary information.
In addition to proprietary information, confidentiality requires organizations to protect all
personal information that it collects or maintains during the course of normal business. To
accomplish this, organizations must define and identify information that is deemed to contain
personal information.
Personal identifiable information (PII) is defined as all data that can be used to identify an
individual, including the following:
Name, such as full legal name, maiden name, mother's maiden name, or alias
Personal identification numbers, such as Social Security number (SSN), passport number,
driver's license number, taxpayer identification number, or financial account or credit
card number
Address, such as street address or email address
Personal characteristics, including photographic images, fingerprints, handwriting, or other
biometric data
Well-designed cybersecurity programs typically attempt to minimize the amount of personal
information used, collected, and stored. Only information that is critical to operations should
be stored. Also, an organization should regularly review its storage of collected personal
information to determine whether that information is still relevant and necessary for meeting
critical business functions.

4 Confidentiality and Privacy ISC 3
In order to protect confidentially and PII, organizations should:

Review current holdings of personal information and confirm the data is accurate, relevant,
timely, and complete.
Reduce personal information gathered to the minimum necessary for critical
business functions.
Define the criteria of each authorization level and monitor the criteria and access
list periodically.
Establish a plan to purge personal information that is no longer required to perform critical
business functions.
1.2 Privacy
The NIST defines privacy as the right of a party to maintain control and confidentiality of
information about itself. Privacy is the process of protecting human autonomy and dignity. The
NIST Privacy Framework is a tool for improving privacy through risk management procedures
and communication methods employed throughout the organization.
The Privacy Framework's purpose is to help organizations manage privacy risks by:
Considering privacy best practices as they design and deploy systems, products, and
services that affect individuals.
Communicating privacy practices to the rest of the organization.
Encouraging cross-organizational workforce collaboration relating to user privacy and
IT security.
The Privacy Framework approach to managing privacy risk requires the consideration of privacy
events as potential problems individuals could experience at some stage during the life cycle
of a data point. This could range from the collection to the disposal of data as it flows through
systems and processes related to delivering products or services.
2 Methods of Protection of Confidential Data
Organizations should have a structured process to determine how information is handled in

order to be in compliance in the following areas:
Applicable legal, regulatory, and policy requirements
Risks and effects of collecting, storing, and deleting information
Identification and evaluation protections and alternative processes for handling information
to mitigate potential privacy risks
Violation of these guidelines could subject the organization to potential litigation and monetary
losses. To mitigate these risks, below are the common operational safeguards, privacy-
specific safeguards, and security controls an organization can utilize to manage PII and
proprietary information:
Data Collection
y Creating Policies and Procedures: Organizations should develop comprehensive
policies and procedures for protecting the confidentiality of PII and proprietary
information by defining:
—the specific confidential data collected from both employees and customers;
—how confidential data is collected, accessed, and retained;
S3–48 Module 4 Confidentiality

© Becker Professional Education Corporation. and Privacy
ISC 3 4 Confidentiality and Privacy
—incident response;
—privacy in the development cycle;
—sharing rules; and
—consequences of violations.
y Conducting Training: Organizations should reduce the possibility that PII will be
accessed, used, or disclosed inappropriately by requiring that all individuals receive
appropriate training to understand the relevant guidelines and the repercussions of
violating these guidelines.
Data Processing
y De-identifying Personal Information: Organizations should de-identify records by
removing enough personal information such that the remaining information does not
identify an individual.
—For example, pseudonymization is a form of de-identification that would replace
the name of a person visiting the doctor with a pseudonym, such as Patient 565
or Client AM.
—Other types of de-identification, like anonymization, remove the ability to trace
identifying data points to a person when full records are not necessary, such as for
research studies or determining correlations and trends.
Data Storage
y Using Access Enforcement: Organizations should control access to personal
information through access control policies and access enforcement mechanisms (e.g.,
access control lists).
y Implementing Access Control for Mobile Devices: Organizations should prohibit or
strictly limit access to personal information from portable and mobile devices, such as
laptops, cell phones, and personal digital assistants.
y Auditing Events: Organizations can monitor events that affect the confidentiality of
personal information, such as inappropriate access to PII.
Data Transmission
Organizations should protect the confidentiality of information transmitted. This is
commonly accomplished through encrypting the communications (i.e., VPN) or by
encrypting the information before it is transmitted.
Data Deletion/Purging
Organizations should set up the policies to determine the data sets subject to be archived
or purged.

2.1 Confidentiality During the System Development Life Cycle

When new systems are being developed, tested, and implemented, organizations often
deploy methods that protect confidential data using data obfuscation. Obfuscation is the
process of replacing production data or sensitive information with data that is less valuable to
unauthorized users. The most common data obfuscation applications are:
Encryption: Scrambles unencrypted data using cryptography so that it can generally only
be deciphered with a key. There are various types of encryption methodologies that differ in
the way in which keys are managed and transferred between users.
Tokenization: Removes production data and replaces it with a surrogate value or token.
Tokens can be generated using random number generators; by hashing, which transforms
data using mathematical algorithms; or by encryption. Keys used to reverse the tokenization
process are stored in a token vault, which is controlled using authorization and access
controls. Tokenization is similar to encryption but it generally does not change the length
or type of characters. Tokens are often used in credit card transactions at different stages
within the payment clearing process.
Masking: Swaps data with other like data so that the original identifying characteristics are
disguised, or masked, while maintaining a similar structure to the unmodified data set. The
modified data set's aggregate value remains intact, allowing insights and the data to be
extracted. There are different forms of masking including shuffling, scrambling, substitution,
nullifying, and masking out in which all or part of the data's value is swapped with a single
character such as an asterisk.
Unaltered Message Transformation Altered Message
Tokenization 4291-6451-6524-5564 Tokenizer 6523-8313-7359-5435

Example application:
Credit card transactions
John Smith
Jason Paul SSN 555-01-4444
Masking SSN 925-01-8264 Mask OR
John Smith
SSN ***-**-8264
Example application:
Healthcare settings or
research studies.
Encryption 42916451652 Encryption Algorithm G09xKzsj7ZTRiFq2ErHqYw

3 Data Encryption
3.1 The Fundamentals

Data is a critical asset to any business. Data breaches may result in a loss of sensitive data
resulting in financial losses (e.g., litigation expenses), interruption of business operations (e.g.,
being unable to process customer orders or unable to work with suppliers), and damage to
the company's reputation. To prevent loss of data and to reduce the risk that the attacker can
extract information needed from the data obtained, data encryption plays a pivotal role as a
defense mechanism against malicious cyberattacks.
Data encryption is a method of mitigating the risk of data breaches and data loss through
the application of cryptography so that data is protected during its collection, processing,
and storage. Cryptography involves applying an algorithm to transform, or encrypt, plaintext
data into ciphertext. Prior to being encoded, data is referred to as plaintext, whereas after it
is encoded and unreadable, it is called ciphertext. Ciphertext can only be decoded by using a
key with the mathematically encoded algorithm, which offers the receiver nonrepudiation, or
assurance, that the sender is who they say they are.
3.2 Encryption Methods

Encryption models can use different types of keys and different combinations of keys within one
model. An organization may use encryption to supplement other measures used to protect data-
at-rest when relevant protections are determined to be appropriate based on assessed risks.
Keys can be public or private. Public keys are shared either publicly or with a group, and private
keys are only known to one user. The following are the two most common encryption methods:
Symmetric Encryption: Involves a single shared or private key for encryption and
decryption of data within a group. The private key is used by all members in the group to
both encrypt and decrypt data and can be in the form of a number, a letter, or a string of
random numbers and letters. Symmetric encryption is commonly used by banks to encrypt
sensitive customer data for time-sensitive transactions as decrypting needs to happen as
quickly as the customer is performing a transaction.
One drawback of symmetric encryption is that it does not facilitate non-repudiation because
any person with the shared key can encrypt and decrypt messages. Therefore, there is no
way to tell where a message originated. It is also difficult to scale because every combination
of users in the group must each share private keys, and those keys must be generated each
time participants leave a group.
SENDER RECEIVER
Plaintext ENCRYPTION Ciphertext Ciphertext DECRYPTION Plaintext
SHARED KEY SHARED KEY

Asymmetric Encryption: This data encryption method uses two keys, a public and private
key. The public key is used to encrypt the message and the private key to decrypt it, or vice
versa. Only the two opposite keys can be used in tandem for this form of encryption to
work. Popular applications of asymmetric encryption include digital signing and blockchain.
The primary weakness of asymmetric encryption is its speed of operation. They keys are
generally longer, one is needed for both encryption and decryption, and the encryption
algorithm is typically more complex. All of these factors require more computing power,
which is time-consuming and could also lead to an increase in technology expense.
SENDER RECEIVER
Plaintext ENCRYPTION Ciphertext Ciphertext DECRYPTION Plaintext
PUBLIC KEY PRIVATE KEY
Hashing is often confused with encryption because it converts a message with variable lengths
to a fixed-length message or code called a message digest or hash value. However, the effect
of hashing is one-way, meaning it scrambles a message into code that cannot be unscrambled.
Encryption is two-way because it can both be encrypted and decrypted.
One primary difference between encryption and hashing is their intended use. Encryption is
intended for the secure transfer of data to maintain confidentiality, whereas hashing is intended
to maintain the integrity of the data transmitting, validating that the message sent is from the
true sender. Comparing two hash values will tell users that the message is legitimate.
Since hash values cannot be decrypted, hashing is often combined with encryption to securely
transfer the message using encryption and then validate the authenticity of that message
using hashing. The message is decrypted using either a public or private key, and the hash
value received by the receiver can be compared to the hash value from the sender to ensure it
is identical.
Pass Key
The term "private" can be used to refer to both a private key that is one of two keys used
in asymmetric encryption or it can be used to refer to a shared private key, which is
symmetric encryption. A shared private key among a group is symmetric encryption, but a
single private key paired with a public key is asymmetric encryption.

3.3 Cipher Techniques

Ciphers are the result of applying encryption algorithms that encode unencrypted messages
into an encrypted form. This generally results in a combination of numbers and letters that
are meaningless and illegible to those without a key. Although some ciphers may seem
simplistic, they are often difficult, if not impossible, to decrypt when combined with other cipher
techniques unless using a key. Two common cipher techniques include:
Substitution Ciphers: Are algorithms that replace each character of a plaintext message
with another character. Very basic ciphers simply replace one letter or number with another
using a key, while more complex ciphers involve mathematics to substitute. For example,
using a cryptography technique known as the modulo function, letters or numbers can be
converted into a number that is then used to decrypt a message.
Transposing Ciphers: Are encryption techniques that rearrange the letters of a message to
form unreadable ciphertext, often by using a matrix to perform columnar transposition. The
following is an example of columnar transposition that works by using the key 3241:
y The ciphertext is: ETVETLTWEMAE
The key is 3241. If using a three by four matrix, the code can be mapped as shown below.
3 2 4 1
E E T M
T T W A
V L E E
Using the key to reorder the ciphertext in numerical sequence reveals the message
"Meet at twelve."
1 2 3 4
M E E T
A T T W
E L V E
There are various other types of ciphers, such as running key ciphers, which encrypt messages
that are as long as the messages themselves; and block ciphers, which operate on chunks of a
message and then apply encryption. The messages may also stream ciphers which operate on
a single character, or a few, known as a stream. When used in combination with other ciphers,
these forms of encryption can be difficult to decode.

4 Data Loss Prevention (DLP)
Data loss prevention (DLP) systems enable organizations to detect and prevent attempts by
employees or unauthorized users to transfer sensitive information out of the organization
electronically across multiple protocols, ports, and communication methods. DLP systems often
use pattern-matching methods or word recognition technology to scan files for certain patterns,
such as the way in which data is formatted or sequenced.
For example, systems designed to comply with regulatory standards, such as HIPAA, PCI-DSS,
and GDPR, may deploy pattern-matching technology that searches for strings of 9-character
numbers with dashes after the third number and fifth number to identify potential Social
Security numbers. The software may then either prevent the message from being sent or
encrypt it.
The main objectives and best practices of DLP are to develop a program to:
Implement a centralized DLP program, with collaboration from various departments, which
oversees data for the entire organization.
Define and create enterprise data usage policies, report data loss incidents, and establish
incident response capability to enable corrective actions to remediate violations.
Evaluate the different forms of data, define the different levels of sensitivity, create
an inventory of sensitive data, identify where sensitive data is stored, and manage
data cleanup.
Monitor the use of sensitive data, understand sensitive data usage patterns, and gain
enterprise visibility.
Enforce security policies to proactively secure data and prevent sensitive data from leaving
an enterprise.
Implement employee education programs.
Two common types of DLP systems include network-based DLP systems and endpoint-based
DLP systems:
Network-based DLP: These types of DLP systems scan outgoing data that meet specific
criteria and are transmitted using means such as email, file transfer protocols (ftp sites that
facilitate file transfer), and direct messaging. Records of DLP policy violations are typically
archived in a database that identifies the data moved and where it went on the network.
y Cloud-based DLP: These DLP systems apply the same protection as a network-based
DLP but apply it to a cloud environment. Many organizations are migrating some
functions, if not all computing functions, to a cloud-based (web-based) environment.
y Data loss is prevented when transferring sensitive data across virtual machines and
platforms rather than an organization's private on-premise network.
Endpoint-based DLP: These types of DLP systems scan files stored or sent to devices that
might be outside of a network, such as a printer, USB drive, or any other device to which
data can be transferred. Transferring data to such devices can be prevented by scanning for
specific keywords, patterns, or file types, such as MP4 files.

Illustration 1 Network-Based Data Loss Prevention
Alice is the director of provider credentialing for North Pointe Hospital's billing department.
She regularly sends records to insurance companies and other health care providers, which
include sensitive data, such as Social Security numbers, dates of birth, and other personally
identifying information. She typically encrypts emails that contain such information, but in
a rush to meet a deadline, Alice forgets to encrypt an email containing dozens of provider
records to an insurance company.
North Pointe recently purchased a subscription to an email DLP solution from the
cybersecurity provider Clix Corp. This is a network-based DLP solution that auto-encrypts
emails that an algorithm detects using pattern recognition applied to all emails that have
North Pointe's domain, @northpointehospital.com. Operating as designed, this DLP
solution automatically encrypted the email Alice forgot to send securely, minimizing the
likelihood that these records would be exploited if intercepted.
4.1 Protecting Data at Rest

Storing sensitive data requires a robust storage infrastructure that provides sufficient physical
security, adequate digital security, authorization, proper access controls, change management
controls, backup, and recovery mechanisms. These safeguards should be in place so that data is
protected as it is collected, processed, stored, transmitted, and purged.
Physical Security: may be in the form of locked cabinets and closets, security cameras and
badge entry-controlled entry/exit points, and tamper-evident seals.
Digital Security Controls: include encrypted hard drives, encrypted USB drives, or secure
file systems that are encrypted.
Authorization and User Access Controls: include control mechanisms, such as role-based
access controls, rule-based access controls, discretionary access controls, and multifactor
authentication.
Change Management Controls: these procedural controls require there to be processes
in place for requesting changes to a system or data, review and approval, implementation,
reversion, and documentation.
Backup and Recovery Mechanisms: these redundancy defenses protect data so it is
not lost and can be restored in the event of a disaster, cyberattack, or accidental deletion
or modification.

4.2 Deleting Confidential Information

Removing and destroying confidential information at the end of its life cycle can be done
through physical destruction, erasing, overwriting, and purging. Physical destruction involves the
physical act of disassembling or changing the chemical construct of the data (i.e., through heat,
pressure, or shredding).
Erasing is the performance of a delete operation of a file or its data. Overwriting, or clearing,
involves preparing media for reuse by replacing the old data with unclassified data. Purging
repeats the clearing process various times and may combine that process with another method,
such as degaussing, which involves creating a strong magnetic field used to erase data on
storage devices that use magnetism, such as magnetic tapes.
In some cases, data remanence may exist on storage devices that have been erased,
overwritten, or treated so that confidential information is removed. This is common on media
storage devices that use magnetism. When data is removed, a residual magnetic flux or imprint
may remain. Even if degaussing is used, there are many tools available that can undelete or
reverse the effects of wiping. Physical destruction may be the only means to completely purge
confidential data.
5 Walk-Through of an Organization's Security,

Confidentiality, and Privacy Procedures
5.1 Performing a Walk-Through

Effective security, confidentiality, and privacy policies and practices require a comprehensive
strategy involving all departments within an organization. To enhance the likelihood that this
strategy can be executed in the event of the examples below, performing periodic read‑throughs
and walk-throughs led by the IT departments or a joint task force of both IT and non-IT
departments is necessary:
Data breaches (Confidentiality and privacy)
Security incidents or disasters (Security)
A read-through involves distributing security, confidentiality, and privacy procedures to
members of both the IT departments and non-IT departments supporting the walk-through
for review. The read-through lets an organization inform personnel of tactical and strategic
procedures and review plans for obsolete information. A structured walk-through takes the
read-through one step further by role playing/simulating a disaster scenario related to security
or a confidentiality and privacy scenario in which an attacker is attempting to obtain data for
personal gain and having team members use the procedures in place to prevent the attack and
ensure the data leaked cannot be deciphered. Fire drills are less common but can be an effective
way to test security policies and determine if employees understand emergency plans and
follow proper protocols when they believe an emergency situation is occurring.
Walk-throughs are more commonly performed than fire drills and involve team members
obtaining evidence about whether the documented policy requirement aligns with the observed
procedures. Walk-throughs occur in phases starting with a planning and preparation phase,
followed by obtaining an understanding of the process being evaluated, performing the
walk‑through, creating documentation, performing tests, and finally evaluating the procedures
and reporting on their effectiveness.

The steps of performing a walk-through are:

1. Plan and Prep
y Define the scope
y Identify key controls and processes
y Identify personnel
2. Obtain an Understanding
y Review documentation
y Interview personnel
y Create notes
3. Perform Walk-through
y Reperform processes
y Verify results and effectiveness
4. Create Documentation
y Create workpapers
y Document procedures
5. Test
y Test controls identified in walk-through
y Obtain samples if needed
6. Evaluate and Report
y Interpret results
y Prepare a report to summarize findings
y Provide recommendations
5.2 Walk-Throughs in Company Functions and Departments

Walk-throughs of documented IT security, confidentiality, and privacy policies should occur for
all functions and departments within an organization, including the following:
Finance and Accounting: Finance and accounting departments are the gatekeepers to a
company's financial records.
y For confidentiality and privacy, walk-throughs should focus on ensuring confidentiality
and privacy policies are followed such that minimal PIIs are collected, and each user
can only access the minimal level of PII and proprietary data to execute his or her
job function.
y For security, walk-throughs should focus on ensuring security policies are in place
to only allow authorized employees access to systems that control any accounting
functions that involve withdrawing or transferring cash, collecting or diverting
payments, and reporting financial information.

Corporate Training and Education: This may not be an individual department, but rather
a function performed by multiple individuals from different departments. Walk-throughs
should include:
y viewing the security, confidentiality, and privacy content being delivered to employees
and determining whether they are appropriate to their job roles;
y employee acknowledgement of the policies and procedures;
y attending courses delivered by trainers;
y reviewing materials and assessments given to trainees; and
y interviewing the training staff regarding plans for making revisions and updates to the
training program.
Human Resources: This department is considered the gatekeeper for onboarding newly
hired employees and ultimately has access to an organization's systems.
y For confidentiality and privacy, walk-throughs should focus on how human resources
follow the policies and procedures to identify and collect PII, manage access to PIIs, and
the process of handling violations.
y For security, walk-throughs should focus on practices regarding background checks,
defining security roles for both contractors and full-time employees, communicating
security policies, monitoring employee activity, and processes for revoking access
privileges as employees transfer positions or are terminated.
IT Risk Management: This department is focused on identifying current and potential
confidentiality and privacy risks so they can be eliminated, minimized, or transferred.
y For confidentiality and privacy, walk-throughs should focus on identifying ways
the department monitors the confidentiality and privacy controls, identifying and
communicating potential violations.
y For security, walk-throughs should focus on identifying ways the department tracks
assets and systems that should be protected, identifies potential vulnerabilities and
threats, assesses the operational and financial impact of risks, develops risk mitigation
strategies, and periodically reviews risk management plans.
In relation to security, service auditors will perform procedures to understand how an entity
communicates information through a security awareness training program. Procedures the
service auditor may perform to obtain an understanding of the organization's communications
may include reviewing documents related to the following:
The service organization's security awareness and training programs
The communication of the entity's code of conduct
Employee handbooks
Information security policies
Incident notification procedures
Other available documentation to understand the service organization's process for
communicating to personnel their responsibilities for system security and other matters

6 Detect Deficiencies in a SOC 2® Engagement
Security, confidentiality, and privacy testing will take place with service organizations that are
subject to System and Organization Controls (SOC) audits. During SOC 2® engagements, a service
auditor evaluates the results of all procedures performed and conducts both a quantitative
and qualitative analysis of whether identified description misstatements, deficiencies in the
suitability of design, and, in a type 2 examination, the operating effectiveness of controls result
in a description that is not presented in accordance with the description criteria or in controls
that are not suitably designed or operating effectively.
Service auditors in a SOC 2® engagement will also perform a walk-through of the service
organization's IT security, confidentiality, and privacy policies. General walk-through procedures
to be performed by SOC 2® engagement service auditors include:
Following a transaction, event, or activity from origination until final disposition
through the service organization's system using the same documents used by service
organization personnel.
When considering confidentiality and privacy, the objective is to understand how PIIs and
proprietary information are handled throughout the life cycle.
Inquiry, observation, inspection of relevant documentation, and flowcharts, questionnaires,
or decision tables to facilitate understanding the design of the controls.
Inquiry about instances during the period in which controls did not operate as described
or designed.
Questioning variations in the process for different types of events or transactions.
An appropriately performed walk-through provides an opportunity to verify the service auditor's
understanding of the flow of transactions and the design of the controls in relation to an
organization's security, confidentiality, and privacy service commitments.
When performed properly, walk-throughs often provide evidence about whether controls
included in the description were suitably designed and implemented and, in a type 2
examination, operated effectively.
When evaluating the results of procedures, the service auditor investigates the nature and cause
of any identified description misstatements and deficiencies or deviations in the effectiveness of
controls and determines the following:
If the identified description misstatements result in either the failure to meet one
or more of the description criteria or in a presentation that could be misunderstood
by users if the service auditor's opinion was not modified to reflect the identified
description misstatements.
Whether identified deviations are within the expected rate of deviation and are acceptable
or whether they constitute a deficiency.
Whether the procedures that have been performed provide an appropriate basis for
concluding that the control operated effectively throughout the specified period.

Whether identified deficiencies are likely to have a pervasive effect on the achievement of
the service organization's service commitments and system requirements based on the
applicable trust services criteria.
The magnitude of the effect of such deficiencies on the achievement of the service
organization's service commitments and system requirements based on the applicable trust
services criteria.
Whether report users could be misled if the service auditor's opinion were not modified to
reflect the identified deficiencies.
Factors that may be considered when determining whether the identified deviations may have a
pervasive effect on other controls include the following:
The effect that entity-level controls have on the operation of other controls. Deviations in
entity-level controls often have a pervasive effect on other controls.
The extent of the use of segmentation, a technique that enhances security by dividing
networks or systems into multiple segments, across the service organization.
The extent to which deficiencies in certain key controls have a pervasive effect on
other controls.
If the service auditor identifies material description misstatements, material deficiencies in
the suitability of design of controls, or, in a type 2 examination, deviations in the operating
effectiveness of controls, the service auditor should modify the opinion. When modifying
the opinion, the service auditor's understanding of the nature and cause of the description
misstatements and deficiencies enables the service auditor to determine how to appropriately
modify the opinion.
When incidents of fraud or suspected fraud are identified during the examination, the service
auditor is expected to respond appropriately. Appropriate responses include the following:
Discussing the matter with service organization senior management (and the engaging
party, and other appropriate parties, unless senior management is suspected to have
committed the fraud).
For potential fraud involving senior management, communicating to those charged
with governance and discussing with them the nature, extent, and timing of procedures
necessary to complete the examination.
Requesting that senior management consult with an appropriately qualified third party.
Considering the implications of the matter in relation to other aspects of the engagement,
including the service auditor's risk assessment and the reliability of written representations
from service organization management.
Obtaining legal advice about the consequences of different courses of action.
Communicating with third parties.
Withdrawing from the engagement.

5
MODULE
Incident Response ISC 3
1 Incident Response Plan Contents
An incident response plan (IRP) is the documentation of a set of procedures, people,

and information to detect, respond to, and limit consequences of a cyberattack against
an organization.
Organizations should have a formal and coordinated plan for responding to incidents, including
a roadmap for implementing the incident response capabilities detailing the method of
detection, response timeline, and incident response team's responsibilities. The plan should
meet the unique requirements related to the organization, including the organization's mission,
size, structure, and operational functions.
The contents included in an IRP are subject to the needs and risks associated with an
organization. However, the National Institute of Standards and Technology (NIST) names the key
elements that most policies contain, including the following:
Mission
Strategies and goals
Senior management approval and statement of commitment
Organizational approach to incident response
Purpose and objectives of the policy
Scope of the policy
Metrics for measuring the incident response capability and its effectiveness
Roadmap for maturing the incident response capability
Definition of computer security incidents and related terms
Organizational structure and definition of roles, responsibilities, and levels of authority
Prioritization or severity ratings of incidents
Internal and external communication methods

5 Incident Response ISC 3
1.1 Incident Response Timeline

Robust IRPs require the recovery timeline to be charted when an incident occurs, clearly
delineating the point at which the incident starts; when it is detected, contained, and eradicated;
and when normal business operations are restored. This is often documented in the form of a
Gannt chart, as follows:
Incident is reported Incident is contained Incident is eradicated Recovery is complete
Incident begins Incident stops
PREPARE DETECT CONTAIN ERADICATE RECOVER LEARN

45 minutes 65 minutes 55 minutes 60 minutes Ongoing
REPORT
Ongoing
Total duration of incident Normal business operations resume
1.2 Method of Detection

The methods of detection deployed should be listed in the contents of an IRP. There are various
mechanisms and forms of technology an organization may use to detect incidents or events,
such as the following:
Vulnerability scanning software
Anomaly detection
Endpoint detection and response (EDR) solutions
File integrity monitoring
Log analysis
Intrusion detection systems (IDS)
Intrusion prevention systems (IPS)
Physical security monitoring
Security information and event management solutions (SIEM)
Threat intelligence software
User behavior analytics (UBA) tools
S3–62 Module 5 Incident

© Becker Professional Education Corporation. All rights Response
reserved.
ISC 3 5 Incident Response
1.3 Incident Response Personnel, Roles, and Responsibilities

The most critical component of an IRP is the human capital designated to respond to an incident.
While an IRP's success depends on the participation and cooperation of individuals throughout
the organization, it requires the assemblance of specialized employees with the right technical
knowledge to handle each piece of the IRP. Guidance and support from senior management is
also essential as they are the champions for incident response management in the organization.
Depending on an entity's size and business model, different structures may be better suited for
adoption. NIST recommends the following models:
Centralized Incident Response Team: In this model, a single incident response
team is tasked with managing incidents across the organization. This approach is
effective for smaller organizations and those with computing environments that aren't
distributed geographically.
Distributed Incident Response Teams: Organizations in this model have multiple incident
response teams that are responsible for specific logical or physical segments of a company's
network. This model is effective for organizations that have geographically widespread
computing resources.
Coordinating Team: A secondary function of either a distributed or centralized incident
response team is coordinating with other departments without having authority over
those teams.
NIST's Computer Security Incident Handling Guide recommends that organizations consider the
following factors when selecting the appropriate structure and staffing models for incident
response teams:
24/7 Availability: Most organizations need incident response staff to be available 24/7
either by phone or on-site. Real-time availability helps minimize the impact of an attack
because it shortens the amount of time it takes to discover and respond to an incident.
Full-Time vs. Part-Time Team Members: The decision to staff an incident response team
full time instead of part time depends on a number of factors, including available funding,
other staffing needs or constraints, the industry in which the company operates, and the
individual company's needs. Outsourcing to a virtual incident response team may be a
viable alternative to hiring full-time staff.
Employee Morale: Incident response work can be demanding because it often requires
on-call responsibilities of most team members. This can make it easy for team members
to become stressed, making it difficult for some organizations to find willing, available, and
skilled people to hire, especially for roles that require 24-hour support. Segregating roles
may be one option to combat this fatigue and be a morale booster.
Cost: Cost is always a factor when deciding how to adequately staff an incident response
team. The 24/7 availability requirement naturally makes it expensive. Because the incident
response team works with so many facets of IT, its members require broader knowledge
than most IT employees. They must also understand how to use incident response tools like
digital forensics software.
Staff Expertise: Incident handling requires a mixture of specialized knowledge and
experience in both technical and nontechnical disciplines. Since IT professionals that
specialize in cybersecurity must possess a deeper and up-to-date knowledge of intrusion
detection, forensics, vulnerabilities, and exploits, it often makes sense to outsource this
function to a managed services provider who can spread the expense across its client base.

While the main focus of an incident response team is intrusion detection, it is common for
teams to perform additional duties to raise awareness of cybersecurity across the organization.
They may include:
Education and Awareness: The more employees outside of the IT team know about
detecting, reporting, and responding to incidents, the less of a burden it will be on the
incident response team. This information can be delivered using various mediums including
workshops, company intranet sites, newsletters, posters, and other paraphernalia with
security tips or reminders.
Advisory Distribution: Issue cyber briefings or newsletters to inform the rest of the
organization regarding new vulnerabilities and threats identified by the teams.
Information Sharing: Incident response teams may participate in information sharing groups
and manage the organization's incident information sharing efforts in the broader cybersecurity
community. This may include sharing information related to past incidents, the response
selected, the results of that response, as well as any company changes that resulted.
2 Responding to Cybersecurity Incidents in Accordance

With the Incident Response Plan
Cybersecurity involves the safety of computer systems which includes the technology
infrastructure supporting the computer systems (network, computers, etc.) and the digital data
contained within.
2.1 Defining Cybersecurity Events and Incidents

An organization's IRPs must distinguish between recognizing and responding to an event versus
a cybersecurity incident. Events may be benign, whereas incidents usually pose a threat to an
organization's computer or network security. Discerning the difference between the two is
critical because the responses may be vastly different. NIST defines these terms as follows:
Event: An event is an observable occurrence in a system or network. Examples include
a user connecting to a shared file server, a server receiving a request for a web page, a
user sending an email, and a firewall blocking a connection attempt. Events also include
cybersecurity changes that have an effect on an organization's operations, mission,
manufacturing capabilities, or reputation.
Adverse Event: Any event with a negative consequence is defined as an adverse event, such as
system crashes, packet floods, unauthorized use of system privileges, unauthorized access to
sensitive data, and the execution of malware that destroys data. This includes both intentional
and unintentional events, as well as human-inflicted and environmentally inflicted events.
Computer Security Incident: This is a type of adverse event that is computer security-related
and caused by malicious human intent, not by environmental or indirect human factors such as
power failures or natural disasters. It is defined as any violation or imminent threat of computer
security policies, acceptable use policies, or standard security practices. Examples include:
y an attacker flooding a web server with requests resulting in a site crash;
y deceiving users into opening phishing emails and downloading tools that infect the
user's computer;
y an attacker holding a company's data hostage in a ransomware attack; and
y adverse events that are as seemingly harmless as exposing sensitive information to
unintended parties because of careless use practices.

reserved.
2.2 Steps in Responding to an Incident

Though incident response plans vary by organization and framework, there are seven widely
recognized steps in responding to incidents, outlined below.
01 PREPARATION Prepare for Incidents
02 DETECTION Detect and Identify Incidents
03 CONTAINMENT Contain the Incident From Spreading
04 ERADICATION Eradicate Threats
05 REPORTING Report and Communicate Status
06 RECOVERY Recover and Restore Normal Operations
07 LEARNING Learn and Improve
1. Preparation: The initial phase of incident response planning involves assembling key
personnel, tools, and processes so the organization will be prepared to handle many
scenarios. Tools and methods adopted in preparation typically include vulnerability
assessment software, intrusion detection and prevention applications (vulnerability
scanners), anti-malware software, and training for both end users and specialists directly
involved in the response.
2. Detection and Analysis/Identification: The second phase concentrates on recognizing
deviations from normal operations, evaluating those deviations, and correctly classifying
them as either an acceptable event or a problematic cybersecurity incident.
3. Containment: Once a threat is correctly identified, the organization must contain it so that
further damage is not incurred. This also allows the cybersecurity response team time to
determine the best approach to eliminate the threat.
y Containing a threat may include technical measures such as isolating a segment of a
network, taking an exposed group of workstations out of use, or removing infected
servers from production and rerouting those to backup or failover equipment.
y Containment may also include nontechnical measures like informing employees so that
certain routine operations still in progress might stop, preventing further proliferation
of the incident.
4. Eradication: This phase targets the extraction of the threat and restoration of affected
systems, which may be as simple as restoring infected files with clean backup copies or
as complex as using specialized software and forensic analysis to help decrypt or remove
infected files. System logging or network monitoring may also be performed company-
wide to determine whether the breadth and depth of eradication efforts are adequate.
A significant incident may require a system to be entirely rebuilt, resulting in the loss of
critical data.

5. Reporting: This phase emphasizes communication of the incident to management,

IT personnel, and affected employees. Messaging should be tailored to each of these
employee groups, with information and next steps only given that are relevant to
each group.
6. Recovery: The recovery step prioritizes returning an organization's normal IT operations
to a fully functional state. This step should be performed using a phased approach with
early days focused on increasing overall security and implementing immediate high-impact
changes, followed by a more holistic long-term phase that may involve strategic changes
such as a shift in infrastructure to prevent similar cybersecurity incidents from reoccurring.
7. Post-Incident Activity/Lessons Learned: The last step in responding to an incident
involves learning and improving. Senior management and directly affected employees
examine the incident, understand how it occurred, and develop ways to improve the
response. Evaluating the response may involve measuring how long it took to perform
each one of the six steps above and identifying areas in which missteps occurred. The
incident response team may issue a report after this phase is completed and modify the IRP
as necessary.
There are numerous popular frameworks that overlap with these seven overarching steps,
including those issued by the SysAdmin, Audit, Network, and Security (SANS) Institute; NIST; and
the International Organization for Standardization (ISO), among others.
2.2.1 SANS Institute Incident Response Plan

The SANS Institute is the largest cybersecurity training organization in the world. It divides
incident response into six different phases in its Incident Handlers Handbook which include:
1. Preparation
2. Identification
3. Containment
4. Eradication
5. Recovery
6. Lessons learned
Guidance is given on applying different commands to identify unusual processes, files, and
registry keys. The guide also explains methods used to scan for abnormal network activity and
aberrations in scheduled tasks like reboots, unexplained accounts, and suspect user behavior.
2.2.2 NIST IRP

NIST separates the incident response process into four stages in its Computer Security Incident
Handling Guide:
1. Preparation
2. Detection and analysis
3. Containment, eradication, and recovery
4. Post-incident activity
It also provides information on organizing incident response efforts such as providing guidance
on developing policies and procedures, as well as recommendations on the composition of an
incident response team. Detailed plans of action are also listed within the NIST guidance as four
phases, and scenarios with applied guidance are in the appendix of the NIST Computer Security
Incident Handling Guide.

reserved.
2.2.3 International Organization for Standardization IRP

The International Organization for Standardization (ISO) has released standards that help
companies across the globe respond to security incidents. These are known as the ISO/IEC
27000 family of standards, and they recommend that security incident management plans
include the following activities:
Evaluating event criteria and defining an incident
Monitoring and detecting events by human or automated means
Managing incidents to the end of their lifecycle
Coordinating with authorities and handling evidence properly
Performing a root cause analysis
Reporting on all incident management activities
2.2.4 Other IRP Organizations and Frameworks

Various other organizations, both private and those affiliated with governments, have
established frameworks that are either industry-specific or offer guidance to businesses and
individuals across the globe. Some of those include the following:
The Information Technology Infrastructure Library (ITIL), which is a library originally
created by the British government but is now managed by a joint venture known as Axelos.
ITIL outlines an incident management process that is integrated with service management
principles, and they issue certifications that are often sought by third-party IT providers,
which is why incident response is tied closely to serving clients.
The United States Computer Emergency Readiness Team (US-CERT) is an organization that
collaborates with government entities, academia, and the private sector to issue guidance
related to incident response planning.
The Payment Card Industry Data Security Standard (PCI-DSS) issues IRPs specific to
responding to cybersecurity incidents related to payments and transactions.
2.2.5 IRPs Tailored to Specific Attacks

Many organizations have a multipronged IRP that is tailored to specific cybersecurity assaults.
This means having several IRPs that are specifically designed to deal with a number of
unique incidents, usually attacks the organization is most vulnerable to. IBM has identified
attacks that are most often aligned with IRPs, which include the following in order of most
frequently implemented:
DDoS attacks
Mobile code such as malware, spyware, viruses, trojans, and worms
Phishing
Insider incident
Business email compromise
Disaster recovery
Supply chain attack
Advanced persistent threats

2.3 Procedures to Test Whether a Company Follows Its Incident

Response Plan
Once a formal IRP is put in place, organizations periodically test whether those plans respond
as expected to both hypothetical and actual cybersecurity incidents. Some of the most common
methods of testing include the following:
Simulations: Also referred to as tabletop exercises, these are simulated events in which
the response team either sits around a table and verbally walks through an incident as if
it is happening in real time, or it could consist of exercises in which an employee or hired
programmer actually executes an attack so that a response can be observed. The latter
exercise is referred to as a "pen test," or penetration test.
y Annual testing of the IRP may be performed using simulations to determine whether
the incident response procedures are up to date and accurate. When updating the
IRP, lessons learned from simulations and tabletop exercises are used to implement
changes to reflect enhanced procedures when handling incidents.
y A service auditor in the context of conducting a SOC 2® engagement may inspect
documentation for the most recent IRP review to determine whether the plan was
tested within the past year, and that drills conducted to simulate incidents were
resolved and service availability was restored. Service auditors may also inspect the IRP
for revision in response to the testing performed.
IRP Metrics: Establishing metrics to which performance can be compared is a way
companies can determine whether established procedures were followed during an incident
or simulation. Example metrics include:
y Mean Time to Detect (MTTD): The MTTD is the amount of time in minutes or hours
that it takes an organization to detect a prior incident or one in progress. Higher
average times indicate poorer detection capabilities and may result in incidents causing
more significant impacts than organizations with a lower MTTD.
y Mean Time to Acknowledge (MTTA): The MTTA is a metric used to determine the
amount of time an organization takes to acknowledge an incident once it has occurred.
It is measured as the difference between the point in time when an incident is reported
and when it is recognized as an actual threat that requires a response.
y Mean Time to Contain (MTTC): Also referred to as the mean time to remediation, this
is the average time it takes to stop and sequester an incident.
y Mean Time to Repair (MTTR): The MTTR refers to the amount of time it takes an
organization to restore a system to the normal operational state that it was in prior
to the event occurring, or to a target state of operations. The target state could be a
full recovery, or it may be defined as minimal functionality that still permits normal
business operations.
y Mean Time Between Failures (MTBF): This is the average time between consecutive
incident failures. A higher MTBF metric indicates infrequent system failures and infers a
more reliable and resilient network.
y System Availability or Downtime: This refers to the amount of time that a production
system is completely or partially unusable. Most agreements with IT providers have a
specified amount of system uptime they are required to meet, with applicable discounts
or other penalties triggered if the uptime threshold is not met.
y Service-Level Agreement Compliance: This involves evaluating whether qualitative
or quantitative specified performance levels in a service-level agreement with an IT
provider were met.

reserved.
Post-Incident Review: Reviewing the chain of events post-incident with high scrutiny
by senior management and security experts can evaluate how effective an IRP was and
whether personnel and technology complied with the plan. This may involve analyzing
logbooks, evaluating system configurations, interviewing employees involved, and
performing further vulnerability testing.
Periodic Audits: Performing regularly scheduled and unscheduled audits of incident
response policies and reviews of those policies helps determine whether organizations are
positioned to respond appropriately to incidents as they occur.
Continuous Monitoring: Employing automated tools that constantly analyze system logs,
network traffic, and unusual user behavior helps promote timely and adequate responses
to incidents.
2.3.1 Indications an Organization Did Not Respond Appropriately

When evaluating whether an organization's IRP is designed appropriately or determining
whether an actual response followed protocol, there are a number of indications that may reveal
a subpar reaction. Such indications can be measured by the following:
Increases in frequency of incidents or severity of incidents
Time to identify or contain incidents
Increases in data center downtime or IT infrastructure damage
Cost of fines, attorneys, and consultants
Decline in company reputation
3 Insurance as a Mitigation Strategy for a Security Incident
Cyber insurance policies are a relatively new form of insurance protection that help
organizations hedge against cyberattacks by providing financial relief in the event of a successful
attack. This relief can help with the cost of restoring data, the temporary disruption in business
operations, lost revenues, and even managing public relations needs. As cyber threats evolve,
insurance companies are carefully defining both their insurable losses and their requirements
for issuing coverage.
3.1 Insurable Losses

Some of the most common losses related to a cyberattack that are typically covered by cyber
insurance include:
Business Interruption Losses: Lost revenue from operating delays that are due to
the inability to access records, systems, or financial resources may be part of a cyber
insurance policy.
Cyber Extortion Losses: Coverage may include funds for ransom payments and fees to
attorneys or IT experts for the cost of negotiating with attackers.
Incident Response Costs: This includes the cost associated with the recovery of lost or
stolen data by external IT experts or managed services providers. Reimbursable expenses
usually include the cost of labor.
Replacement Costs for Information Systems: If an attack results in corrupted software
or physically damaged hardware, insurance may cover a partial or complete replacement of
IT assets.

Litigation and Attorney Fees: Cyberattacks often result in the need for consultations with
attorneys to address lawsuits (especially class-action lawsuits) that arise from the attack
or just to get legal advice on how to proceed after the initial attack in a way that minimizes
future liability.
Reputational Damage: Costs related to public relations, crisis management, and marketing
to customers regarding a data breach may be covered by the policy. However, harm to
a company's brand or the long-term impact that it may experience are unlikely to be
covered costs.
Information or Identity Theft: Insurance may cover the cost of losses related to an
attacker using an employee's identity that stemmed from the attack.
3.2 Cyber Insurance Requirements for Applicants

Most cyber insurance companies require some up-front mitigating risk controls to be in place to
minimize both the likelihood of an event and the impact if an event does occur. Some of those
controls include the following:
Background Checks: Understanding the criminal records of the employees given access
to a company's systems is critical in protecting IT assets. This is usually an item on an
application checklist.
Compliance With Regulations: This includes attestation that the organization is compliant
with applicable regulations such as HIPAA or PCI-DSS, especially for companies that collect
individual health or financial data.
Disaster Recovery: This includes the existence of a disaster recovery plan and regularly
testing that the recovery mechanisms in place work.
Employee Training: Educating employees on common schemes like phishing scams helps
protect against cyberattacks. Implementing phishing tests or other security programs may
reduce premiums.
Company Policies: Insurance carriers often request copies of personnel policies that cover
security as it relates to employees, customers, and vendors. These policies usually specify
acceptable use and access to data, how company devices should be used, and prohibited
practices by vendors and employees.
Independent Risk Assessment: Usually performed by a third party, IT risk assessments
help insurance companies ascertain weaknesses that could put the insured at risk for
an incident.
Incident Response Plans: Carriers typically look for IRP in place and how they deal with a
cyber incident. For plans that are not robust in incident response planning, premiums may
be higher.
IT Controls: Standard IT security controls are part of any cybersecurity application checklist
which generally include firewalls, intrusion detection or prevention systems, antivirus or
endpoint software, controlled access to assets, and modern authentication tools such as
multifactor authentication (MFA).
Mandatory Pen Testing: Some insurers are making penetration testing a requirement as
part of the application process. Companies with harder to intrude/penetrate systems may
get a lower premium.
Loss History: Carriers evaluating new clients typically review losses from any prior
incidents and price the risk for that client based on those losses, as well as all of the other
factors above.

reserved.
ISC
4
System and Organization
Controls (SOC) Engagements
Module
1 SOC Engagement Categories and Types 3
2 Reporting on SOC Engagements: Part 1 13
3 Reporting on SOC Engagements: Part 2 41
4 Planning and Risk Assessment in a SOC Engagement 65
5 Performing SOC Engagements 79

NOTES

1
MODULE
SOC Engagement
Categories and Types ISC 4
1 Overview of SOC Engagements
Organizations often engage in business relationships with other entities to outsource key
services and business operations. The organization utilizing the outsourced services is
considered the user entity, and the outside organization providing services is known as the
service organization. A service organization provides the user entity with the benefits of its
personnel, expertise, equipment, and technology to operate tasks and functions that the user
entity wishes to outsource.
Examples of the types of services provided by service organizations:
Outsourced Payroll Processors: Service organizations that provide payroll services to
user entities.
Cloud Service Providers: Third-party organizations offering a cloud-based platform,
infrastructure, application, or storage services.
Credit Card Processing Organizations: Companies that process payments for merchants
by offering an infrastructure that routes payment from customer banks or financial
institutions to retailers.
Enterprise IT Outsourcing Services: IT-managed service providers that manage, operate,
and maintain user entities’ IT data centers, infrastructure, and application systems.
Financial Technology (FinTech) Services: Financial institutions that provide IT-based
transaction processing services such as servicing loans, payment processing, and
asset management.
Customer Support: Organizations that provide customers of user entities online or
telephonic customer support and service management.
User entities and business partners, entities with which another commercial entity has some
form of alliance such as their external auditor, usually need information about the design,
operation, and effectiveness of controls within the service organization’s system. To support risk
assessment procedures, user entities may request a System and Organizational Controls (SOC)
report from the service organization. An independent CPA, referred to as the service auditor,
performs a SOC examination in accordance with attestation standards issued by the American
Institute of Certified Public Accountants (AICPA).
1.1 Types of SOC Engagements

SOC engagements assess the effectiveness of a service organization’s controls. These
engagements, which result in the issuance of a SOC report, promote reliance by third parties on
service organizations.
© Becker Professional Education Corporation. All rights reserved. Module 1 S4–3 SOC Enga
1 SOC Engagement Categories and Types ISC 4
There are three main types of SOC engagements including SOC 1®, SOC 2®, and SOC 3®:
SOC 1® for Service Organizations: Internal Control over Financial Reporting (SOC 1®
engagement). The examination and reporting on controls at a service organization that are
likely to be relevant to user entities’ internal control over financial reporting.
SOC 1® reports are restricted to management of the service organization, user entities of the
service organization’s system, and the independent auditors of such user entities. It does
not include potential users of the service organization.
SOC 2® for Service Organizations: Trust Services Criteria (SOC 2® engagement). The
examination and reporting on the security, availability, or processing integrity of a system,
or the confidentiality or privacy of the information processed by the system (the AICPA’s five
trust services categories).
SOC 2® reports are intended for use by those who have sufficient knowledge and
understanding of the service organization, the services it provides, and the system used to
provide those services, among other matters. Management and the service auditor should
agree on the intended users of the report (specified parties).
The expected knowledge of specified parties ordinarily includes the following:
y The nature of the service provided by the user organization
y Service organization’s system interactions with user entities, subservice organizations,
and other parties
y Internal control and its limitations
y Complementary user entity controls
y Complementary subservice organizational controls
y User entity responsibilities and their impact to effectively use the service
organization’s services
y The applicable trust services criteria
y The risks that may impact the service organization’s service commitments and system
requirements, and how controls address those risks
SOC 3® for Service Organizations: Trust Services Criteria for General Use Report
(SOC 3® engagement). Similar to the requirements and guidance for performing a SOC
2® engagement, the service auditor reports on whether controls within the system
were effective to provide reasonable assurance that the service organization’s service
commitments and system requirements were achieved based on the applicable trust
services criteria. The reporting requirements are different from a SOC 2® report; a SOC 3®
report does not include a description of the system (detailed controls within the system are
not disclosed), a description of the service auditor’s tests of controls, and the results thereof.
A SOC 3® report is ordinarily for general users who need assurance about the controls at a
service organization relevant to security, availability, processing integrity, confidentiality, or
privacy, but lack the knowledge and understanding for a SOC 2® report.
Other SOC engagements include the following:
SOC for Cybersecurity Engagement: Examine and report on a description of the entity’s
cybersecurity risk management program and the effectiveness of controls with that program.
SOC for Supply Chain Engagement: Examine and report on an entity’s controls over the
security, availability, processing integrity, confidentiality, or privacy of a system used to
produce, manufacture, or distribute products.
S4–4 Module 1 SOC Engagement

© Becker Professional Education Categories
Corporation. All and Types
rights reserved.
ISC 4 1 SOC Engagement Categories and Types
1.1.1 Types of SOC Reports

At the completion of a SOC engagement, the practitioner issues a report showing the findings.
SOC reports differ depending on the type of SOC engagement completed and whether the
report issued is a Type 1 or Type 2 report.
Type 1
A report on the fairness of the presentation of management’s description of the service
organization’s system and the suitability of the design of the controls to achieve the related
control objectives included in the description as of a specified date.
Type 2
A report on the fairness of the presentation of management’s description of the service
organization’s system and the suitability of the design and operating effectiveness of the
controls to achieve the related control objectives included in the description throughout a
specified period.
SOC 1® and SOC 2® reports can be issued as either Type 1 or Type 2 reports depending on the
needs of the user, but a SOC 3® report is always issued as a Type 2 report.
Illustration 1 SOC 1® Use
Wyatt Co., a financial advising company, utilizes a third-party service provider named
Database Inc. to process its sales contracts and store information about its clients. Wyatt
Co.'s auditors want to ensure that the controls in place at Database Inc. are designed and
operating effectively because control deficiencies at Database Inc. would negatively affect
Wyatt Co. and its clients. Wyatt Co.'s auditors gain comfort by obtaining and reviewing
the attestation to fairness of the controls and their operations within the System and
Organization Controls (SOC 1®) Type 2 report because it gives them assurance that this has
been in place over the last six months.
1.1.2 Contents of Type 1 and Type 2 SOC reports

The main components of a SOC report are consistent for both SOC 1® and SOC 2® engagements.
A service auditor’s Type 1 report is typically comprised of the following:
Management’s description of the service organization’s system.
A written assertion by management of the service organization about whether, as of a
specified date, based on the criteria:
y Management’s description of the system fairly presents the service organization’s
system that was designed and implemented.
y The controls related to the control objectives stated in management’s description of the
system were suitably designed to achieve those control objectives.
A report that expresses an opinion on the matters described above.
A service auditor’s Type 2 report is comprised of the following:
Management’s description of the service organization’s system.
A written assertion by management of the service organization about whether, throughout a

specified period, based on the criteria:
y Management’s description of the system fairly presents the service organization’s
system that was designed and implemented.
y The controls related to the control objectives stated in management’s description
of the system were suitably designed and operated effectively to achieve those
control objectives.
A report that expresses an opinion on the matters described above and includes a
description of the tests of controls and the results.
Pass Key
Key Differences Between Type 1 and Type 2 SOC Reports

A Type 1 report covers the system design as of a given point in time whereas a Type 2
report covers both the design and operating effectiveness over a period of time.
1.2 Summary of SOC Reports

Report
Type Subject Matter Types Purpose Use of Report
SOC 1 ®
Assesses controls Type 1 Provides information and Restricted to
relevant to financial a service auditor’s opinion management
reporting. Type 2 about controls at a service of the service
organization likely relevant to organization,
financial reporting. Enables the user entities, and
user auditor to perform risk auditors.
assessment procedures.
Uses a Type 2 report as audit

evidence that controls at
the service organization are
operating effectively.
SOC 2® Assesses controls Type 1 Provides information and Restricted to
relevant to security, a service auditor’s opinion management
Type 2
availability, about controls at a service and other
processing organization relevant to specified parties.
integrity, security, availability, processing
confidentiality, or integrity, confidentiality, or
privacy. privacy.
SOC 3® Assesses controls Type 2 Provides a service auditor’s Not restricted.
relevant to security, only opinion about controls at a Users are
availability, service organization relevant to interest parties.
processing security, availability, processing
integrity, integrity, confidentiality, or
confidentiality, or privacy.
privacy.

rights reserved.
2 Trust Services Criteria
2.1 Applicability of the Trust Services Criteria to SOC 2® and SOC 3®

Engagements
Due to the nature of a system of internal controls, entities face certain risks that threaten
their ability to achieve their objectives. Due to these inherent risks, entities are responsible
for designing and implementing suitable controls to mitigate the risks. The AICPA’s Assurance
Services Executive Committee (ASEC) has established trust services criteria that set forth
the outcomes that an entity’s controls should meet to achieve the entity’s unique objectives.
This enables practitioners to evaluate and report on controls over the security, availability,
processing integrity, confidentiality, or privacy of information and systems for SOC 2® and SOC
3® engagements. The report can be based on any of the five trust services categories, either
individually or in combination. These categories include security, availability, processing integrity,
confidentiality, and privacy.
The security category is addressed in most trust services engagements. Security controls are
generally a primary area of focus for system users because organizations and their customers
and business partners have an increased dependence on technology and concerns about
cybersecurity risks and their impact on operational processes. Although uncommon, there
may be circumstances in which the security category is not addressed by a trust services
engagement.
2.2 Trust Services Criteria

2.2.1 Trust Services Categories
The five trust services categories can be remembered using the mnemonic “CAPPS”:
Confidentiality: Information designated as confidential is protected to meet the
entity’s objectives.
Availability: Information and systems are available for operation and use to meet the
entity’s objectives.
Processing Integrity: System processing is complete, valid, accurate, timely, and authorized
to meet the entity’s objectives.
Privacy: Personal information is collected, used, retained, disclosed, and disposed of to
meet the entity’s objectives.
Security: Information and systems are protected against unauthorized access;
unauthorized disclosure of information; and damage to systems that could compromise the
availability, integrity, confidentiality, and privacy of information or systems and affect the
entity’s ability to meet its objectives.
2.2.2 Application and Use of the Trust Services Criteria

The trust services criteria were designed to provide flexibility in application and use for a variety
of different subject matters. The types of subject matter a practitioner may be engaged to report
on using the trust services criteria include the following:
SOC for cybersecurity engagement—the effectiveness of controls within an entity’s
cybersecurity risk management program to achieve the entity’s cybersecurity objectives
using the trust services criteria relevant to security, availability, and confidentiality as
control criteria.
SOC 2® engagement:
Type 1: Same subject matter as a Type 2 SOC 2® engagement; however, a Type 1 SOC
2® report does not contain an opinion on the operating effectiveness of controls nor a
detailed description of tests of controls performed by the service auditor and the results of
those tests.
Type 2: The suitability of design and operating effectiveness of controls included in
management’s description of a service organization’s system relevant to one or more of
the trust services criteria over security, availability, processing integrity, confidentiality,
or privacy throughout a specified period to achieve the entity’s objectives based on those
criteria. A Type 2 SOC report includes an opinion on the operating effectiveness of controls,
and a detailed description of tests of controls performed by the service auditor and the
results of those tests.
SOC 3® engagement—the design and operating effectiveness of a service organization’s
controls over a system relevant to one or more of the trust services criteria over security,
availability, processing integrity, confidentiality, and privacy. A SOC 3® report contains
an opinion on the operating effectiveness of controls but does not include a detailed
description of tests of controls performed by the service auditor and the results of
those tests.
The suitability of design and operating effectiveness of controls of an entity, other than a
service organization, over one or more systems relevant to one or more of the trust services
categories of security, availability, processing integrity, confidentiality, or privacy (e.g., a SOC
for supply chain engagement).
The suitability of the design of an entity’s controls over security, availability, processing
integrity, confidentiality, or privacy to achieve the entity’s objectives based on the related
3 The COSO Framework Overview and Alignment to the

Trust Services Criteria
3.1 Overview of the COSO Framework

The AICPA has aligned the trust services criteria with the COSO (Committee of Sponsoring
Organizations of the Treadway Commission) Internal Control—Integrated Framework (the COSO
framework), a widely accepted control framework utilized by entities to establish and implement
an effective system of internal control. The COSO framework includes five components that
are supported by 17 principles. The trust services criteria have been aligned to the 17 COSO
principles, but include additional criteria.
3.1.1 Control Environment

COSO principles 1 through 5 relate to the control environment, which cover control from the
perspective of the board and management through integrity, ethics, the proper corporate
structure, and establishing an environment that holds employees accountable.
1. The entity demonstrates a commitment to integrity and ethical values.
2. The board of directors demonstrates independence from management and exercises
oversight of the development and performance of internal control.
3. Management establishes, with board oversight, structures, reporting lines, and appropriate
authorities and responsibilities in the pursuit of objectives.

rights reserved.
4. The entity demonstrates a commitment to attract, develop, and retain competent

individuals in alignment with objectives.
5. The entity holds individuals accountable for their internal control responsibilities in the
pursuit of objectives.
3.1.2 Risk Assessment

COSO principles 6 through 9 relate to the risk assessment component of the COSO framework.
They focus on identifying risk, considering the potential for fraud, and understanding changes
that could impact internal controls.
6. The entity specifies objectives with sufficient clarity to enable the identification and
assessment of risks relating to objectives.
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.
8. The entity considers the potential for fraud in assessing risks to the achievement of objectives.
9. The entity identifies and assesses changes that could significantly impact the system of
internal control.
3.1.3 Control Activities

COSO principles 10 through 12 relate to the control activities implemented and designed
to ensure the proper application of policies and procedures that help ensure management
directives and control objectives are met.
10. The entity selects and develops control activities that contribute to the mitigation of risks to
the achievement of objectives to acceptable levels.
11. The entity also selects and develops general control activities over technology to support the
achievement of objectives.
12. The entity deploys control activities through policies that establish what is expected and
procedures that put policies into action.
The trust services criteria expand on principle 12 by adding four common criteria referred to
as the trust services supplemental criteria:
y Logical and Physical Access Controls: Relates to how an entity restricts, provides, and
removes access and prevents unauthorized access.
y System Operations: Relates to how an entity detects and mitigates processing
deviations, including logical and physical security deviations.
y Change Management: Relates to how an entity manages changes and prevents
unauthorized changes from being made.
y Risk Mitigation: Relates to how an entity manages risk mitigation activities arising from
potential business disruptions and the use of vendors and business partners.
3.1.4 Information and Communication

COSO principles 13 through 15 focus on obtaining, generating, and controlling information
and communication.
13. The entity obtains or generates and uses relevant, quality information to support the
functioning of internal control.
14. The entity internally communicates information, including objectives and responsibilities for
internal control, necessary to support the functioning of internal control.
15. The entity communicates with external parties regarding matters affecting the functioning
of internal control.
3.1.5 Monitoring Activities

COSO principles 16 and 17 relate to monitoring activities, which outline how an organization
should conduct ongoing evaluations of control activities and communicate internal
control deficiencies.
16. The entity selects, develops, and performs ongoing and/or separate evaluations to ascertain
whether the components of internal control are present and functioning.
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, as appropriate.
3.2 Alignment of the Trust Services Criteria and the COSO Principles
The trust services criteria consist of:
criteria common to all five of the trust services categories (common criteria); and
additional specific criteria for the availability, processing integrity, confidentiality, and
privacy categories.
3.2.1 Overview
Trust Services Common Additional Category-
Category Criteria Specific Criteria
N/A, common criteria is suitable
Security 
with no additional criteria
Availability  A series
Processing
 PI series
Integrity
Confidentiality  C series
Privacy  P series
3.2.2 Additional Criteria for Availability (A series)

The additional criteria for availability focus on an entity’s ability to ensure all systems are
continuously available as needed by maintaining and monitoring processing capacity, identifying
and responding to threats, and ensuring a recovery plan is in place and tested.
A1.1: The entity maintains, monitors, and evaluates current processing capacity and use
of system components to manage capacity demand and to enable the implementation of
additional capacity to meet entity objectives.
A1.2: The entity ensures systems are available by identifying environmental threats,
designing detection measures, implementing protection mechanisms and alerts, responding
to environmental threats, communicating threat events, performing data backup, ensuring
there is offsite storage, implementing an alternate infrastructure, and considering data
recoverability to meet entity objectives.
A1.3: The entity tests its recovery plan procedures to ensure system recovery meets
entity objectives.

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3.2.3 Additional Criteria for Processing Integrity (PI series)

The additional criteria for process integrity include considerations related to creating, using,
and communicating quality information so that objectives will be met regarding product/service
specifications, controls for completeness and accuracy, productivity, and system specifications.
PI1.1: The entity obtains or generates, uses, and communicates relevant, quality information
regarding processing objectives to support the use of products and services.
PI1.2: The entity implements policies and procedures over system inputs to result in
products, services, and reporting that meet entity objectives.
PI1.3: The entity implements policies and procedures over system processing to result in
products, services, and reporting that meet entity objectives.
PI1.4: The entity implements policies and procedures to make available or deliver output
completely, accurately, and timely that meet entity objectives.
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 objectives.
3.2.4 Additional Criteria for Confidentiality (C series)

The additional criteria for confidentiality relate to ensuring confidential information is
handled appropriately.
C1.1: The entity identifies and maintains confidential information to meet the entity’s
confidentiality objectives.
C1.2: The entity disposes of confidential information to meet the entity’s confidentiality
objectives.
3.2.5 Additional Criteria for Privacy (P series)

The additional criteria for privacy relate to collecting personal data, obtaining consent when
collecting and using that data, using data for specific purposes only, managing access to
individuals’ data responsibly, disclosing policies to third parties and individuals properly,
maintaining complete and accurate records, and monitoring and enforcing practices in place.
P1.0: Notice and Communication of Objectives Related to Privacy
P2.0: Choice and Consent
P3.0: Collection
P4.0: Use, Retention, and Disposal
P5.0: Access
P6.0: Disclosure and Notification
P7.0: Quality
P8.0: Monitoring and Enforcement
NOTES

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2
MODULE
Reporting on SOC
Engagements: Part 1 ISC 4
1 Forming the Opinion in a SOC Engagement
The service auditor should form an opinion about the subject matter of the engagement. When
forming the opinion, the service auditor should evaluate:
the sufficiency and appropriateness of the evidence obtained; and
whether uncorrected misstatements, individually or in the aggregate, are material.
In a SOC engagement, the service auditor forms an opinion about whether the subject matter
is in accordance with (or based on) the criteria, in all material respects, or the assertion is fairly
stated in all material respects. The opinion of the service auditor focuses on:
Fair presentation of management’s description of the service organization’s system.
The suitability of the design of the controls related to the control objectives stated in
management’s description.
The effective operation of the controls stated in management’s description (Type 2 only).
The overall objectives of a SOC 1® and SOC 2® engagement are consistent, however, the subject
matter for which an opinion is being formed is different. In a SOC 1® engagement, the service
auditor forms an opinion regarding the controls at a service organization relevant to the user
entities’ internal control over financial reporting. In a SOC 2® engagement, the service auditor
forms an opinion regarding the controls at a service organization relevant to one or more of the
five trust services criteria, which include security, availability, processing integrity, confidentiality,
and privacy.
2 Types of Opinions in a SOC Engagement
When a service auditor concludes a SOC 1® or SOC 2® engagement, the report will contain the
service auditor’s opinion pertaining to the controls examined. The service auditor reaches his or
her opinion by determining whether:
The description of the controls is presented fairly by management.
The controls are designed effectively.
The controls operate as intended over a specified period of time (Type 2 only).
The opinions of the service auditor in a SOC engagement depend on the facts and circumstances
of the evidence gathered throughout the engagement and may include an:
unmodified (unqualified) opinion;
qualified opinion;
adverse opinion; or
disclaimer of an opinion.
© Becker Professional Education Corporation. All rights reserved. Module 2 S4–13 Reporting
2 Reporting on SOC Engagements: Part 1 ISC 4
2.1 Unmodified (Unqualified) Opinion

An unmodified opinion is the service auditor’s opinion that, in all material respects, based on the
criteria described in management’s assertion:
1. Management’s description of the system fairly presents the system that was designed
and implemented.
y SOC 1®: Management’s description of the service organization’s system fairly presents
the service organization’s system that was designed and implemented as of a specified
date (Type 1) or throughout the specified period (Type 2).
y SOC 2®: Management’s description of the service organization’s system presents the
service organization’s system that was designed and implemented in accordance with
the description criteria, as of a specified date (Type 1) or throughout the specified
period (Type 2).
2. The controls stated in management’s description of the system were suitably designed.
y SOC 1®: The controls related to the control objectives statement in management’s
description of the service organization’s system were suitably designed to achieve
the control objectives as of the specified date (Type 1) or throughout the specified
period (Type 2).
y SOC 2®: The controls stated in management’s description were suitably designed to
provide reasonable assurance that the service organization’s service commitments and
system requirements were achieved based on the applicable trust services criteria as of
the specified date (Type 1) or throughout the specified period (Type 2).
3. The controls stated in management’s description of the system operated effectively
(Type 2 only).
y SOC 1®: The controls related to the control objectives stated in management’s
description of the system operated effectively throughout the specified period to
achieve the control objectives.
y SOC 2®: The controls stated in management’s description of the system operated
effectively throughout the specified period to provide reasonable assurance that the
service organization’s service commitments and system requirements were achieved
based on the applicable trust services criteria.
If the application of complementary user entity controls is necessary to achieve the related
control objectives stated in management’s description of the service organization’s system, a
statement to that effect has been made.
If the application of complementary subservice organization controls is necessary to achieve
the related control objectives stated in management’s description of the service organization’s
system, a statement to that effect has been made.
2.2 Modifications to the Service Auditor’s Opinion

The service auditor is required to modify the opinion when either of the following circumstances
exist and, in the service auditor’s professional judgment, the effect of the matter is or may
be material:
The service auditor is unable to obtain sufficient appropriate evidence to conclude that the
subject matter is in accordance with (or based on) the criteria, in all material respects.
The service auditor concludes, based on evidence obtained, that the subject matter is not in
accordance with (or based on) the criteria, in all material respects.
S4–14 Module 2 Reporting

© Becker Professional Education on SOCAllEngagements:
Corporation. rights reserved.Part 1
ISC 4 2 Reporting on SOC Engagements: Part 1
The service auditor’s opinion should be modified, and the service auditor’s report should include
a description of the matter or matters giving rise to the modification, if the service auditor
concludes any of the following:
SOC 1® engagement:
y Management’s description of the service organization’s system is not fairly presented, in
all material respects.
y The controls are not suitably designed to provide reasonable assurance that the control
objectives stated in management’s description of the service organization’s system
would be achieved if the controls operated effectively, in all material respects.
y The controls did not operate effectively throughout the specified period to achieve
the related control objectives stated in management’s description of the service
organization’s system, in all material respects (Type 2 only).
y The service auditor is unable to obtain sufficient and appropriate evidence.
SOC 2® engagement:
y Management’s description of the service organization’s system does not present the
system designed and implemented throughout the period in accordance with the
description criteria, in all material respects.
y The controls are not suitably designed to provide reasonable assurance that the service
organization’s service commitments and system requirements would be achieved
based on the applicable trust services criteria if the controls operated effectively, in all
material respects.
y The controls did not operate effectively throughout the specified period to provide
reasonable assurance that the service organization’s service commitments and system
requirements were achieved based on the applicable trust services criteria, in all
material respects (Type 2 only).
y The service auditor is unable to obtain sufficient and appropriate evidence.
The service auditor determines whether a qualified opinion, an adverse opinion, or a disclaimer
of opinion is appropriate depending on the following:
The nature of the matter giving rise to the modification (that is, whether the subject matter
of the engagement is presented in accordance with [or based on] the criteria, in all material
respects, or, in the case of an inability to obtain sufficient appropriate evidence, may be
materially misstated).
The service auditor’s professional judgment about the pervasiveness of the effects, or
possible effects, of the matter on the subject matter of the engagement.
2.2.1 Types of Modified Opinions

There are three types of modified opinions:
Qualified Opinion: A qualified opinion states that except for the effects of the matter(s)
giving rise to the modification, the description is presented in accordance with the
description criteria and the controls were suitably designed and operating effectively (Type
2), in all material respects.
Adverse Opinion: An adverse opinion states that the description misstatements, either
individually or in the aggregate, are material and pervasive, or deficiencies in the design or
operation of controls are material and pervasive.
Disclaimer of Opinion: A disclaimer of opinion states that the auditor does not express
an opinion.
2.2.2 Summary of Modified Opinions

The chart below summarizes the nature of matters giving rise to the service auditor’s
opinion modification:
Service Auditor’s Professional

Judgment About the Pervasiveness
of the Effects (or Possible Effects)
on the Opinion on the Description,
Nature of Matter Nature of Matter on the Suitability of the Design of
Giving Rise to the Giving Rise to the Controls, and on the Operating
Modification (SOC 1®) Modification (SOC 2®) Effectiveness of Controls
Material but Not Material and
Pervasive Pervasive
Scope limitation: An Scope limitation: An Qualified opinion Disclaimer of
inability to obtain inability to obtain opinion
sufficient appropriate sufficient appropriate
evidence. evidence.
Material misstatements: Material misstatements: Qualified opinion Adverse opinion
The description is The description is
materially misstated. materially misstated.
OR OR
The controls are not The controls are not
suitably designed to suitably designed to
achieve one or more provide reasonable
of the related control assurance that one or
objectives stated more of the service
in management’s organization’s service
description of the service commitments or system
organization’s system. requirements were
achieved based on the
OR
applicable trust services
The controls are not criteria.
operating effectively to
OR
achieve one or more
of the related control The controls are not
objectives stated operating effectively
in management’s to provide reasonable
description of the service assurance that one or
organization’s system. more of the service
organization’s service
commitments or system
requirements were
achieved based on the
applicable trust services
criteria.

3 Contents of the Auditor’s Report for a SOC Engagement
The SOC report includes the following key components:

1. Management’s description of the system
2. Management’s assertion
3. Independent auditor’s report
4. Auditor’s tests of controls and results of tests
3.1 Management’s Description of the System

3.1.1 SOC 1® Purpose and Common Sections of Management’s System Description
A SOC 1® engagement is an examination to report on a service organization’s controls relevant
to user entities’ internal control over financial reporting.
The service organization’s management is responsible for documenting the description of the
service organization’s system. The description must provide sufficient information to allow a
user auditor to understand how the service organization’s processing affects the user entity’s
financial statements and to assess the risk of material misstatement of the user entity’s financial
statements. The form and extent of the description are determined by management and may
depend on the size and complexity of the service organization.
Common sections of a system description subject to SOC 1® engagements include:
Types of services provided—defined scope of services provided and the classes of
transactions processed.
Procedures performed—procedures, within both manual and automated systems, by which
services are provided, including procedures to initiate, authorize, record, process, correct,
and transfer transactions to reports and other information for user entities.
System functionality—how the system captures and addresses significant events and
conditions (other than transactions).
Subservice organizations—services performed by entities the service organization uses
to provide services to the user entity, including whether the carve-out method or the
inclusive method has been used, and any complementary subservice organizational controls
necessary to meet control objectives.
Controls—a description of the control objective and design to achieve those objectives,
including the frequency, timing, person or parties responsible for performance, and the
source of information to which the control is applied.
Information on other aspects of the control environment, risk assessment process,
information and communication, control activities, and monitoring activities that are
relevant to the services provided.
Prepare reports—process to prepare reports and other information for user entities.
Deficiencies in information—if applicable, information used in the performance of the
procedures (if applicable, related accounting records and supporting information) to initiate,
authorize, record, process, and report transactions. This includes the correction of incorrect
information and how information is transferred to the report, and other information
prepared for user entities.
Complementary user entity controls (CUECs)—controls that must be implemented by the

user entity to meet control objectives.
Relevant details of changes to the service organization’s system during the period covered
by the description (Type 2 only).
The description does not omit or distort information relevant to the system and is prepared
to meet the common needs of a broad range of user entities and their auditors, and
thus may not include every aspect that a user entity may consider important in its own
particular environment.
3.1.2 SOC 2® Purpose and Common Sections of Management’s System Description

A SOC 2® engagement is an examination of a service organization’s description of its system, the
suitability of the design of controls, and in a Type 2 engagement, the operating effectiveness of
controls relevant to security, availability, processing integrity, confidentiality, and privacy.
The service organization’s management is responsible for presenting a description of the
system to enable report users, such as user entities, business partners, or other relevant
parties, to understand the system and the processing and flow of data throughout and from the
system. The description is to be prepared in accordance with specific criteria and describes the
procedures and controls in place to manage risk.
Common sections of a system description subject to a SOC 2® engagement include:
Types of services provided—types of services provided by service organizations, including
the services that are the focus of the engagement.
Principal service commitments and system requirements—the commitments made to user
entities and the system requirements required to achieve such commitments.
y Service commitments—declarations made by service organization management to user
entities and others (such as user entities’ customers) about the system used to provide
the service.
y System requirements—specifications regarding how the system should function to
meet the service organization’s service commitments to user entities and others (such
as user entities’ customers), to meet the service organization’s commitments to vendors
and business partners, to comply with relevant laws and regulations and guidelines of
industry groups (such as business or trade associations), and to achieve other objectives
of the service organization that are relevant to the trust services category or categories
addressed by the description.
Components of the system used to provide the services—infrastructure, software, people,
procedures, and data.
Identified system incidents—incidents that were the result of controls that were not suitably
designed or operating effectively or that resulted in a significant failure in the achievement
of one or more service commitments and system requirements. The nature, extent (or
effect), and timing of the system incident and its disposition (based on management’s
judgment) that occurred as of the date of the description (Type 1) or during the period of
time covered by the description (Type 2).
Applicable trust services criteria—the trust services criteria being reported on, including
applicable controls in place to provide reasonable assurance that the service commitments
and system requirements were achieved.
Complementary user entity controls (CUECs)—the controls implemented by the user entity
that are necessary, in combination with controls at the service organization, to provide
reasonable assurance that the service commitments and system requirements would
be achieved.

Subservice organizations—a subservice organization used by the service organization and

the controls at the subservice organization are necessary, in combination with controls at
the service organization, to provide reasonable assurance that the service commitments
and system requirements would be achieved.
y Inclusive method—nature of the service provided, controls, portions of the system
attributable to the subservice organization along with relevant aspects (e.g.,
infrastructure, software, people, procedures, data).
y Carve-out method—nature of the service provided, types of controls along with the
applicable trust services criteria that are intended to be met by the complementary
subservice organization controls (CSOCs).
Irrelevant specific criteria—explanations for why specific trust services criteria are not
relevant for the service organization’s system.
Details of system and control changes during the period that are relevant to the service
organization’s service commitments and system requirements (Type 2 only).
3.1.3 Management’s Description of the Entity’s Cybersecurity Risk Management

Program
An entity’s cybersecurity risk management program is a set of policies, processes, and controls
designed to:
protect information and systems from security events that could compromise the
achievement of the entity’s cybersecurity objectives; and
detect, respond to, mitigate, and recover from, on a timely basis, security events that are
not prevented.
The categories of description criteria include the following:
1. Nature of business and operations
2. Nature of information at risk
3. Cybersecurity risk management program objectives (cybersecurity objectives)
4. Factors that have a significant effect on inherent cybersecurity risks
5. Cybersecurity risk governance structure
6. Cybersecurity risk assessment process
7. Cybersecurity communications and the quality of cybersecurity information
8. Monitoring of the cybersecurity risk management program
9. Cybersecurity control processes
The cybersecurity risk management examination is predicated on the concept that management
is responsible for developing and presenting a description of the entity’s cybersecurity risk
management program, making an assertion about whether the description is presented in
accordance with the description criteria, and making an assertion about the effectiveness of the
controls within the program based on a set of control criteria.
3.2 Management’s Assertions

In a SOC engagement, the service auditor is required to request a written assertion
from management.
In a SOC 1® or SOC 2® engagement, management’s assertion addresses whether:
1. Management’s description of the system fairly presents the system that was designed and
implemented.
y SOC 1®: Management’s description of the service organization’s system fairly presents
the service organization’s system that was designed and implemented as of a specified
date (Type 1) or throughout the specified period (Type 2).
y SOC 2®: Management’s description of the service organization’s system presents the
service organization’s system that was designed and implemented in accordance with
the description criteria, as of a specified date (Type 1) or throughout the specified
period (Type 2).
2. The controls stated in management’s description of the system were suitably designed.
y SOC 1®: The controls related to the control objectives statement in management’s
description of the service organization’s system were suitably designed to achieve the
control objectives as of the specified date (Type 1) or throughout the specified period
(Type 2).
y SOC 2®: The controls stated in management’s description were suitably designed to
provide reasonable assurance that the service organization’s service commitments and
system requirements were achieved based on the applicable trust services criteria as of
the specified date (Type 1) or throughout the specified period (Type 2).
3. The controls stated in management’s description of the system operated effectively
(Type 2 only).
y SOC 1®: The controls related to the control objectives stated in management’s
description of the system operated effectively throughout the specified period to
achieve the control objectives.
y SOC 2®: The controls stated in management’s description of the system operated
effectively throughout the specified period to provide reasonable assurance that the
In a SOC 3® engagement, management’s assertion addresses whether:
the controls within the system were effective throughout the specified period to provide
reasonable assurance that the service organization’s service commitments and system
requirements were achieved based on the applicable trust services criteria, including a
description of the boundaries of the system and the service organization’s principal service
commitments and system requirements.
Management’s assertions are included in the SOC report along with the description of the
service organization’s system in the service auditor’s report. If management refuses to provide
a written assertion, the service auditor is required to withdraw from the engagement when
withdrawal is possible under applicable laws and regulations. If law or regulation does not
allow the service auditor to withdraw, the service auditor should disclaim an opinion on the
description, the suitability of design of controls in a Type 1 engagement, and the operating
effectiveness of controls in a Type 2 engagement.

3.2.1 Summary of Management Assertions by Engagement Type
Management’s Assertions by SOC Engagement and Report Type

Report Type SOC 1® SOC 2® SOC 3®
Type 1 Management’s system Management’s
description system description
Management’s written Management’s
assertion about whether written assertion
the description fairly about whether the
presents the system, description fairly
presents the system,
AND
AND
the controls were
suitably designed the controls related
to achieve control to the applicable trust
objectives services criteria were
suitably designed to
meet those criteria
Type 2 Management’s system Management’s Management’s

description system description description
of the service
Management’s written Management’s
organization’s
assertion about whether written assertion
system
the description fairly about whether the
boundaries
presents the system description fairly
and copy of its
that was designed presents the system
privacy notice if
and implemented that was designed
addressing the
throughout the specified and implemented
privacy principle
period, throughout the
specified period, Management’s
AND
written assertion
AND
the controls were concerning
suitably designed the controls were whether effective
throughout the period suitably designed controls over the
to achieve control throughout the system related to
objectives, period to achieve applicable trust
applicable trust services criteria
AND
services criteria,
the controls operated AND
effectively throughout
the period to achieve the controls operated
control objectives effectively throughout
the period to meet
applicable trust
services criteria
4 Contents of the Service Auditor’s Report for a SOC 1®

Engagement
4.1 Contents of the SOC 1® Report

The SOC 1® report includes the following key components:
1. Management’s Description of the System
Management’s description of the system as of a specified date (Type 1) or throughout the
specified period (Type 2).
2. Management’s Assertion
Management assertion that addresses whether, based on the criteria in a
management’s assertion:
y Management’s description of the service organization’s system fairly presents the
service organization’s system that was designed and implemented as of a specified date
(Type 1) or throughout the specified period (Type 2).
y The controls related to the control objectives stated in management’s description of
the service organization’s system were suitability designed to achieve those control
objectives as of the specified date (Type 1) or throughout the specified period (Type 2).
service organization’s system operated effectively to achieve those control objectives
(Type 2 only).
3. Independent Service Auditor’s Report
The service auditor’s opinion about whether:
service organization’s system that was designed and implemented as of a specified
date (Type 1).
y The controls related to the control objectives stated in management’s description of
the service organization’s system were suitability designed to achieve those control
objectives as of the specified date (Type 1).
service organization’s system operated effectively to achieve those control objectives
(Type 2 only).
4. Auditor’s Tests of Controls and Results of Tests
Description of the service auditor’s tests of controls and results thereof (Type 2 only).

4.1.1 Elements of the Service Auditor’s SOC 1® Report

The elements to be included in a service auditor’s SOC 1® report include:
Independent Service Auditor’s SOC 1® Report

Title A title that includes the word independent.
Addressee An appropriate addressee as required by the circumstances of the engagement.
Scope Identification of the following:

Management’s description of the service organization’s system, the function
performed by the system, and the period to which the description relates.
The criteria against which the fairness of the presentation of the description and
the suitability of the design and operating effectiveness (Type 2) of the controls to
achieve the related control objectives stated in the description were evaluated.
Any information included in a document containing the service auditor’s report that
is not covered by the service auditor’s report.
Any services performed by a subservice organization and whether the carve-out
method or the inclusive method was used in relation to them.
If the carve-out method was used, a statement that:
— Management’s description of the service organization’s system excludes the
control objectives and related controls of the relevant subservice organizations.
— Certain control objectives specified by the service organization can be achieved
only if complementary subservice organization controls assumed in the design of
the service organization’s controls are suitably designed and operating effectively.
— The service auditor’s procedures do not extend to such complementary
subservice organization controls.
If the inclusive method was used, a statement that:
— Management’s description of the service organization’s system includes the
subservice organization’s specified control objectives and related controls,
and that the service auditor’s procedures included procedures related to the
subservice organization.
A statement that the controls and control objectives included in the description are
those that management believes are likely to be relevant to user entities’ internal
control over financial reporting, and the description does not include those aspects
of the system that are not likely to be relevant to user entities’ internal control over
financial reporting.
If management’s description of the service organization’s system refers to the need
for complementary user entity controls, a statement that:
— The service auditor has not evaluated the suitability of the design or operating
effectiveness of complementary user entity controls, and that the control
objectives stated in the description can be achieved only if complementary user
entity controls are suitably designed and operating effectively, along with the
controls at the service organization.
Service A reference to management’s assertion and a statement that management is

Organization’s responsible for:
Responsibilities — Preparing the description of the service organization’s system and the assertion,
including the completeness, accuracy, and method of presentation of the
description and assertion.
— Providing the services covered by the description of the service organization’s
system.
— Specifying the control objectives and stating them in the description of the
service organization’s system.
— Identifying the risks that threaten the achievement of the control objectives.
Service — Selecting the criteria.

Organization’s
— Designing, implementing, and documenting controls that are suitably designed
Responsibilities
and operating effectively to achieve the related control objectives stated in the
(continued) description of the service organization’s system.
Service Auditor’s A statement that the service auditor is responsible for expressing an opinion on the
Responsibilities fairness of the presentation of management’s description of the service organization’s
system and on the suitability of the design and operating effectiveness (Type 2) of the
controls to achieve the related control objectives stated in the description based on the
service auditor’s examination.
A statement that:
The examination was conducted in accordance with attestation standards
established by the AICPA.
The standards require the service auditor to plan and perform the examination to
obtain reasonable assurance about whether, in all material respects, based on the
criteria in management’s assertion, management’s description of the system is fairly
presented and the controls are suitably designed and operating effectively (Type
2), as of the specified date (Type 1) or throughout the specified period (Type 2), to
achieve the related control objectives.
The service auditor believes the evidence obtained is sufficient and appropriate to
provide a reasonable basis for the service auditor’s opinion.
A statement that an examination of management’s description of a service
organization’s system and the suitability of the design and operating effectiveness
(Type 2) of the service organization’s controls to achieve the related control objectives
stated in the description involves:
Performing procedures to obtain evidence about the fairness of the presentation of
the description and the suitability of the design and operating effectiveness (Type 2)
of the controls to achieve the related control objectives stated in the description
based on the criteria in management’s assertion.
Assessing the risks that management’s description of the service organization’s
system is not fairly presented and that the controls were not suitably designed or
operating effectively (Type 2) to achieve the related control objectives.
Evaluating the overall presentation of management’s description of the service
organization’s system, suitability of the control objectives stated in the description,
and suitability of the criteria specified by the service organization in its assertion.
Testing the operating effectiveness of those controls that management considers
necessary to provide reasonable assurance that the related control objectives stated
in management's description of the service organization's system were achieved
(Type 2 only).
Inherent A description of the inherent limitations of controls, including that projecting to the
Limitations future any evaluation of the fairness of the presentation of management’s description
of the service organization’s system or conclusions about the suitability of the design or
operating effectiveness (Type 2) of the controls to achieve the related control objectives
is subject to the risk that controls at a service organization may become ineffective.
Description of A reference to a description of the service auditor’s tests of controls and the results,
Tests of Controls including:
(Type 2 only) The controls that were tested.
Whether the items tested represent all or a selection of items in the population.
The nature of the tests in sufficient detail for user auditors to determine the effect of
such tests on their risk assessment.
Any identified deviations in the operation of controls included in the description,
the extent of testing performed by the service auditor that identified deviations
(including the number of items tested), and the number and nature of deviations
noted (even if, on the basis of tests performed, the service auditor concludes that
the related control objective was achieved).

Description of When applicable, if the work of the internal audit function has been used in a test
Tests of Controls of controls to obtain evidence, a description of the internal auditor’s work and the
(Type 2 only) service auditor’s procedures with respect to that work.
(continued)
Other Matter A statement that the service auditor did not perform any procedures regarding the
(Type 1 only) operating effectiveness of controls and, therefore, expresses no opinion thereon.
Opinion The service auditor’s opinion on whether, in all material respects, based on the criteria
described in management’s assertion:
Management’s description of the service organization’s system fairly presents
the service organization’s system that was designed and implemented as of the
specified date (Type 1) or throughout the specified period (Type 2).
The controls related to the control objectives stated in management’s description
of the service organization’s system were suitably designed to provide reasonable
assurance that the control objectives would be achieved if the controls operated
effectively as of the specified date (Type 1) or throughout the specified period
(Type 2).
The controls operated effectively to provide reasonable assurance that the control
objectives stated in management’s description of the service organization’s system
were achieved throughout the specified period (Type 2 only).
If the application of complementary user entity controls is necessary to achieve
the related control objectives stated in management’s description of the service
organization’s system, a statement to that effect.
If the application of complementary subservice organization controls is necessary
to achieve the related control objectives stated in management’s description of the
service organization’s system, a statement to that effect.
Restricted Use An alert, in a separate paragraph, that restricts the use of the report. The alert should
state:
The report, including the description of tests of controls and results (Type 2),
is intended solely for the information and use of management of the service
organization, user entities of the service organization’s system as of the specified
date (Type 1) or during some or all of the period covered by the report (Type 2), and
the auditors who audit and report on such user entities’ financial statements or
internal control over financial reporting.
The report is not intended to be, and should not be, used by anyone other than the
specified parties.
Service Auditor’s The manual or printed signature of the service auditor’s firm.
Signature
Service Auditor’s The city and state where the service auditor practices.
City and State
Date of the Service The date of the report.

Auditor’s Report The report should be dated no earlier than the date on which the service auditor has
obtained sufficient appropriate evidence on which to base the service auditor’s opinion,
including evidence that:
management’s description of the service organization system has been prepared;
management has provided a written assertion; and
the attestation documentation has been reviewed.
Pass Key
Key Differences Between SOC 1® Type 1 and Type 2 Reports

The main differences between a SOC 1® Type 1 and SOC 1® Type 2 report relate to the
addition of expanded language to include the operating effectiveness of control in a Type 2
report. The only section that is fully unique to a Type 2 report (excluded from Type 1
reports) is the reference to the description of the service auditor’s tests of controls and the
related results.
4.1.2 Sample Report: SOC 1® Type 1 Report
Independent Service Auditor’s Report on XYZ Service Organization’s

Description of Its [type or name of] System and the Suitability of the Design of
Controls
To: XYZ Service Organization
Scope
We have examined XYZ Service Organization’s description of its [type or name
of] system titled “XYZ Service Organization’s Description of Its [type or name of]
System” for processing user entities’ transactions [or identification of the function
performed by the system] as of [date] (description) and the suitability of the
design of the controls included in the description to achieve the related control
objectives stated in the description, based on the criteria identified in “XYZ Service
Organization’s Assertion” (assertion). The controls and control objectives included
in the description are those that management of XYZ Service Organization
believes are likely to be relevant to user entities’ internal control over financial
reporting, and the description does not include those aspects of the [type or name
of] system that are not likely to be relevant to user entities’ internal control over
Service Organization’s Responsibilities
In [section number where the assertion is presented], XYZ Service Organization has
provided an assertion about the fairness of the presentation of the description
and suitability of the design of the controls to achieve the related control
objectives stated in the description. XYZ Service Organization is responsible for
preparing the description and assertion, including the completeness, accuracy,
and method of presentation of the description and assertion, providing the
services covered by the description, specifying the control objectives and stating
them in the description, identifying the risks that threaten the achievement of
the control objectives, selecting the criteria stated in the assertion, and designing,
implementing, and documenting controls that are suitably designed and operating
effectively to achieve the related control objectives stated in the description.
(continued)

(continued)
Service Auditor’s Responsibilities

Our responsibility is to express an opinion on the fairness of the presentation of
the description and on the suitability of the design of the controls to achieve the
related control objectives stated in the description, based on our examination.
Our examination was conducted in accordance with attestation standards
established by the American Institute of Certified Public Accountants. Those
standards require that we plan and perform the examination to obtain reasonable
assurance about whether, in all material respects, based on the criteria in
management’s assertion, the description is fairly presented, and the controls
were suitably designed to achieve the related control objectives stated in the
description as of [date]. We believe that the evidence we obtained is sufficient and
appropriate to provide a reasonable basis for our opinion.
An examination of a description of a service organization’s system and the
suitability of the design of controls involves:
Performing procedures to obtain evidence about the fairness of the
presentation of the description and the suitability of the design of the controls
to achieve the related control objectives stated in the description, based on
the criteria in management’s assertion.
Assessing the risks that the description is not fairly presented and that the
controls were not suitably designed to achieve the related control objectives
stated in the description.
Evaluating the overall presentation of the description, suitability of the control
objectives stated in the description, and suitability of the criteria specified by
the service organization in its assertion.
Inherent Limitations
The description is prepared to meet the common needs of a broad range of
user entities and their auditors who audit and report on user entities’ financial
statements and may not, therefore, include every aspect of the system that each
individual user entity may consider important in its own particular environment.
Because of their nature, controls at a service organization may not prevent, or
detect and correct, all misstatements in processing or reporting transactions [or
identification of the function performed by the system]. Also, the projection to the
future of any evaluation of the fairness of the presentation of the description,
or conclusions about the suitability of the design of the controls to achieve
the related control objectives, is subject to the risk that controls at a service
organization may become ineffective.
(continued)
(continued)
Other Matter
We did not perform any procedures regarding the operating effectiveness of
controls stated in the description and, accordingly, do not express an opinion
thereon.
Opinion
In our opinion, in all material respects, based on the criteria described in XYZ
Service Organization’s assertion:
a. The description fairly presents the [type or name of] system that was designed
and implemented as of [date].
b. The controls related to the control objectives stated in the description were
suitably designed to provide reasonable assurance that the control objectives
would be achieved if the controls operated effectively as of [date].
Restricted Use
This report is intended solely for the information and use of management of XYZ
Service Organization, user entities of XYZ Service Organization’s [type or name
of] system as of [date], and their auditors who audit and report on such user
entities’ financial statements or internal control over financial reporting and have
a sufficient understanding to consider it, along with other information, including
information about controls implemented by user entities themselves, when
assessing the risks of material misstatement of user entities’ financial statements.
This report is not intended to be, and should not be, used by anyone other than
the specified parties.
[Service auditor’s signature]
[Service auditor’s city and state]
[Date of the service auditor’s report]

4.1.3 Sample Report: SOC 1® Type 2 Report
Independent Service Auditor’s Report on XYZ Service Organization’s

Description of Its [type or name of] System and the Suitability of the Design
and Operating Effectiveness of Controls
Scope
performed by the system] throughout the period [date] to [date] (description) and
the suitability of the design and operating effectiveness of the controls included in
the description to achieve the related control objectives stated in the description,
based on the criteria identified in “XYZ Service Organization’s Assertion”
(assertion). The controls and control objectives included in the description
are those that management of XYZ Service Organization believes are likely to
be relevant to user entities’ internal control over financial reporting, and the
description does not include those aspects of the [type or name of] system that are
not likely to be relevant to user entities’ internal control over financial reporting.
In [section number where the assertion is presented], XYZ Service Organization has
provided an assertion about the fairness of the presentation of the description
and suitability of the design and operating effectiveness of the controls to
achieve the related control objectives stated in the description. XYZ Service
Organization is responsible for preparing the description and assertion, including
the completeness, accuracy, and method of presentation of the description
and assertion, providing the services covered by the description, specifying the
control objectives and stating them in the description, identifying the risks that
threaten the achievement of the control objectives, selecting the criteria stated
in the assertion, and designing, implementing, and documenting controls that
are suitably designed and operating effectively to achieve the related control
objectives stated in the description.
the description and on the suitability of the design and operating effectiveness
of the controls to achieve the related control objectives stated in the description,
based on our examination.
(continued)
(continued)

were suitably designed and operating effectively to achieve the related control
objectives stated in the description throughout the period [date] to [date]. We
believe that the evidence we obtained is sufficient and appropriate to provide a
reasonable basis for our opinion.
suitability of the design and operating effectiveness of controls involves:
presentation of the description and the suitability of the design and operating
effectiveness of the controls to achieve the related control objectives stated in
the description, based on the criteria in management’s assertion.
controls were not suitably designed or operating effectively to achieve the
related control objectives stated in the description.
Testing the operating effectiveness of those controls that management
considers necessary to provide reasonable assurance that the related control
objectives stated in the description were achieved.
the service organization in its assertion.
Because of their nature, controls at a service organization may not prevent, or
detect and correct, all misstatements in processing or reporting transactions [or
identification of the function performed by the system]. Also, the projection to the
future of any evaluation of the fairness of the presentation of the description,
or conclusions about the suitability of the design or operating effectiveness of
the controls to achieve the related control objectives, is subject to the risk that
controls at a service organization may become ineffective.
Description of Tests of Controls
The specific controls tested, and the nature, timing, and results of those tests are
listed in [section number where the description of tests of controls is presented].
(continued)

(continued)
Opinion
a. The description fairly presents the [type or name of] system that was designed
and implemented throughout the period [date] to [date].
b. The controls related to the control objectives stated in the description were
suitably designed to provide reasonable assurance that the control objectives
would be achieved if the controls operated effectively throughout the period
[date] to [date].
c. The controls operated effectively to provide reasonable assurance that the
control objectives stated in the description were achieved throughout the
period [date] to [date].
Restricted Use
This report, including the description of tests of controls and results thereof in
[section number where the description of tests of controls is presented], is intended
solely for the information and use of management of XYZ Service Organization,
user entities of XYZ Service Organization’s [type or name of] system during some
or all of the period [date] to [date], and their auditors who audit and report on
such user entities’ financial statements or internal control over financial reporting
and have a sufficient understanding to consider it, along with other information,
including information about controls implemented by user entities themselves,
when assessing the risks of material misstatement of user entities’ financial
statements. This report is not intended to be, and should not be, used by anyone
other than the specified parties.
5 Contents of the Service Auditor’s Report for a SOC 2®

Engagement
5.1 Contents of the SOC 2® Report

The SOC 2® report includes the following key components:
1. Management’s Description of the System
Management’s description of the system as of a point in time (Type 1) or throughout a
period of time (Type 2) in accordance with the description criteria.
2. Management’s Assertion
Management assertion that addresses whether:
y The description of the service organization’s system as of a point in time (Type 1) or
throughout a period of time (Type 2) is presented in accordance with the description
criteria.
y The controls stated in the description were suitably designed as of a point in time (Type
1) or throughout a period of time (Type 2) to provide reasonable assurance that the
y The controls stated in the description operated effectively throughout a period of time
to provide reasonable assurance that the service organization’s service commitments
and system requirements were achieved based on the applicable trust services criteria
(Type 2 only).
3. Independent Service Auditor’s Report
The service auditor’s opinion about whether:
y The description of the service organization’s system as of a point in time (Type 1) or
throughout a period of time (Type 2) is presented in accordance with the description
criteria.
y The controls stated in the description were suitably designed as of a point in time (Type
1) or throughout a period of time (Type 2) to provide reasonable assurance that the
y The controls stated in the description operated effectively throughout a period of time
to provide reasonable assurance that the service organization’s service commitments
and system requirements were achieved based on the applicable trust services criteria
(Type 2 only).
4. Auditor’s Tests of Controls and Results of Tests
Description of the service auditor’s tests of controls and results thereof (Type 2 only).

5.1.1 Elements of the Service Auditor’s SOC 2® Report

The elements to be included in a service auditor’s SOC 2® report include:
Independent Service Auditor’s SOC 2® Report

Title A title that includes the word independent
Addressee An appropriate addressee as required by the circumstances of the engagement.
Scope An identification or description of the subject matter or assertion being reported on,
including the point in time or period of time (Type 2) to which the measurement or
evaluation of the subject matter or assertion relates.
Any services provided by, along with controls at, a subservice organization and
whether the carve-out method or the inclusive method was used in relation to them.
An identification of the criteria against which the subject matter was measured or
evaluated:
In a SOC 2® engagement, the description is evaluated against the description criteria
and the suitability of design and operating effectiveness of controls (Type 2) is
evaluated against the trust services criteria relevant to the categories addressed by
the engagement (applicable trust services criteria).
A reference to both sets of criteria should be included in the scope paragraph of the
service auditor’s report.
Service A statement that identifies the responsible party and its responsibility for the subject
Organization’s matter in accordance with (or based on) the criteria or for its assertion.
Responsibilities
Service Auditor’s A statement that the service auditor’s responsibility is to express an opinion on the
Responsibilities subject matter or assertion, based on the service auditor’s examination.
A statement that:
The service auditor’s examination was conducted in accordance with attestation
standards established by the AICPA.
Those standards require that the service auditor plan and perform the examination
to obtain reasonable assurance about whether the subject matter is in accordance
with the criteria, in all material respects.
The service auditor believes the evidence the service auditor obtained is sufficient
and appropriate to provide a reasonable basis for the service auditor’s opinion.
A description of the nature of an examination engagement.
Inherent A statement that describes significant inherent limitations, if any, associated with the
Limitations measurement or evaluation of the subject matter against the criteria.
Description of Tests A description of the procedures performed by the service auditor and the results of
of Controls (Type 2 those procedures.
only)
Other Matter A statement that the service auditor did not perform any procedures regarding the
(Type 1 only) operating effectiveness of controls stated in the description and, accordingly, does not
express an opinion thereon.
Opinion The service auditor’s opinion about whether the subject matter is in accordance with
(or based on) the criteria, in all material respects.
Restricted Use An alert, in a separate paragraph, that restricts the use of the report and should:
State that the service auditor’s report is intended solely for the information and use
of the specified parties.
Restricted Use Identify the specified parties for whom use is intended.
(continued) State that the report is not intended to be, and should not be, used by anyone other
than the specified parties.
Service auditor’s The manual or printed signature of the service auditor’s firm.
signature
Service auditor’s The city and state where the service auditor practices.
city and state
Date of the service The date of the report.

auditor’s report
Pass Key
Key Differences Between SOC 2® Type 1 and Type 2 Reports

The SOC 2® report elements would be tailored to exclude all references to the operating
effectiveness of controls when performing a Type 1 engagement. The Type 1 report would
not include a description of the service auditor’s tests of controls and related results.
5.1.2 Describing Test of Controls and Results in a SOC 2® Engagement

A service auditor’s SOC 2® report for a Type 2 engagement should contain a reference to the
description of the service auditor’s tests of controls and the results of such tests.
Information required to be described includes:
Controls that were tested.
Whether the items tested represent all, or a selection of, the items in the population.
The nature of the tests performed in sufficient detail to enable report users to determine
the effect of such tests on their risk assessments.
If deviations were identified, the following information would also be included:
The number of items tested
The number and nature of deviations
Causative factors (optional)
If the work of the internal audit function has been used in the tests of controls to obtain
evidence, the service auditor is required to include a description of the internal auditor’s work
and the service auditor’s procedures with respect to the work of the internal auditor.

5.1.3 Sample Report: Service Auditor’s Report for a SOC 2® Type 1 Engagement
Independent Service Auditor’s Report

Scope
We have examined XYZ Service Organization’s (XYZ’s) accompanying description of
its [type or name] system titled [insert title of management’s description] as of [date]
(description) based on the criteria for a description of a service organization’s
system in DC section 200, 2018 Description Criteria for a Description of a Service
Organization’s System in a SOC 2® Report (AICPA, Description Criteria) (description
criteria) and the suitability of the design of controls stated in the description as
of [date], to provide reasonable assurance that XYZ’s service commitments and
system requirements were achieved based on the trust services criteria relevant
to security, availability, processing integrity, confidentiality, and privacy (applicable
trust services criteria) set forth in TSP section 100, 2017 Trust Services Criteria for
Security, Availability, Processing Integrity, Confidentiality, and Privacy (AICPA, Trust
Services Criteria).
XYZ is responsible for its service commitments and system requirements
and for designing, implementing, and operating effective controls within the
system to provide reasonable assurance that XYZ’s service commitments and
system requirements were achieved. XYZ has provided the accompanying
assertion titled [insert the title of the attached management assertion] (assertion)
about the description and the suitability of design of controls stated therein.
XYZ is also responsible for preparing the description and assertion, including
the completeness, accuracy, and method of presentation of the description
and assertion; providing the services covered by the description; selecting
the applicable trust services criteria and stating the related controls in the
description; and identifying the risks that threaten the achievement of the service
organization’s service commitments and system requirements.
Our responsibility is to express an opinion on the description and on the suitability
of design of controls stated in the description based on our examination. Our
examination was conducted in accordance with attestation standards established
by the American Institute of Certified Public Accountants. Those standards require
that we plan and perform our examination to obtain reasonable assurance about
whether, in all material respects, the description is presented in accordance with
the description criteria and the controls stated therein were suitably designed to
provide reasonable assurance that the service organization’s service commitments
and system requirements were achieved based on the applicable trust services
criteria. We believe that the evidence we obtained is sufficient and appropriate to
provide a reasonable basis for our opinion.
(continued)
(continued)
An examination of the description of a service organization’s system and the

suitability of the design of controls involves the following:
Obtaining an understanding of the system and the service organization’s
service commitments and system requirements.
Assessing the risks that the description is not presented in accordance with
the description criteria and that controls were not suitably designed.
Performing procedures to obtain evidence about whether the description is
presented in accordance with the description criteria.
Performing procedures to obtain evidence about whether controls stated
in the description were suitably designed to provide reasonable assurance
that the service organization achieved its service commitments and system
requirements based on the applicable trust services criteria.
Evaluating the overall presentation of the description.
Our examination also included performing such other procedures as we
considered necessary in the circumstances.
The description is prepared to meet the common needs of a broad range of report
users and may not, therefore, include every aspect of the system that individual
users may consider important to meet their informational needs.
There are inherent limitations in any system of internal control, including the
possibility of human error and the circumvention of controls. The projection to the
future of any conclusions about the suitability of the design of controls is subject
to the risk that controls may become inadequate because of changes in conditions
or that the degree of compliance with the policies or procedures may deteriorate.
Other Matter
We did not perform any procedures regarding the operating effectiveness
of controls stated in the description and, accordingly, do not express an
opinion thereon.
Opinion
In our opinion, in all material respects,
a. The description presents XYZ’s [name or type] system that was designed and
implemented as of [date], in accordance with the description criteria.
b. The controls stated in the description were suitably designed as of [date], to
provide reasonable assurance that XYZ’s service commitments and system
requirements would be achieved based on the applicable trust services
criteria, if its controls operated effectively as of that date.
(continued)

(continued)
Restricted Use
This report is intended solely for the information and use of XYZ, user entities
of XYZ’s [type or name] system as of [date], business partners of XYZ subject
to risks arising from interactions with the [type or name] system, practitioners
providing services to such user entities and business partners, prospective user
entities and business partners, and regulators who have sufficient knowledge and
understanding of the following:
The nature of the service provided by the service organization
How the service organization’s system interacts with user entities, business
partners, subservice organizations, and other parties
Internal control and its limitations
User entity responsibilities and how they may affect the user entity’s ability to
effectively use the service organization’s services
The applicable trust services criteria
The risks that may threaten the achievement of the service organization’s
service commitments and system requirements and how controls address
those risks
these specified parties.
5.1.4 Sample Report: Service Auditor’s Report for a SOC 2® Type 2 Engagement

Scope
We have examined XYZ Service Organization's (XYZ's) accompanying description of
its [type or name] system titled [insert title of management’s description] throughout
the period [date] to [date] (description) based on the criteria for a description of
a service organization's system in DC section 200, 2018 Description Criteria for a
Description of a Service Organization’s System in a SOC 2® Report (AICPA, Description
Criteria) (description criteria) and the suitability of the design and operating
effectiveness of controls stated in the description throughout the period [date]
to [date] to provide reasonable assurance that XYZ's service commitments and
Services Criteria).
XYZ is responsible for its service commitments and system requirements and
for designing, implementing, and operating effective controls within the system
to provide reasonable assurance that XYZ's service commitments and system
requirements were achieved. XYZ has provided the accompanying assertion
titled [insert the title of the attached management assertion] (assertion), about
the description and the suitability of design and operating effectiveness of
controls stated therein. XYZ is also responsible for preparing the description and
assertion, including the completeness, accuracy, and method of presentation of
the description and assertion; providing the services covered by the description;
selecting the applicable trust services criteria and stating the related controls in
the description; and identifying the risks that threaten the achievement of the
service organization's service commitments and system requirements.
Our responsibility is to express an opinion on the description and on the suitability
of design and operating effectiveness of controls stated in the description
based on our examination. Our examination was conducted in accordance with
attestation standards established by the American Institute of Certified Public
Accountants. Those standards require that we plan and perform our examination
to obtain reasonable assurance about whether, in all material respects, the
description is presented in accordance with the description criteria and the
controls stated therein were suitably designed and operated effectively to provide
reasonable assurance that the service organization’s service commitments and
system requirements were achieved based on the applicable trust services
criteria. We believe that the evidence we obtained is sufficient and appropriate to
provide a reasonable basis for our opinion.
(continued)

(continued)
An examination of the description of a service organization’s system and

the suitability of the design and operating effectiveness of controls involves
the following:
Obtaining an understanding of the system and the service organization’s
service commitments and system requirements
Assessing the risks that the description is not presented in accordance with
the description criteria and that controls were not suitably designed or did not
operate effectively
Performing procedures to obtain evidence about whether the description is
presented in accordance with the description criteria
Performing procedures to obtain evidence about whether controls stated
in the description were suitably designed to provide reasonable assurance
that the service organization achieved its service commitments and system
requirements based on the applicable trust services criteria
Testing the operating effectiveness of controls stated in the description to
provide reasonable assurance that the service organization achieved its
service commitments and system requirements based on the applicable trust
services criteria
Evaluating the overall presentation of the description
Our examination also included performing such other procedures as we
considered necessary in the circumstances.
The description is prepared to meet the common needs of a broad range of report
users and may not, therefore, include every aspect of the system that individual
users may consider important to meet their informational needs.
There are inherent limitations in the effectiveness of any system of internal
control, including the possibility of human error and the circumvention of controls.
Because of their nature, controls may not always operate effectively to provide
reasonable assurance that the service organization’s service commitments and
system requirements are achieved based on the applicable trust services criteria.
Also, the projection to the future of any conclusions about the suitability of the
design and operating effectiveness of controls is subject to the risk that controls
may become inadequate because of changes in conditions or that the degree of
compliance with the policies or procedures may deteriorate.
The specific controls we tested, and the nature, timing, and results of those tests
are listed in section XX.
(continued)
(continued)
Opinion
In our opinion, in all material respects,
implemented throughout the period [date] to [date] in accordance with the
description criteria.
b. The controls stated in the description were suitably designed throughout
the period [date] to [date] to provide reasonable assurance that XYZ’s service
commitments and system requirements would be achieved based on the
applicable trust services criteria if its controls operated effectively throughout
that period.
c. The controls stated in the description operated effectively throughout the
period [date] to [date] to provide reasonable assurance that XYZ’s service
commitments and system requirements were achieved based on the
Restricted Use
section XX, is intended solely for the information and use of XYZ, user entities
of XYZ’s [type or name] system during some or all of the period [date] to [date],
business partners of XYZ subject to risks arising from interactions with the [type or
name] system, practitioners providing services to such user entities and business
partners, prospective user entities and business partners, and regulators who
have sufficient knowledge and understanding of the following:
those risks

3
MODULE
Reporting on SOC
Engagements: Part 2 ISC 4
1 Overview of the Carve-out and Inclusive Methods
When conducting a SOC engagement, the service auditor may need to consider outsourced
functions that are performed for the service organization by other organizations. For SOC 1®
engagements, a vendor used by a service organization is considered a subservice organization if:
The services provided by the vendor are likely relevant to user entities' internal control over
Controls implemented at the subservice organization are necessary to achieve the control
objectives stated in management's description of the service organization's system. These
controls are referred to as complementary subservice organization controls (CSOCs).
For SOC 2® and SOC 3® engagements, a vendor used by a service organization is considered a
subservice organization only if:
The services provided by the vendor are relevant to report users’ understanding of the
service organization’s system as it relates to the applicable trust services criteria.
Controls at the subservice organization are necessary, in combination with the service
organization’s controls, to provide reasonable assurance that the service commitments and
system requirements are achieved. These controls are referred to as CSOCs.
A subservice organization may be a separate entity that is external to the service organization
or may be a related entity, such as a subsidiary of the parent company that owns the service
organization. Service organization management is responsible for determining whether it uses a
If the service organization uses a subservice organization, management is responsible for
determining whether to carve out or include the subservice organization’s controls within the
scope of the engagement. The two methods are defined as follows:
Carve-out Method: Method of addressing the services provided by a subservice
organization in which the CSOCs of the subservice organization are excluded from the
description of the service organization’s system and from the scope of the engagement.
This method identifies:
1. The nature of the services performed by the subservice organization.
2. The types of controls expected to be performed at the subservice organization that
are necessary, in combination with controls at the service organization, to provide
reasonable assurance that the control objectives stated in management's description
of the service organization's system (SOC 1®) or the service organization's service
commitments and system requirements (SOC 2®) were achieved. These may include
logical access controls, controls relevant to the completeness and accuracy of
processing transactions, or controls relevant to accurate and complete reporting.
3. The controls at the service organization used to monitor the effectiveness of the
subservice organization’s controls.
Inclusive Method: Method of addressing the services provided by a subservice organization

in which the description of the service organization’s system includes a description of:
1. The nature of the services provided by the subservice organization.
2. The components of the subservice organization’s system used to provide services to the
service organization, including the subservice organization’s controls that are necessary,
in combination with controls at the service organization, to provide reasonable
assurance that the control objectives stated in management's description of the service
organization's system (SOC 1®) or the service organization's service commitments and
system requirements (SOC 2®) were achieved.
When a service organization uses multiple subservice organizations, it may prepare its
description using the carve-out method for one or more subservice organizations and the
inclusive method for others.
An inclusive report generally provides more information for report users and is most useful in
the following circumstances:
The services provided by the subservice organization are extensive.
A Type 1 or Type 2 report that meets the needs of report users is not available from the
Information about the subservice organization is not readily available from other sources.
Management may determine that the carve-out method is most practical in the following
circumstances:
The challenges entailed in implementing the inclusive method are sufficiently onerous, and
it is not practical to use the inclusive method.
The service auditor is not independent of the subservice organization. (When the inclusive
method is used, the SOC 2® engagement covers the service organization and the subservice
organization, and the service auditor must be independent of both entities.)
A Type 1 or Type 2 service auditor’s report on the subservice organization, meeting user
needs, is available.
The service organization is unable to obtain contractual or other commitment from the
subservice organization regarding its willingness to be included in the SOC 2® engagement.
The subservice organization’s services and controls can have a pervasive effect on the service
organization’s system. In these situations, management and the service auditor would consider
whether the use of the carve-out method may result in a description of the service organization’s
system that is so limited that it is unlikely to be useful to the intended users of the report.
When making this determination, consideration of the following factors should be considered:
The significance of the portion of the system functions performed by the
The complexity of the services and the types of controls that would be expected to be
implemented by the subservice organization.
The extent to which the achievement of the service organization’s service commitments and
system requirements based on the applicable trust services criteria depends on controls at
the subservice organization.
The number of applicable trust services criteria that would not be met if the types of
controls expected to be implemented at the subservice organization were not implemented.

The ability of the intended users of the report to obtain sufficient appropriate
evidence about the design and, in a Type 2 engagement, the operating effectiveness
of controls at the subservice organization (e.g., the availability of a SOC report for the
subservice organization).
When the subservice organization’s services and controls have a pervasive effect on the service
organization’s system, management would not be able to use the carve-out method.
1.1 Impact of the Carve-out and Inclusive Methods in a SOC Report

When a service organization uses a subservice organization, the service auditor’s report is
required to identify any services performed by the subservice organization and whether the
carve-out method or inclusive method was used in relation to them.
If the carve-out method was used, the service auditor’s report should include a statement
indicating:
Management’s description of the service organization’s system excludes the control
objectives and related controls at relevant subservice organizations.
Certain control objectives specified by the service organization can be achieved only if
complementary subservice organization controls assumed in the design of the service
organization’s controls are suitably designed and operating effectively.
The service auditor’s procedures do not extend to such complementary subservice
organization controls.
If the inclusive method was used, the service auditor’s report should include a statement
that management’s description of the service organization’s system includes the subservice
organization’s specified control objectives and related controls, and that the service auditor’s
procedures included procedures related to the subservice organization.
1.1.1 Complementary User Entity Controls (CUECs)

For SOC 1® and SOC 2® engagements, complementary user entity controls (CUECs) are controls
that are necessary to be implemented by the user entity, in combination with the service
organization’s controls, to provide reasonable assurance that the control objectives stated
in management's description of the service organization's system (SOC 1®) or the service
organization's service commitments and system requirements (SOC 2®) were achieved. When
CUECs are identified, management of the service organization is required to ensure that the
system description contains certain disclosures about those controls, including a statement that
user entities are responsible for implementing those CUECs.
In some instances, a service organization’s controls cannot provide reasonable assurance
that its service commitments and system requirements were achieved without the user entity
performing certain activities in a defined manner.
In these cases, the service organization expects the user entity to implement necessary controls
and to perform them completely and accurately in a timely manner. Management of the service
organization identifies such CUECs in their system description.
Common examples of CUECs include:
Security monitoring
Managed service provider (MSP) environment changes
Encrypted financial data
Physical access controls
Authorization policies
A service organization’s controls are usually able to provide reasonable assurance that the
service organization’s service commitments or system requirements were achieved without the
implementation of CUECs because the service organization restricts its service commitments
and system requirements to those matters that are its responsibility and that it can reasonably
perform.
Example 1 CUEC
Encrypted Financial Data: A service organization has a business relationship with a

user entity that operates as a bank, which sends large amounts of data to the service
organization. A CUEC within the service organization’s report might say that user entities
must send data in an encrypted manner using encryption or request that the service
organization provide a secure transmission method.
For SOC 1® reports, any relevant CUECs that ensure control objectives are met should be
described in the system description. It is recommended that a statement be made, if applicable,
that a service organization’s controls could only be achieved if CUECs are designed and
operating effectively.
For SOC 2® reports, a service organization’s system descriptions should also include relevant
CUECs and a statement that user entities are responsible for those controls. The report should
also state that the engagement did not include an evaluation of whether the CUECs were
evaluated for design suitability or operating effectiveness.
SOC 2® reports should also include language about how CUECs interact with the service
organization’s controls. In some cases, separate SOC 2® reports may exist for subservice
organizations that outline relevant CUECs and potentially fall within the scope of the service
entity’s controls.
Pass Key
Key Differences Between CSOC and CUEC

CSOCs are controls that a subservice organization must execute in order for a service
organization’s controls to function effectively, whereas CUECs are controls a user
organization must employ for the service organization’s controls to function. In both
scenarios, the service organization relies on other entities (vendor or client) for their own
controls to work properly.
1.1.2 Impact of Complementary User Entity Controls (CUECs) and Complementary

Subservice Organization Controls (CSOCs) on the SOC report
If the application of complementary user entity controls or complementary subservice
organization controls (or both) are considered necessary to achieve the related control
objectives stated in management’s description of the service organization’s system (SOC 1®) or
the service organization's service commitments and system requirements (SOC 2®), the auditor’s
report must include a statement to that effect in the opinion section of the report.

1.1.3 Sample Report: SOC 1® Type 2 Report (Service Organization Uses Carve-
out Method for Subservice Organization, Service Organization Requires
Complementary User Entity Controls and Complementary Subservice
Organization Controls)

Scope
performed by the system] throughout the period [date] to [date] (description) and
the suitability of the design and operating effectiveness of the controls included in
the description to achieve the related control objectives stated in the description,
based on the criteria identified in “XYZ Service Organization’s Assertion”
(assertion). The controls and control objectives included in the description
are those that management of XYZ Service Organization believes are likely to
be relevant to user entities’ internal control over financial reporting, and the
description does not include those aspects of the [type or name of] system that are
not likely to be relevant to user entities’ internal control over financial reporting.
Example Service Organization uses Computer Subservice Organization,
a subservice organization, to provide hosting services. The description
includes only the control objectives and related controls of Example Service
Organization and excludes the control objectives and related controls of the
subservice organization. The description also indicates that certain control
objectives specified by Example Service Organization can be achieved only if
complementary subservice organization controls assumed in the design of
Example Service Organization’s controls are suitably designed and operating
effectively, along with the related controls at Example Service Organization. Our
examination did not extend to controls of the subservice organization, and we
have not evaluated the suitability of the design nor operating effectiveness of
such complementary subservice organization controls.
The description indicates that certain control objectives specified in the
description can be achieved only if complementary user entity controls assumed
in the design of Example Service Organization’s controls are suitably designed
and operating effectively, along with related controls at the service organization.
Our examination did not extend to such complementary user entity controls and
we have not evaluated the suitability of the design or operating effectiveness of
such complementary user entity controls.
(continued)
(continued)

Same as standard SOC 1® report.
Opinion
a. The description fairly presents the [type or name of] system that was
designed and implemented throughout the period [date] to [date].
b. The controls related to the control objectives stated in the description
were suitably designed to provide reasonable assurance that the control
objectives would be achieved if the controls operated effectively throughout
the period [date] to [date], and the subservice organization and user entities
applied the complementary controls assumed in the design of Example
Service Organization’s controls throughout the period January 1, 201X, to
December 31, 201X.
c. The controls operated effectively to provide reasonable assurance that the
control objectives stated in the description were achieved throughout the
period [date] to [date], if complementary subservice organization and user
entity controls assumed in the design of Example Service Organization’s
controls operated effectively throughout the period January 1, 201X, to
December 31, 201X.
Restricted Use

1.1.4 Sample Report: SOC 1® Type 2 Report (Using the Inclusive Method,
Complementary User Entity Controls Are Required)

Scope
of] system and ABC Subservice Organization’s description of its application
maintenance and support services, both of which are included in titled “XYZ
Service Organization’s Description of Its [type or name of] System” for processing
user entities’ transactions [or identification of the function performed by the
system] throughout the period [date] to [date] (description) and the suitability of
the design and operating effectiveness of XYZ Service Organization’s and ABC
Subservice Organization’s controls included in the description to achieve the
related control objectives stated in the description, based on the criteria identified
in “XYZ Service Organization’s Assertion” and “ABC Subservice Organization’s
Assertion” (assertion). ABC Subservice Organization is a subservice organization
that provides application maintenance and support services to XYZ Service
Organization. XYZ Service Organization’s description includes a description of
ABC Subservice Organization’s application maintenance and support services
used by XYZ Service Organization to process transactions for user entities,
including controls relevant to the control objectives stated in the description.
The controls and control objectives included in the description are those that
management of XYZ Service Organization and management of ABC Subservice
Organization believe are likely to be relevant to user entities’ internal control over
financial reporting, and the description does not include those aspects of the
[type or name of] system that are not likely to be relevant to user entities’ internal
control over financial reporting.
The description indicates that certain control objectives specified in the
description can be achieved only if complementary user entity controls
assumed in the design of XYZ Service Organization’s controls are suitably
designed and operating effectively, along with related controls at the service
organization and the subservice organization. Our examination did not extend
to such complementary user entity controls and we have not evaluated the
suitability of the design or operating effectiveness of such complementary user
entity controls.
(continued)
(continued)

In [section number where the assertion is presented], XYZ Service Organization
and ABC Subservice Organization has have provided an their assertions about
the fairness of the presentation of the description and suitability of the design
and operating effectiveness of the controls to achieve the related control
objectives stated in the description. XYZ Service Organization and ABC Subservice
Organization is are responsible for preparing the description and their assertions,
including the completeness, accuracy, and method of presentation of the
description and assertion; providing the services covered by the description;
specifying the control objectives and stating them in the description; identifying
the risks that threaten the achievement of the control objectives; selecting the
criteria stated in the assertion; and designing, implementing, and documenting
controls that are suitably designed and operating effectively to achieve the related
control objectives stated in the description.
the description and on the suitability of the design and operating effectiveness
of the controls to achieve the related control objectives stated in the description,
based on our examination.
were suitably designed and operating effectively to achieve the related control
objectives stated in the description throughout the period [date] to [date]. We
believe that the evidence we obtained is sufficient and appropriate to provide a
reasonable basis for our opinion.
suitability of the design and operating effectiveness of controls involves:
presentation of the description and the suitability of the design and operating
effectiveness of the controls to achieve the related control objectives stated in
the description, based on the criteria in management’s assertion.
controls were not suitably designed or operating effectively to achieve the
related control objectives stated in the description.
Testing the operating effectiveness of those controls that management
considers necessary to provide reasonable assurance that the related control
objectives stated in the description were achieved.
(continued)

(continued)

the service organization and subservice organization in their its assertions.
Because of their nature, controls at a service organization or subservice
organization may not prevent, or detect and correct, all misstatements in
processing or reporting transactions [or identification of the function performed
by the system]. Also, the projection to the future of any evaluation of the fairness
of the presentation of the description, or conclusions about the suitability of
the design or operating effectiveness of the controls to achieve the related
control objectives, is subject to the risk that controls at a service organization or
subservice organization may become ineffective.
Opinion
Service Organization’s assertion and ABC Subservice Organization’s assertion:
a. The description fairly presents the [type or name of] system and ABC
Subservice Organization’s application maintenance and support services that
was were designed and implemented throughout the period [date] to [date].
b. The controls of XYZ Service Organization and ABC Subservice Organization
related to the control objectives stated in the description were suitably
designed to provide reasonable assurance that the control objectives would
be achieved if the controls operated effectively throughout the period [date]
to [date], and user entities applied the complementary user entity controls
assumed in the design of XYZ Service Organization’s controls throughout the
period January 1, 201X, to December 31, 201X.
c. The controls of XYZ Service Organization and ABC Subservice Organization
operated effectively to provide reasonable assurance that the control
objectives stated in the description were achieved throughout the period
[date] to [date] if complementary user entity controls assumed in the design
of XYZ Service Organization’s controls operated effectively throughout the
period January 1, 201X, to December 31, 201X.
Restricted Use
1.1.5 Sample Report: Service Auditor’s SOC 2® Report for a Type 2 Engagement
(Carved-out Controls of a Subservice Organization and Complementary
Subservice Organization and Complementary User Entity Controls)

Scope
its [type or name] system titled [insert title of management’s description] throughout
the period [date] to [date] (description) based on the criteria for a description of
a service organization’s system in DC section 200, 2018 Description Criteria for a
Description of a Service Organization’s System in a SOC 2® Report (AICPA, Description
Criteria) (description criteria) and the suitability of the design and operating
effectiveness of controls stated in the description throughout the period [date]
to [date] to provide reasonable assurance that XYZ’s service commitments and
Services Criteria).
XYZ uses a subservice organization to provide application maintenance and
support services. The description indicates that complementary subservice
organization controls that are suitably designed and operating effectively are
necessary, along with controls at XYZ, to achieve XYZ’s service commitments
and system requirements based on the applicable trust services criteria. The
description presents XYZ’s controls, the applicable trust services criteria, and the
types of complementary subservice organization controls assumed in the design
of XYZ’s controls. The description does not disclose the actual controls at the
subservice organization. Our examination did not include the services provided
by the subservice organization, and we have not evaluated the suitability
of the design or operating effectiveness of such complementary subservice
organization controls.
The description indicates that complementary user entity controls that are
suitably designed and operating effectively are necessary, along with controls at
XYZ, to achieve XYZ’s service commitments and system requirements based on
the applicable trust services criteria. The description presents XYZ’s controls, the
applicable trust services criteria, and the complementary user entity controls
assumed in the design of XYZ’s controls. Our examination did not include such
complementary user entity controls and we have not evaluated the suitability of
the design or operating effectiveness of such controls.
(continued)

(continued)

Opinion
In our opinion, in all material respects:
applicable trust services criteria, if its controls operated effectively throughout
that period and if the subservice organization and user entities applied the
complementary controls assumed in the design of XYZ’s controls throughout
that period.
applicable trust services criteria, if complementary subservice organization
controls and complementary user entity controls assumed in the design of
XYZ’s controls operated effectively throughout that period.
Restricted Use
(continued)
(continued)
Complementary user entity controls and complementary subservice

organization controls and how those controls interact with the controls
at the service organization to achieve the service organization’s service
commitments and system requirements
those risks
1.1.6 Sample Report: Service Auditor’s SOC 2® Report for a Type 2 Engagement
(Subservice Organization Presented Using the Inclusive Method and
Complementary User Entity Controls)

Scope
its [type or name] system, including application maintenance and support services
provided by and controls operated by ABC Subservice Organization (ABC), titled
[insert title of management’s description] throughout the period [date] to [date]
(description) based on the criteria for a description of a service organization’s
system in DC section 200, 2018 Description Criteria for a Description of a Service
Organization’s System in a SOC 2® Report (AICPA, Description Criteria) (description
criteria) and the suitability of the design and operating effectiveness of controls,
including the controls designed by XYZ and operated by ABC, stated in the
description throughout the period [date] to [date] to provide reasonable assurance
that XYZ’s service commitments and system requirements were achieved based
on the trust services criteria relevant to security, availability, processing integrity,
confidentiality, and privacy (applicable trust services criteria) set forth in TSP
section 100, 2017 Trust Services Criteria for Security, Availability, Processing Integrity,
Confidentiality, and Privacy (AICPA, Trust Services Criteria).
(continued)

(continued)
ABC is an independent subservice organization providing application

maintenance and support services to XYZ. The description includes those
elements of the application maintenance and support services provided to XYZ
and the controls designed by XYZ and operated by ABC that are necessary for
XYZ to achieve its service commitments and system requirements based on the
The description indicates that complementary user entity controls that are
suitably designed and operating effectively are necessary, along with controls at
XYZ, to achieve XYZ’s service commitments and system requirements based on
the applicable trust services criteria. The description presents XYZ’s controls, the
applicable trust services criteria, and the complementary user entity controls
assumed in the design of XYZ’s controls. Our examination did not include such
complementary user entity controls, and we have not evaluated the suitability of
the design or operating effectiveness of such controls.
Subservice Organization’s Responsibilities
ABC has provided the accompanying assertion titled “Assertion of ABC Subservice
Organization Management,” (ABC assertion) about the description and the
controls stated therein. ABC is responsible for preparing the portion of the
description related to the application maintenance and support services
provided to XYZ and the ABC assertion, including the completeness, accuracy,
and method of presentation of the description and assertion; providing
the services covered by the description; and implementing, operating, and
documenting controls designed by XYZ, which enable XYZ to achieve its service
Opinion
In our opinion, in all material respects:
(continued)
(continued)

applicable trust services criteria, if its controls operated effectively throughout
that period, and if the user entities applied the complementary controls
assumed in the design of XYZ’s controls throughout that period.
applicable trust services criteria, if complimentary user entity controls
assumed in the design of XYZ’s controls operated effectively throughout
that period.
Restricted Use
Complementary user entity controls and complementary subservice
organization controls and how those controls interact with the controls
at the service organization to achieve the service organization’s service
commitments and system requirements
those risks

2 Impact of Modified Opinions on the SOC Report
The service auditor’s report will need to be modified accordingly when a modified opinion is
necessary based on the professional judgment of the service auditor.
2.1 Qualified Opinion

The service auditor expresses a qualified opinion in the following circumstances:
SOC 1® engagement:
y If the misstatements in management’s description of the service organization’s system
or deficiencies in the suitability of the design or operating effectiveness (Type 2) of the
controls are limited to one or more, but not all, aspects of the description of the service
organization’s system or control objectives and do not affect the service auditor’s
opinion on other aspects of the description of the service organization’s system or other
control objectives.
SOC 2® engagement:
y The service auditor concludes that description misstatements, either individually or in
the aggregate, are material but not pervasive, or deficiencies in the design or operation
(Type 2) of controls are material but not pervasive.
y The service auditor is unable to obtain sufficient appropriate evidence on which to
base the opinion, and the service auditor has concluded that the possible effects on the
subject matter of undetected description misstatements or deficiencies, if any, could be
material but not pervasive to the subject matter.
2.1.1 Elements of Service Auditor’s SOC 1® Report: Qualified Opinion

When the service auditor has determined that a qualified opinion is appropriate, the service
auditor’s SOC 1® report will include:
Qualified Opinion SOC 1® Report

Title Same as standard SOC 1® report.
Addressee Same as standard SOC 1® report.
Scope Same as standard SOC 1® report.
Service Same as standard SOC 1® report.
Organization’s
Responsibilities
Service Auditor’s Same as standard SOC 1® report.
Responsibilities
Inherent Same as standard SOC 1® report.
Limitations
Description of Same as standard SOC 1® report.
Tests of Controls
(Type 2 only)
Other Matter Same as standard SOC 1® report.
(Type 1 only)
Qualified A separate paragraph, before the opinion paragraph, that provides a

Opinion description of the matters giving rise to the modification.
In addition, the service auditor’s opinion paragraph should be amended
as follows:
In our opinion, except for the matter referred to in the preceding paragraph,
in all material respects, based on the criteria described in [service
organization’s] assertion in section 2, ...
Restricted Use Same as standard SOC 1® report.
Signature
City and State
Date of the Same as standard SOC 1® report.
Service Auditor’s
Report
2.1.2 Elements of Service Auditor’s SOC 2® Report: Qualified Opinion Due to

Material Misstatements
When material misstatements in the description or deficiencies in the design or operation of
controls are identified, the service auditor generally expresses a qualified opinion if:
1. The identified misstatements in the description of the service organization’s system are
limited to one or more, but not all, aspects of the description.
2. The identified deficiencies in the suitability of the design or operating effectiveness (Type 2)
of the controls result in the failure of the controls to provide reasonable assurance that one
or more, but not all, of its service commitments and system requirements were achieved
3. The identified misstatements and deficiencies do not otherwise affect the service auditor’s
opinion on other aspects of the description of the service organization’s system or on
whether controls were suitably designed or operated effectively (Type 2).

When the service auditor has determined that a qualified opinion is appropriate because of
material misstatements or deficiencies, the service auditor’s SOC 2® report will include:
Qualified Opinion Due to Material Misstatements SOC 2® Report

Organization’s
Responsibilities
Service Auditor’s The service auditor’s responsibility paragraph should be amended to state
Responsibilities that the service auditor believes that the evidence the service auditor has
obtained is sufficient and appropriate to provide a basis for the service
auditor’s qualified opinion.
Limitations
Tests of Controls
(Type 2 only)
(Type 1 only)
Qualified A separate paragraph, before the opinion paragraph, that provides a
Opinion description of the matters giving rise to the modification.
as follows:
In our opinion, except for the effects of matters giving rise to the modification,
the description is presented in accordance with the description criteria
and the controls were suitably designed and operating effectively (Type
2) to provide reasonable assurance that the service organization’s service
applicable trust services criteria, in all material respects.
Signature
City and State
Service Auditor’s
Report
2.1.3 Elements of Service Auditor’s SOC 2® Report: Qualified Opinion Due to

Scope Limitations
The service auditor should express a qualified opinion when unable to obtain sufficient
appropriate evidence on which to base the opinion and the service auditor has concluded
that the possible effects on the subject matter of undetected description misstatements or
deficiencies, if any, could be material but not pervasive to the subject matter.
When the service auditor determines that a qualified opinion is appropriate because of scope
limitations, the service auditor’s SOC 2® report will include:
Qualified Opinion Due to Scope Limitations SOC 2® Report


Organization’s
Responsibilities
Service Auditor’s The service auditor’s responsibility paragraph should be amended to state that
Responsibilities the service auditor believes that the evidence the service auditor has obtained
is sufficient and appropriate to provide a basis for the service auditor’s qualified
opinion.
Limitations
Tests of Controls
(Type 2 only)
(Type 1 only)
Qualified Opinion A separate paragraph, before the opinion paragraph, that provides a clear
explanation of the matters giving rise to the modification.
In addition, the service auditor’s opinion paragraph should be amended as
follows:
In our opinion, except for the possible effects of the matters giving rise to the
modification, the description is presented in accordance with the description
criteria and the controls were suitably designed and operating effectively
(Type 2) to provide reasonable assurance that the service organization’s service
commitments and system requirements were achieved based on the applicable
trust services criteria, in all material respects.
If the service auditor also concludes there were material misstatements in the
description or material deficiencies in the suitability of design or operating
effectiveness of controls, the service auditor should include, in separate
paragraphs of the report, a clear explanation of both:
the scope limitation; and
the matters that caused the description, suitability of design, or operating
effectiveness of controls to be materially misstated.
Signature
City and State
Date of the Service Same as standard SOC 2® report.
Auditor’s Report

2.2 Adverse Opinion

A practitioner should issue an adverse opinion when he or she concludes that the description
misstatements, either individually or in the aggregate, are material and pervasive, or deficiencies
in the design or operation of controls are material and pervasive.
2.2.1 Elements of Service Auditor’s SOC 1® Report: Adverse Opinion

The service auditor expresses an adverse opinion if the misstatements in management’s
description of the service organization’s system or deficiencies in the suitability of the design or
operating effectiveness of the controls are material and pervasive throughout the description or
across all or most of the control objectives.
When the service auditor has determined that an adverse opinion is appropriate, the service
Adverse Opinion SOC 1® Report

Organization’s
Responsibilities
Responsibilities
Limitations
Tests of Controls
(Type 2 only)
(Type 1 only)
Adverse Opinion A separate paragraph, before the opinion paragraph, that provides a
description of the matters giving rise to the modification.
as follows:
In our opinion, because of the matter referred to in the preceding
paragraph, in all material respects, based on the criteria described in
[name of service organization’s] assertion in section 2:
The description does not fairly present the [type or name of system] that
was designed and implemented throughout the period.
The controls related to the control objectives stated in the description
were not suitably designed to provide reasonable assurance that the
control objectives would be achieved if the controls operated effectively
throughout the period [date] to [date].
Adverse Opinion The controls tested, which were those necessary to provide reasonable
assurance that the control objectives stated in the description were
(continued)
achieved, did not operate effectively throughout the period from [date]
to [date].
Signature
City and State
Service Auditor’s
Report
2.2.2 Elements of Service Auditor’s SOC 2® Report: Adverse Opinion

The service auditor expresses an adverse opinion if the description misstatements in the
description of the service organization’s system or deficiencies or deviations in the suitability
of the design or operating effectiveness of the controls are material and pervasive throughout
the description or prevent the achievement of all or most of the service organization’s service
commitments and system requirements based on the applicable trust services criteria.
When the service auditor has determined that an adverse opinion is appropriate, the service
Adverse Opinion SOC 2® Report

Organization’s
Responsibilities
Service Auditor’s The service auditor’s responsibility paragraph should be amended
Responsibilities to state:
We believe that the evidence we obtained is sufficient and appropriate to
provide a reasonable basis for our adverse opinion.
Limitations
Tests of Controls
(Type 2 only)
(Type 1 only)

Adverse Opinion A separate paragraph, before the opinion paragraph, that provides a clear
explanation of the matters giving rise to the modification.
as follows:
In our opinion, because of the significance of the matter(s) referred to in
the preceding paragraph, in all material respects:
a. The description of the [name or type] system does not present the
system that was designed and implemented throughout the period
[date] to [date] in accordance with the description criteria.
b. The controls stated in the description were not suitably designed
throughout the period [date] to [date] to provide reasonable
assurance that the service organization’s service commitments and
system requirements would be achieved based on the applicable
c. The controls stated in the description did not operate effectively
throughout the period [date] to [date] to provide reasonable
assurance that the service organization’s service commitments and
system requirements were achieved based on the applicable trust
services criteria.
Signature
City and State
Service Auditor’s
Report
2.3 Disclaimer of Opinion

A disclaimer of opinion should be issued when the service auditor is unable to obtain sufficient
appropriate evidence on which to base the opinion, and the service auditor concludes that the
possible effects on the subject matter of undetected misstatements could be both material
and pervasive.
In these situations, the service auditor’s opinion should be modified, and the service auditor’s
report should include a separate paragraph containing a clear description of the matters that
give rise to the modification. In a disclaimer of opinion, that paragraph describes the items in
question in which the examination did not comply with the attestation standards.
When disclaiming an opinion:
The first sentence of the service auditor’s report is revised to state, “We were engaged
to examine.”
The standards under which the service auditor conducts an examination are identified in
the first paragraph of the report rather than the second.
The report omits statements:

y Indicating what those standards require of the practitioner.
y Indicating that the practitioner believes the evidence obtained is sufficient and
appropriate to provide a reasonable basis for the service auditor’s opinion.
y Describing the nature of an examination engagement.
2.3.1 Sample Report Language When a Disclaimer of Opinion Is Issued
We were engaged to examine XYZ Company’s description of its medical claims

processing system titled “XYZ Company’s Description of its Medical Claims
Processing System” for processing medical claims throughout the period [date] to
[date] (description) and the suitability of the design and operating effectiveness
of the controls included in the description to achieve the related control
objectives stated in the description, based on the criteria identified in “XYZ Service
Organization’s Assertion” (assertion).
XYZ Company’s management is responsible for the fairness of the presentation of
the description and the suitability of the design and operating effectiveness of the
controls included in the description. Our responsibility is to express an opinion on
the fairness of the presentation of the description and the suitability of the design
and operating effectiveness of the controls included in the description, based on
conducting the examination in accordance with attestation standards established
by the American Institute of Certified Public Accountants.
Attestation standards established by the American Institute of Certified Public
Accountants require that we request certain written representations from
management, including a representation that all relevant matters are reflected
in the measurement or evaluation of the fairness of the presentation of the
description of the service organization’s system and the suitability of design and
operating effectiveness of controls. We requested that management provide us
with such a representation, but management refused to do so.
Because of the limitation on the scope of our examination discussed in the
preceding paragraph, the scope of our work was not sufficient to enable
us to express, and we do not express, an opinion on whether XYZ Company’s
description of its medical claims processing system throughout the period [date]
to [date] is fairly presented or on whether the controls included in the description
were suitability designed and operating effectively to achieve the related control
objectives stated in the description, based on the criteria identified in XYZ
Company’s assertion, in all material respects.

2.4 Report Paragraphs Describing Matters Giving Rise to Modification

When a service auditor concludes that a modified opinion is appropriate based on the evidence
obtained during a SOC engagement, a separate paragraph should be added to the service
auditor’s report to explain the matter giving rise to the modification.
2.4.1 The Description Includes Controls That Have Not Been Implemented
The below language is an example of a separate paragraph that would be added when the
description includes controls that have not been implemented:
The accompanying description of the XYZ System states that Example Service Organization
uses operator identification numbers and passwords to prevent unauthorized access to its
system. Our testing determined that operator identification numbers and passwords are
used in applications A and B, but are not used in applications C and D.
2.4.2 Controls That Are Not Suitably Designed

The below language is an example of a separate paragraph that would be added to the auditor’s
report preceding the opinion paragraph, when the auditor concludes the controls are not
suitably designed:
The accompanying description of ABC Service Organization’s system states on page 8 that
ABC Service Organization’s system supervisor makes changes to the systems only if the
changes are authorized, tested, and documented. The procedures, however, do not include
a requirement for approval of the change before the change is placed into operation. As a
result, controls were not suitably designed or operating effectively throughout the period
[date] to [date] to provide reasonable assurance that the service organization’s service
commitments and system requirements were achieved based on trust services criterion
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.
NOTES

Planning and Risk
4
MODULE
Assessment in a SOC
Engagement ISC 4
1 Understanding Service Organization Management’s

Responsibilities
The service auditor, when auditing the service organization, is required to establish, prior to
acceptance of the SOC engagement, an understanding with service organization management
about its responsibilities and the responsibilities of the service auditor. The decisions a service
organization’s management makes prior to engaging the service auditor can affect the nature,
extent, and timing of procedures the service auditor performs.
The service auditor should also establish communication with management of the service
organization. The service auditor should determine the appropriate person(s) within the service
organization’s management or governance structure with whom to interact. This should include
the service auditor’s consideration of which person(s) has the appropriate responsibilities for,
and knowledge of, the relevant matters.
1.1 SOC 1® Engagements

For SOC 1® engagements, management of the service organization is responsible for the
following during the engagement:
Defining the scope of the engagement, including:
y Which services (including the classes of transactions processed), functions performed,
business units, functional areas, or applications are likely to be relevant to user entities’
internal control over financial reporting.
y Management also considers whether the service organization has any contractual
obligations to provide a Type 1 or Type 2 report to one or more of its user entities,
including the frequency with which such a report is to be issued and the period that will
be covered by the report.
y In the case of a recurring or existing engagement, the prior report provides a useful
starting point for defining the scope of the engagement.
The report type (Type 1 or Type 2).
Determining the as of date (Type 1) or specified period (Type 2) of the engagement.
If services provided to a service organization by other entities are likely to be relevant to
user entities’ internal control over financial reporting, and if so, identifying these other
entities as subservice organizations.
Whether subservice organizations will be presented using the carve-out or inclusive method
in the description of the service organization’s system.
Preparing a description of the system, including the completeness, accuracy, and method of
presentation of the description.
Having a reasonable basis for its assertion.

Planning and Risk Asse
4 Planning and Risk Assessment in a SOC Engagement ISC 4
Selecting the criteria to be used, stating them in the assertion, and determining that the
criteria are appropriate for management’s purposes.
Specifying and stating the control objectives, whether any control objectives are specified by
law, regulation, or another party, including the party specifying the control objectives.
Identifying the risks that threaten the achievement of the stated control objectives and
designing, implementing, and documenting controls that are suitably designed and
operating effectively to provide reasonable assurance that stated control objectives will
be met.
Preparing a written assertion that accompanies management’s description of the service
organization’s system and providing both to the user entities.
Providing the service auditor with access to all relevant information (records,
documentation, service-level agreements, internal audit, or other reports), additional
information that the service auditor may request, and personnel to obtain relevant
evidence.
Providing the service auditor with written representations at the conclusion of
the engagement.
If the service auditor plans to use internal auditors to provide direct assistance, providing
the service auditor with written acknowledgment that internal auditors providing direct
assistance to the service auditor will be allowed to follow the service auditor’s instructions
and that the service organization will not intervene in the work the internal auditor performs
for the service auditor.
Disclosing to the service auditor:
y Incidents of noncompliance with laws and regulations, fraud, or uncorrected
misstatements that are clearly not trivial and that may affect one or more user entities
and whether such incidents have been communicated appropriately to affected
user entities.
y Knowledge of any actual, suspected, or alleged intentional acts that could adversely
affect the presentation of the description of the service organization’s system, or the
completeness or achievement of the control objectives stated in the description.
y Any deficiencies in the design of controls of which management is aware.
y All instances in which controls have not operated as described.
y Any events subsequent to the period covered by the description of the service
organization’s system, up to the date of the service auditor’s report, that could have a
significant effect on management’s assertion.

For SOC 2® engagements, management of the service organization is responsible for the
following prior to engaging the service auditor:
y The services provided to user entities (which will establish the subject matter of
the engagement).
y The system used to provide services.
y The report type (Type 1 or Type 2).
y Identifying risks of business partners or services to the service organization related to
the system.
S4–66 Module 4 Planning and

© Becker Professional Risk Assessment
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Corporation. All a SOCreserved.
Engagement
ISC 4 4 Planning and Risk Assessment in a SOC Engagement
y Determining the as of date (Type 1) or specified period (Type 2) of the engagement.

y If services are provided to the service organization by other entities, evaluating the
effect of those services on the achievement of service commitments and system
requirements, and concluding whether those entities are subservice organizations.
Whether subservice organizations will be presented using the carve-out or inclusive
method in the description of the service organization’s system. If a subservice
organization is to be presented using the inclusive method, obtaining agreement from
subservice organization management to participate in the engagement.
y Selecting the trust services category or categories to be included in the scope of
the engagement.
Specifying the principal service commitments made to user entities and the necessary
system requirements to operate the system.
Specifying the principal system requirements related to commitments made to
business partners.
Identifying and analyzing risks that could prevent the service organization from achieving its
Designing, implementing, operating, monitoring, and documenting controls that are suitably
designed and operating effectively (Type 2), to provide reasonable assurance about the
service organization’s ability to achieve their service commitments and system requirements
Management of the service organization is also responsible for the following during the SOC 2®
engagement:
Preparing a description of the system and its assertion, including the completeness,
accuracy, and method of presentation of the description and assertion.
Having a reasonable basis for its assertion.
Identifying the risks that threaten the service organization’s achievement of its service
commitments and system requirements stated in the description.
Providing a written assertion that accompanies management’s description of the service
organization’s system and providing both to report users.
Designing, implementing, and documenting controls that are suitably designed
and operating effectively (Type 2), to provide reasonable assurance that the service
commitments and system requirements will be achieved based on the applicable trust
services criteria.
Providing the service auditor with access to all relevant information (records,
documentation, service-level agreements, internal audit, or other reports), additional
information that the service auditor may request, and personnel to obtain relevant
evidence.
Providing the service auditor with written representations at the conclusion of
the engagement.
If the service auditor plans to use internal auditors to provide direct assistance, providing
the service auditor with written acknowledgment that internal auditors providing direct
assistance to the service auditor will be allowed to follow the service auditor’s instructions
and that the service organization will not intervene in the work the internal auditor performs
for the service auditor.

Disclosing to the service auditor:

y Incidents of noncompliance with laws and regulations, fraud, or uncorrected
misstatements that are clearly not trivial and that may affect one or more user entities
and whether such incidents have been communicated appropriately to affected
user entities.
y Knowledge of any actual, suspected, or alleged intentional acts that could adversely
affect the presentation of the description of the service organization’s system, the
suitability of design of its controls, or the operating effectiveness of controls (Type 2).
y Any deficiencies in the design of controls of which management is aware.
y All instances in which controls have not operated as described.
y All identified system incidents that resulted in a significant impairment of the service
organization’s achievement of its service commitments and system requirements as
of the date of the description (Type 1) or during the period of time covered by the
description (Type 2).
y Any events subsequent to the period covered by the description of the service
organization’s system, up to the date of the service auditor’s report, that could have a
significant effect on management’s assertion.

For SOC 3® engagements, the responsibilities of management of the service organization
are substantially the same as those for a SOC 2® engagement, except that management
does not prepare a system description. During acceptance and planning, management’s
responsibilities include:
y The services provided to user entities (which will establish the subject matter of
the engagement).
y The system used to provide services.
y The report type (Type 1 or Type 2).
y Identifying risks of business partners or services to the service organization related to
the system.
y Determining the as of date (Type 1) or specified period (Type 2) of the engagement.
y If services are provided to the service organization by other entities, evaluating the
effect of those services on the achievement of service commitments and system
requirements, and concluding whether those entities are subservice organizations.
Whether subservice organizations will be presented using the carve-out or inclusive
method in the description of the service organization’s system. If a subservice
organization is to be presented using the inclusive method, obtaining agreement from
subservice organization management to participate in the engagement.
y Selecting the trust services category or categories to be included in the scope of
the engagement.
Specifying the principal service commitments made to user entities and the necessary
system requirements to operate the system.
Identifying and analyzing risks that could prevent the service organization from achieving its

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Engagement
Designing, implementing, monitoring, and documenting effective controls to provide

reasonable assurance of achieving the service organization’s service commitments and
system requirements based on the applicable trust services criteria.
Identifying subservice organizations and determining whether to present them under the
inclusive or carve-out method.
If using the carve-out method, identifying complementary subservice organization
controls (CSOCs).
Providing a written assertion that discloses:
y The boundaries of the system.
y The service organization’s principal service commitments and system requirements.
2 Objectives and Planning Considerations for a

Service Auditor
Planning a SOC engagement requires the service auditor to obtain an understanding of

key areas and formulate assessments of risk relevant to the engagement. The planning
requirements of a service auditor for SOC 1®, SOC 2®, and SOC 3® engagements are similar.
2.1 Objectives of the Service Auditor

The objectives of the service auditor are to:
Obtain reasonable assurance about whether, in all material respects, based on
suitable criteria:
system that was designed and implemented throughout the specified period (Type 2) or
as of a specified date (Type 1).
service organization’s system were suitably designed throughout the specified period
(Type 2) or as of a specified date (Type 1).
y When included in the scope of the engagement, the controls operated effectively to
provide reasonable assurance that the control objectives stated in management’s
description of the service organization’s system were achieved throughout the
specified period.
Report in accordance with the service auditor’s findings.
2.2 Responsibilities of the Service Auditor

During planning of any SOC engagement, the service auditor is responsible for:
Determining whether to accept or continue the engagement.
Agreeing on engagement terms.
Reaching an understanding with management regarding a written assertion.
During planning of a SOC 1® engagement, the service auditor is also responsible for:
Assessing the risk of material misstatement.
Obtaining an understanding of the service organization’s system and assessing the
suitability of the criteria used by management in preparing its system description.

During planning of SOC 2® and SOC 3® engagements, the service auditor is also responsible for:
Establishing an overall strategy for the engagement.
Sets the scope, timing, and direction of the engagement and guides the development of the
engagement plan, including the consideration of materiality and the identification of the
risks of material misstatement (SOC 2®).
Performing risk assessment procedures.
Includes understanding of the service organization’s system and how the system controls
were designed, implemented, and operated to provide reasonable assurance that the
service organization’s service commitments and system requirements are achieved based
on the applicable trust services criteria (SOC 2®).
2.2.1 Agreeing to Engagement Terms

A SOC engagement is an example of an assertion-based examination engagement, and relevant
engagement standards apply.
The service auditor and the service organization should agree upon the engagement terms,
such as:
The objectives and scope of the engagement.
The responsibilities of the service auditor and the responsible party (likely management
of the service organization), including the responsibility of management to provide a
representation letter.
The identification of the criteria used to measure, evaluate, or disclose information about
the subject matter.
Acknowledgement that the engagement will be conducted in accordance with attestation
standards established by the AICPA and the inherent limitations of an engagement.
The service auditor should request that management provide a written assertion.
2.3 Independence Considerations

Independence is required in an engagement to report on controls at a service organization.
The independence assessment process may address matters such as scope of services, fee
arrangements, firm and individual financial relationships, firm business relationships, and
alumni and familial relationships with the client and client personnel.
The service auditor is not required to be independent of each user entity.
2.3.1 Service Organization and Service Auditor

The service auditor needs to be independent with respect to the responsible party (or parties),
as defined in those standards. The responsible party is most often the service organization.
2.3.2 Subservice Organization and Service Auditor

If the service organization uses a subservice organization, and management elects to use
the inclusive method to present certain information about the subservice organization in
its description of the service organization’s system, subservice organization management is
also a responsible party. As a result, the service auditor should also be independent of the

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Engagement
2.3.3 Service Auditor Lack Independence

When the service auditor is not independent but is required by law or regulation to accept
the engagement and report on the subject matter, the service auditor should disclaim an
opinion and should specifically state that the service auditor is not independent. The service
auditor is neither required to provide, nor precluded from providing, the reasons for the lack of
independence, but should include all reasons if any are given.
2.4 Materiality Considerations

The services auditor is required to consider materiality during risk assessment and to determine
the nature, extent, and timing of procedures necessary to obtain sufficient appropriate evidence
to support an opinion in the SOC engagement. Materiality definitions and interpretations vary
between SOC 1® and SOC 2® engagements but in both cases, the service auditor is required to
reassess materiality if the auditor obtains new information that would have caused the auditor
to assess the initial materiality differently.
2.4.1 Materiality in a SOC 1® Engagement

In a SOC 1® engagement, the service auditor’s consideration of materiality should include the fair
presentation of the description of the service organization’s system. The concept of materiality in
the context of the fair presentation of the description relates to the information being reported
on, not the financial statements of user entities. Materiality relates to qualitative factors, such as
whether significant aspects of the processing have been included in the description or if relevant
information has been omitted or distorted.
Materiality with respect to the operating effectiveness of controls for a Type 2 report includes
the consideration of quantitative and qualitative factors, such as:
Quantitative: the tolerable and observed rate of deviations
Qualitative: the nature and cause of deviations
Example 1 Materiality in a SOC 1® Engagement
The service organization is responsible for implementing general IT controls. The service
organization’s application controls cannot function without the underlying general IT
controls; therefore, the general IT controls would be considered material to the description
of the service organization’s system and would be included in the service organization’s
description of its system.
2.4.2 Materiality in a SOC 2® Engagement

In the SOC 2® engagement, materiality can be described as the likelihood and magnitude of
the risks that threaten the achievement of the service organization’s service commitments
and system requirements and whether the controls the service organization has designed,
implemented, and operated were effective in mitigating those risks to an acceptable level based
on the applicable trust services criteria.
The service auditor should consider the nature of threats and the likelihood and
magnitude of the risks arising from those threats to the achievement of the service
organization’s service commitments and system requirements based on the applicable trust
services criteria.

The service auditor’s consideration of materiality is a matter of professional judgment and is

affected by the service auditor’s perception of the common information needs of the broad
range of report users as a group.
When considering materiality, the service auditor typically considers whether misstatements
in the description or deficiencies in the suitability of design of controls, and the operating
effectiveness of controls (Type 2), could reasonably be expected to influence the relevant
decisions made by the broad range of report users.
If the engagement has been designed to meet the informational needs of a specific subset
of such SOC 2® report users, and the report is restricted to those specific users, the service
auditor considers the possible effect of such misstatements on the decisions that may be
made by that specific subset of report users.
2.4.3 Misstatements in a SOC Engagement

The following are common terms used when discussing misstatements related to the different
subject matters in a SOC engagement:
Description Misstatement: The term used when describing errors or omissions in the
description of the service organization’s system.
Deviation or Exception: Identified misstatements resulting from the failure of a control to
operate in a specific instance. A deviation could result in a deficiency.
Deficiency in the Design: When a control necessary to meet control objectives is missing
or improperly designed so that even if it operates as designed, control objectives would not
be achieved.
Deficiency in the Operating Effectiveness: When a properly designed control fails to
operate as designed or when the person performing the control does not possess the
competency necessary to perform the control effectively.
The service auditor accumulates misstatements related to each of the subject matters of
the engagement. These include the description, the suitability of design of controls, and
the operating effectiveness of controls (Type 2). Misstatements or deficiencies related to a
specific subject matter in the service auditor’s opinion could affect the other subject matters in
the opinion.
Example 2 Misstatements in a SOC Engagement
Brown Corp., a service organization that provides server hosting for the user entity’s emails,
included the following controls in its description:
Secured room with locks and a security system where email data is stored
and maintained
Backup power system for when power outages occur
Daily file backups to external servers in another state
It was determined that the security system included in the description was never
implemented by the service organization, which would compromise the operating
effectiveness of the organization’s controls to ensure that the email data is safely stored.
This control that was not implemented may affect the relevance of design controls, as
unauthorized personnel may have access to email data since the security system was
not implemented.

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3 Risk Assessment in a SOC Engagement
3.1 Understanding the System, System Requirements, and Service

Commitments in a SOC 2® Engagement
In a SOC 2® engagement, a system is defined as the infrastructure, software, procedures,
and data that are designed, implemented, and operated by people to achieve one or more
of the organization’s specific business objectives in accordance with management-specified
requirements. The system components are comprised of the following categories:
Infrastructure: Individual physical or virtual resources, or a collection of resources, that
support a service organization’s environment. This may include physical structures or
hardware such as buildings, servers, switches, file storage devices, surveillance equipment,
mobile devices, and internally or externally connected networks.
Software: Applications and programs that support the operations of an IT system such as
operating systems, middleware, database structures and retrieval mechanisms, external
web-based applications, internally shared applications, and details describing those systems
or how they function.
People: The employees, contractors, subcontractors, and managers who govern, manage,
operate, secure, and use the system. Common personnel include developers, system end
users, vendors, and managers.
Data: The type of information used by personnel and systems, information describing
that data such as data dictionaries, and information mapping the flow of data and where it
is stored.
Procedures: The automated or manual business procedures that are related to services
and products offered, including the activities that initiate, authorize, perform, deliver, and
report on those procedures.
3.1.1 Boundaries of the System

The boundaries of a system need to be clearly defined and communicated to report users in
a SOC engagement. The system boundaries are the specific aspects of a service organization’s
infrastructure, software, people, procedures, and data necessary to provide its services. When
systems for multiple services share aspects, infrastructure, software, people, procedures, and
data, the systems will overlap, but the boundaries of each system will differ.
A financial reporting system is bounded by the components of the system related to
financial transaction initiation, authorization, recording, processing, and reporting.
The boundaries of a system related to processing integrity may extend to other operations
such as risk management, internal audit, information technology, or call center processes.
In a SOC 2® engagement that addresses the confidentiality and privacy criteria, the system
boundaries cover, at a minimum, all the system components as they relate to the life cycle
of the confidential and personal information within well-defined processes and informal ad
hoc procedures.

3.1.2 Service Commitments and System Requirements

A service organization’s system of internal control is evaluated by using the trust services
criteria to determine whether such controls provide reasonable assurance that its business
objectives and sub-objectives were achieved. Objectives and sub-objectives relate primarily to
the following:
The achievement of service commitments made to user entities related to the system
used to provide the services and the system requirements necessary to achieve
those commitments.
Service commitments may be established for many different aspects of the service being
provided, including the following:
y Specifics of an algorithm used in a system calculation
y The hours the system will be available
y Published password standards
y Encryption standards used to encrypt stored customer data
Service commitments may also be established for one or more of the trust services
categories addressed by the description.
Compliance with laws and regulations regarding the provision of the services by the system.
The achievement of the other objectives the service organization has for the system.
System requirements may also define how the system should function to meet the service
commitments, comply with laws and regulations, and achieve other objectives. Examples include
requirements such as:
Workforce member fingerprinting and background checks established in government
banking regulations
System edits that restrict the values accepted for system input, which are defined in
application design documents
Maximum acceptable intervals between periodic reviews of workforce member logical
access as documented in the security policy manual
Data definition and tagging standards, including any associated metadata requirements
(e.g., Simple Object Access Protocol), established by industry groups or other bodies
Business processing rules and standards established by regulations (e.g., Health Insurance
Portability and Accountability Act)
System requirements may result from the service organization’s commitments related to one or
more of the trust services categories.

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3.1.3 Assessing the Suitability of the Service Commitments and

System Requirements
A service organization’s management is responsible for achieving its service commitments
and system requirements, as well as for disclosing the principal system requirements and
service commitments in the system description in a manner that allows SOC 2® report users
to understand how the controls operate and how management and the service auditor
evaluated the suitability of the controls' design and operating effectiveness (Type 2). The service
commitments that a service organization makes to user entities may differ based on the needs
of the user entities. Management does not need to disclose every service commitment to every
user entity. Management should disclose those that are relevant to the common needs of the
broad range of SOC 2® report users.
When deciding whether the disclosures stated in the description are appropriate, the service
auditor should consider whether:
The service commitments are presented in sufficient detail for report users to understand
the relationship between the controls implemented by the service organization, the service
commitments, and system requirements.
The description summarizes the principal service commitments that are common to such
report users when the SOC 2® report is designed for a broad range of users.
In addition to describing only controls that have been implemented, the description should
provide sufficient details about each control to enable report users, particularly user entities
and business partners, to understand how each control may affect their interactions with the
service organization.
Suitability of the Service Commitments and

Illustration 1
System Requirements
CompuGain Inc. is a payment processing company that allows its clients to process
payments using credit cards, debit cards, and mobile phones over its payment network.
Retail Xtra Co. signs up with CompuGain because of the payment processor’s ability to
maintain consumer privacy when processing transactions over its network. Due to the
focus on the trust services criterion of Privacy, Retail Xtra ensures that the following
stipulations (service requirements) are outlined in its service-level agreement:
CompuGain will obtain a customer’s consent before processing a payment and
transferring information.
CompuGain will provide a brief privacy notice to customers prior to completing a
transaction at the time of purchase.
CompuGain will respond to requests from Retail Xtra’s customers regarding past
transactions within 10 days of receiving the request.

3.2 Risk Assessment Considerations of the Service Organization

In a SOC engagement, risk assessment begins with the service organization identifying and
assessing the types, likelihood, and impact of risks that affect the preparation of the description,
the suitability of design of controls, and the operating effectiveness of controls (Type 2) within
the system. How an entity both identifies and manages risks could affect its ability to meet its
commitments and control objectives.
These risks may include:
Intentional and unintentional internal and external acts
Identified threats and vulnerabilities to, and deficiencies of, the system
The use of subservice organizations that store, process, or transmit sensitive information on
the service organization’s behalf
The type of employee personnel with access to the system
A lack of CUECs or CSOCs, when those controls are considered necessary
3.2.1 Inherent Risk Factors

In all SOC engagements, risk assessment primarily focuses on inherent risks (i.e., the risks
present before the consideration of controls) that affect the preparation of the description of
the system and the effectiveness of the service organization’s controls. Some of the risk factors
considered in an organization’s risk assessment process include the following:
Changes in the Operating Environment: Newly promulgated regulations or standards
may require new controls or existing ones to be revised.
New Personnel: New personnel performing manual controls could increase the risk that
controls do not operate effectively.
New or Revamped Information Systems: New IT systems could affect control functions
and user entities.
Rapid Growth: An increase in customers could reduce the effectiveness of certain controls.
New Technology: New software or other technology may perform similar functions
differently, which could affect user entities.
New Business Models, Products, or Activities: Diverting resources to new activities could
impact certain controls at the service organization.
Corporate Restructurings: Changes in ownership or internal structure may affect reporting
responsibilities or the resources that serve user entities.
Expanded Foreign Operations: Organizations that use employees in foreign locations may
have difficulty responding to changes in user requirements.
New Accounting Standards: Implementing new accounting pronouncements in software
and controls may affect user entities.
Changes in Economic Conditions: Slowing economic growth may impact the range of
services offered.

Education in rights
Engagement
3.3 Risk Assessment Considerations of a Service Auditor

In a SOC engagement, the service auditor must perform risk assessment procedures that are
sufficient to enable the auditor to identity and assess the risk of material misstatement and
provide a basis for designing and performing procedures that are responsive to the risks. In a
Type 1 or Type 2 engagement, the risk of material misstatement relates to the risk that, in all
material respects, based on the criteria in management’s assertion:
1. Management’s description of the service organization’s system is not fairly presented;
2. The controls are not suitably designed to provide reasonable assurance that the control
objectives stated in management’s description of the service organization’s system would be
achieved if the controls operated effectively; and
3. The controls did not operate effectively throughout the specified period to achieve related
control objectives stated in management’s description of the service organization’s system
(Type 2 only).
3.3.1 Performing Risk Assessment Procedures

As part of the risk assessment, the service auditor should obtain an understanding of the service
organization’s system, including controls within the system. That understanding should include
the service organization’s processes and procedures used to:
prepare the description of the service organization’s system, including the determination of
the control objectives;
identify the controls designed to achieve control objectives;
assess the suitability of the design of the controls; and
assess the operating effectiveness of controls (Type 2 only).
If the service organization has an internal audit function, the service auditor’s understanding of
the service organization’s system should include the following:
The nature of the internal audit function’s responsibilities and how the internal audit
function fits into the service organization’s organizational structure
The activities performed or to be performed by the internal audit function as it relates to the
service organization
The service auditor’s risk assessment procedures to obtain an understanding of the service
organization’s system may include the following, in some combination:
Inquiring of service organization management, those charged with governance, and others
within the service organization who, in the service auditor’s judgment, may have relevant
information.
Observing operations and inspecting documents, reports, and printed and electronic
records of transaction processing.
Inspecting a selection of agreements between the service organization and its user entities
and business partners.
Reperforming the application of a control.
Reading relevant reports received from regulators, internal auditors, or other specialists
(SOC 2®).

Service auditors may accomplish risk assessment procedures through the performance of a
walk-through. Additionally, risk assessment procedures may be performed concurrently with
procedures performed to obtain information about whether the system description is presented
in accordance with the description criteria and whether the controls were suitably designed and
operated effectively to meet the control objectives.
The service auditor should also perform risk assessment procedures to identify any fraud risk
or risk of noncompliance with laws or regulations. Risks could include management override
of controls, misappropriation of assets, or the creation of false or misleading documents
or records.

Education in rights
Engagement
5
MODULE
Performing SOC
Engagements ISC 4
1 Overview
Once the service auditor has accepted the engagement and completed the initial planning and
risk assessment, the next phase of the engagement involves obtaining an understanding of the
system defined by the service organization, performing tests of controls and obtaining evidence,
and the consideration of subsequent events.
Key areas of engagement performance once initial risk assessment procedures are complete:
1. Respond to the assessed risks.
2. Evaluate whether management’s description of the service organization’s system is fairly
presented in accordance with the description criteria.
3. Obtain and evaluate evidence regarding the suitability of the design of controls.
4. Obtain and evaluate evidence regarding the operating effectiveness of controls
(Type 2 only).
5. Evaluate the results of the procedures.
6. Form the opinion.
2 Responding to the Assessed Level of Risk
The service auditor is required to obtain sufficient audit evidence to reduce attestation risk to an
acceptably low level. This evidence enables the service auditor to obtain reasonable assurance
and to draw conclusions on which to base the service auditor’s opinion.
When performing a SOC engagement, the service auditor is required to design and implement
overall responses to address the assessed risks of material misstatement for the subject matter;
and design and perform further procedures whose nature, extent, and timing are based on, and
responsive to, the assessed risks of material misstatement.
Assessment of the risks of material misstatement is impacted by several factors, including:
materiality considerations;
the service auditor’s understanding of the effectiveness of the control environment; or
other components of internal control related to the service provided to user entities and
business partners.
The control environment or other components of the system of internal control may impact
the effectiveness of specific system controls. Ineffective aspects of the control environment or
other components of the service organization’s system of internal control may cause the service
auditor to design and perform further procedures whose nature, extent, and timing are based
on, and responsive to, the higher assessed risks related to the ineffective aspects of the control
environment or other components of internal control.
© Becker Professional Education Corporation. All rights reserved. Module 5 S4–79 P

5 Performing SOC Engagements ISC 4
Example 1 Audit Procedures Based on Risk Assessment
The service auditor observes a business process that rewards employees with a
compensation incentive for reaching targeted outcomes. If the service auditor assesses
a high risk of manipulation of controls to misstate the actual outcomes, due to the
employees’ desire to reach the incentive, it is likely that the service auditor will increase the
testing of controls, the sample population used for testing, or both.
Overall responses by the service auditor to address the assessed risks of material misstatement
may include:
Maintaining a culture of professional skepticism with the engagement team.
Assigning more experienced staff or using specialists as needed.
Providing additional supervision over audit procedures.
Incorporating elements of unpredictability in the selection of procedures to be performed.
Making changes to the nature, extent, or timing of procedures (e.g., selecting different types
of procedures, or changing the extent and timing of those procedures).
3 Evaluating Management’s Description
3.1 SOC 1®: Evaluating Whether Management’s Description of the

Service Organization’s System Is Fairly Presented
The service auditor is required to obtain and read management’s description of the service
organization’s system and evaluate whether those aspects of the description that are included in
the scope of the engagement are presented fairly, in all material respects, based on the suitable
criteria in management’s assertion, including whether:
The control objectives stated in management’s description of the service organization’s
system are reasonable in the circumstances.
Controls identified in management’s description of the service organization’s system
were implemented.
Complementary user entity controls and complementary subservice organization controls, if
any, are adequately described.
The services performed by a subservice organization, if any, are adequately described,
including whether the carve-out method or the inclusive method has been used in relation
to them.
The attributes of suitable criteria for evaluating the fair presentation of management’s
description includes:
Whether management’s description of the service organization’s system presents how
the service organization’s system was designed and implemented, including the following
information about the service organization’s system, if applicable:
y The types of services provided, including, as appropriate, the classes of
transactions processed.
S4–80 Module 5 Performing

© Becker Professional Education Corporation. SOC reserved.
All rights Engagements
ISC 4 5 Performing SOC Engagements
y The procedures, within both automated and manual systems, by which services
are provided.
y The information used in the performance of the procedures, including, if applicable,
related accounting records and supporting information involved in initiating,
authorizing, recording, processing, and reporting transactions.
y How the service organization’s system captures and addresses significant events and
conditions other than transactions.
y The process used to prepare reports and other information for user entities.
y Services performed by a subservice organization.
y The specified control objectives and controls designed to achieve those objectives.
y Other aspects of the service organization’s control environment, risk assessment
process, information and communications, control activities, and monitoring activities
that are relevant to the services provided.
Whether management’s description of the service organization’s system includes relevant
details of changes to the service organization’s system during the period covered by the
description (Type 2 only).
Whether management’s description of the service organization’s system does not omit
or provide misleading information relevant to the service organization’s system, while
acknowledging that management’s description of the service organization’s system is
prepared to meet the common needs of a broad range of user entities and their auditors,
and may not include every aspect of the service organization’s system that each individual
user entity may consider important in its own particular environment.
The service auditor should also consider and assess the adequacy of the level of detail of the
description, the nature of the user entities, and available documentation from the service
organization such as a policy and procedures manual, legal contracts, and any process narratives.
Through inquiries and other procedures, the service auditor should also determine whether the
service organization’s system has been implemented.
3.1.1 Performing Procedures to Obtain Evidence

Procedures the service auditor may perform to evaluate whether the description of the service
organization’s system is fairly presented typically include a combination of the following:
Considering the nature of the user entities and how the services provided by the service
organization are likely to affect them.
Reading contracts with user entities to gain an understanding of the service organization’s
contractual obligations.
Observing the procedures performed by service organization personnel.
Reviewing the service organization’s policy and procedure manuals and other
documentation of the system (e.g., flowcharts and narratives).
Performing walk-throughs of transactions through the service organization’s system.
A description is not fairly presented if:
the description states or implies that controls are being performed when they are not being
performed; or
the description inadvertently or intentionally omits relevant controls performed by the
service organization that are not suitably designed or operating effectively.

3.2 SOC 2®: Evaluating Whether the Description Presents the System
That Was Designed and Implemented in Accordance With the
Description Criteria
The service auditor should obtain and read the description of the service organization’s system
and perform procedures to determine whether the description is presented in accordance
with the description criteria. Determining whether the description of a service organization’s
system is presented in accordance with the description criteria involves comparing the service
auditor’s understanding of the service provided to user entities to the system through which
service is provided based on the trust services category or categories included in the scope of
the engagement.
A description of a service organization’s system in a SOC 2® engagement is presented in
accordance with the description criteria when it does the following:
Describes the system that the service organization has implemented.
Includes information about each description criterion, to the extent it is relevant to the
system being described.
Does not inadvertently or intentionally omit or distort information that is likely to be
relevant to report users’ decisions.
A description is not presented in accordance with the description criteria if:
the description states or implies that certain IT components exist when they do not;
the description states or implies that certain processes and controls have been
implemented when they are not being performed; or
the description contains statements that cannot be objectively evaluated.
Determining whether the description is presented in accordance with the description criteria
also involves evaluating whether each stated control has been implemented. A control has been
implemented when it has been placed into operation. If a service auditor concludes that certain
controls stated in the description have not been implemented, the service auditor may request
that the service organization delete those controls from the description. If management does
not modify the description accordingly, the service auditor should consider the impact on his or
her conclusion about the description and on the presentation of the service auditor’s report.
3.2.1 Performing Procedures to Obtain Evidence

The service auditor performs multiple procedures to obtain evidence about whether the
description presents the system that was designed and implemented in accordance with the
description criteria, including some combination of the following:
Discussing with management and other service organization personnel the content of
management’s assertion and the description.
Reading the service organization’s annual report.
Reading the service organization’s service commitments and system requirements to
determine whether they are appropriate for the specific engagement circumstances.
Inspecting documentation supporting the service organization’s risk assessment (including
plan for mitigating risks).
Observing controls performed by service organization personnel.
Reading contracts with user entities and business partners, as well as marketing
materials distributed to user entities and business partners or posted on the service
organization’s website.

Reading documents to understand the service organization’s risk governance structure and
processes (board minutes, organization charts, communications).
Reading documents to understand the organization’s process for communicating
responsibilities for system security to service organization personnel (employee handbooks,
code of conduct).
Reading internal audit reports, third-party assessments, audit committee presentations, and
other documentation related to the service organization’s monitoring activities.
Reading sample contracts with subservice organizations and vendors.
Reading incident response and recovery plan documentation to understand the service
organization’s processes for recovering from identified system events.
3.2.2 Walk-throughs and Other Procedures

Performing walk-throughs provide evidence about whether the controls within the system have
been implemented. Walk-through procedures include:
Following a transaction, event, or activity from origination until final disposition
through the service organization’s system using the same documents used by service
organization personnel.
Inquiry, observation, inspection of relevant documentation, and flowcharts, questionnaires,
or decision tables to facilitate understanding the design of the controls.
Inquiry about instances during the period in which controls did not operate as described
or designed.
Questioning variations in the process for different types of events or transactions.
An appropriately performed walk-through provides an opportunity to verify the service auditor’s
understanding of the flow of transactions and the design of the controls. When performed
properly, walk-throughs often provide evidence about whether controls included in the
description were suitably designed and implemented and operated effectively (Type 2).
3.2.3 Evaluation of Description Disclosures

The service auditor should evaluate whether the description is misleading within the context of
the engagement based on the evidence obtained. The service auditor should consider whether
additional disclosures are necessary to supplement the description.
Additional disclosures may include:
Significant interpretations made in applying the criteria in the engagement circumstances.
Subsequent events, depending on their nature and significance.
If the service auditor believes that the description is misstated or otherwise misleading, the
service auditor should ask management to amend the description. If service organization
management refuses to amend the description, the service auditor must consider the effect on
the opinion about the description.

4 Performing Tests of Controls and Other Procedures in a

SOC 2® Engagement
In addition to obtaining evidence that the description presents the system that was designed
and implemented in accordance with the description criteria, the service auditor must also
obtain evidence that the controls were suitably designed and operated effectively during the
specified period (Type 2).
4.1 Procedures to Obtain Evidence About the Suitability of the Design

of Controls
The evidence gathered by the service auditor when obtaining an understanding of the service
organization’s system and the related controls, as well as when determining if the description is
fairly presented is useful when assessing the suitability of the design of the controls.
To supplement such evidence, the auditor may perform a combination of the following
procedures:
Inquiry of service organization personnel about the design and operation of controls or
system events.
Inspection of documents.
Additional walk-throughs.
Reading applicable supporting system documentation.
Determining whether attacks, vulnerability exploitations, emerging risks, or threats have
been adequately addressed.
When evaluating the suitability of the design of the controls, the service auditor should consider
the frequency of the control, the competence and authority of the individual performing the
control, the precision and sensitivity of tasks within the control, and any evidence that may
contradict the assertion that the control is functioning as designed.
4.2 Obtaining Evidence About the Operating Effectiveness of Controls

in a Type 2 Engagement
If controls are suitably designed, they have the potential to meet the applicable trust services
criteria, thereby enabling the service organization’s controls to provide reasonable assurance
that the service organization’s service commitments and system requirements were achieved.
Suitably designed controls operate as designed by individuals who have the necessary
authority and competence to perform the controls.
Controls that operate effectively provide reasonable assurance of achieving the service
services criteria.
In the Type 2 engagement, the service auditor tests the operating effectiveness of the controls
stated in the description based on the applicable trust services criteria. The service auditor
performs tests of controls to obtain evidence about the operating effectiveness of controls.
The evidence obtained from the tests of controls relates to how the controls were applied, the
consistency with which they were applied, and by whom or in what manner they were applied.

If a service organization uses the inclusive method to present the services and controls of a
subservice organization, the service auditor also applies tests of controls to the controls at
the subservice organization.
The service auditor is responsible for determining the nature, extent, and timing of procedures
necessary to obtain sufficient and appropriate evidence about the operating effectiveness of
controls throughout the engagement period.
Nature: How controls are tested.
Extent: The number of procedures performed and the size of the sample.
Timing: When the controls are tested and the frequency of testing.
A combination of controls is necessary when more than one control is required to address
a risk that would prevent the service organization from achieving one or more of its service
4.2.1 Nature of Test of Controls

The nature and objectives of tests to evaluate the operating effectiveness of controls are
different from those performed to evaluate the suitability of the design of controls. When
designing and performing tests of controls, the service auditor will often do the following:
Make inquiries and perform other procedures such as inspection, observation, or
reperformance to obtain evidence about the following:
y How the control was applied.
y The consistency with which the control was applied throughout the period.
y By whom or by what means the control was applied.
Determine whether the controls to be tested depend on other controls and, if so, whether
it is necessary to obtain evidence supporting the operating effectiveness of those
other controls.
Evaluate and determine an effective method for selecting the items to be tested to meet the
objectives of the procedure.
The service auditor must consider the reliability of evidence obtained by evaluating the
completeness and accuracy of information and determining whether it is sufficiently precise to
meet their needs.
4.2.2 Extent of Test of Controls

The extent of the service auditor’s testing refers to the size of the sample tested or the number
of observations of a control activity.
The extent of testing is based on the service auditor’s professional judgment after considering:
y The tolerable rate of deviation
y The expected rate of deviation
y The frequency with which the control operates
y The relevance and reliability of the evidence that can be obtained to support the
conclusion that the controls are operating effectively
y The length of the testing period

y The significance of the control to the achievement of the service organization’s service
commitments and system requirements based on the applicable trust services criteria
y The extent to which audit evidence is obtained from tests of other controls that support
the achievement of those service commitments and system requirements based on the
applicable trust services criteria
4.2.3 Timing of Test of Controls

The following are factors that are relevant to the service auditor’s determination of the timing of
tests of controls:
The period of time during which the information will be available:
y Electronic files may be overwritten after a period of time.
y Procedures may occur only at certain times during the period.
y Certain procedures may need to be performed after the end of the period, such as
reviewing reconciliations that are generated after the end of the period.
Whether the control leaves evidence of its operation and, if not, whether the control should
be tested through observation.
The significance of the control being tested.
The service auditor may perform tests of controls at interim dates, at the end of the engagement
period, or after the engagement period if the tests relate to controls that were in operation
during the period but do not leave evidence until after the end of the period. When tests are
performed at an interim date, the service auditor should determine what procedures are
necessary to obtain evidence about the control performance through the end of the period.
4.3 Reporting Failures, System Incidents, and Concerns

Service auditors should gain an understanding of processes in place to report system failures,
system incidents, and complaints by either external or internal system users by inquiring
of management about the controls in place. Management is responsible for identifying the
nature, extent, and timing of system incidents in the service organization’s system description,
making that an ideal place to start reviewing for such incidents. Service auditors may consider
information related to the following in gaining an understanding and obtaining evidence:
Quarterly or annual board meetings should involve discussions of incident responses and
escalation plans for unforeseen events. Minutes from board meetings should indicate
communication of such failures to senior management and the board of directors, as well as
the incident response plan resulting from a significant event.
Inquiries about third-party administered whistleblower hotlines available to internal and
external users to understand whether management monitors workforce and customer
complaints as well as sanction personnel who violate the code of conduct. Verification and
testing of operability can be performed by test-dialing the hotline, reviewing operating
procedures related to complaint intake, and documenting system failures.
External and internal system users should be provided with documented responsibilities,
policies, and procedures related to security commitments, including instructions on how to
report and escalate security failures, system incidents, concerns, and complaints. A common
place for documentation around policies, procedures, and communication plans to be in
place is on a company’s intranet for employees, customer portal, and websites. Changes,
security alerts, and known issues should be documented and communicated to internal and
external system users.

Management monitors and provides training to personnel.

External and internal system users are provided with a description of its system, system
boundaries, and system processes that include infrastructure, software, people, processes
and procedures, and data. A common place for this documentation is on a company’s
intranet for internal users, and internet for external users.
Agreements are established with service providers and business partners that include
clearly defined terms, conditions, and responsibilities for service providers and
business partners.
Planned changes to system components are reviewed, approved, and scheduled internally,
then communicated (along with potential impact) to internal and external users. A common
place for this documentation is the IT maintenance schedule and communications for
internal users, and the customer portal or website for external users.
5 Evaluating the Results of Procedures in a SOC 2®

Engagement
Sufficient evidence is necessary to support the service auditor’s opinion and report. The service
auditor must consider all information and evidence obtained during the engagement. This
should include evidence from all sources (both internal and external) as well as evidence that
both corroborates or contradicts management’s assertions.
The absence of information should be considered by the service auditor as evidence.
If the evidence is not sufficient and appropriate based on the professional judgment of the
service auditor, additional procedures should be performed to gather additional evidence.
If the service auditor is unable to obtain necessary further evidence, the service auditor should
consider the implications for the service auditor’s opinion.
The service auditor must evaluate the results of all procedures performed and must conduct
both quantitative and qualitative analyses. Analysis must also be performed on deviations in the
operating effectiveness of controls resulting in a description that is not presented in accordance
with the description criteria or in controls that are not suitably designed or operating effectively
(Type 2 only).
When evaluating the results of procedures, the service auditor investigates the nature and cause
of any identified description misstatements and deficiencies or deviations in the effectiveness of
controls and determines the following:
Whether the identified description misstatements result in either the failure to meet
one or more of the description criteria or in a presentation that could be misunderstood
by users if the service auditor’s opinion were not modified to reflect the identified
description misstatements.
Whether identified deviations are within the expected rate of deviation and are acceptable
or whether they constitute a deficiency.
If deviations are within the expected rate of deviation, whether the procedures that have
been performed provide an appropriate basis for concluding that the control operated
effectively throughout the specified period.
Whether identified deficiencies are likely to have a pervasive effect on the achievement of
the service organization’s service commitments and system requirements based on the
applicable trust services criteria or whether they are likely to affect only one of them.

Whether:
y a previously tested control (or combination of controls) provides sufficient appropriate
evidence about whether controls operated effectively; or
y additional testing of the control or other controls is necessary to determine whether the
controls were effective throughout the period.
If the service auditor is unable to apply additional procedures to the selected items, the
service auditor should consider the reasons for this limitation and conclude on whether
those selected items are deviations from the prescribed policy or result in a limitation of
the scope of the engagement.
The magnitude of the effect of such deficiencies on the achievement of the service
services criteria.
Whether report users could be misled if the service auditor’s opinion were not modified to
reflect the identified deficiencies.
Considerations of any known or suspected fraud or noncompliance with laws or regulations.
If the service auditor identifies material description misstatements, material deficiencies in the
suitability of design of controls, or deviations in the operating effectiveness of controls (Type 2),
the service auditor should modify the opinion. When modifying the opinion, the service auditor’s
understanding of the nature and cause of the description misstatements and deficiencies
enables the service auditor to determine how to appropriately modify the opinion.
6 Subsequent Events and Subsequently Discovered Facts
6.1 Nature of Subsequent Events

Transactions or events may occur after the engagement period, but prior to the date of the
service auditor’s report, that could have a significant effect on the description, the suitability of
design of controls, and the operating effectiveness of controls (Type 2), or on management’s
assertion. In these circumstances, disclosure of those events and transactions in the description
may be necessary to prevent report users from being misled.
The service auditor is required to inquire of management about whether it is aware of any such
events. If such events exist, the service auditor should apply appropriate procedures to obtain
evidence regarding the events.
The service auditor may obtain evidence by inquiring about the operating effectiveness of
controls by inspecting the following:
Relevant internal auditors’ reports issued during the subsequent period
Other practitioners’ reports issued during the subsequent period
Relevant regulatory agencies’ reports issued during the subsequent period
Reports on other professional engagements for that entity

6.1.1 Subsequent Events Likely to Affect a SOC Report

The following examples are likely to affect system descriptions or management’s assertions
in a SOC engagement. After the period covered by an engagement, the service organization’s
management discovered:
During the last quarter of the period covered by the service auditor’s report, the IT director
provided all of the programmers with access to the production data files, enabling them to
modify data.
A confidentiality breach occurred during the period covered by the service auditor’s
report (SOC 2®)
The signatures on a number of non-automated trade execution instructions submitted
during the engagement period that appeared to be authenticated by signature verification
had been forged (SOC 1®).
A defalcation occurred at the service organization (SOC 1®).
6.1.2 Subsequent Events Unlikely to Affect a SOC Report

Not all subsequent events are likely to impact a SOC report. The following examples are frequent
subsequent occurrences that are unlikely to affect system descriptions or management’s
assertions.
The service organization:
was acquired by another company.
experienced a major operational disruption that was caused by weather or a natural
disaster.
made significant changes to its information systems, including either a system conversion or
outsourcing a portion of its operations.
6.1.3 Impact of Subsequent Events on the SOC Report

Upon becoming aware of a subsequent event that is of significance, a service auditor should
request that management disclose the event in either management’s assertions or the
description of the service organization’s system.
If management refuses to disclose an event, that if undisclosed, would mislead report users, the
practitioner should consider taking the following actions:
Modifying the auditor’s report and disclosing the event.
Withdrawing from the engagement.
6.2 Subsequently Discovered Facts After the Issuance of a SOC Report

The service auditor is not required to perform any procedures regarding the description,
the suitability of design of controls, the operating effectiveness of controls (Type 2), or
management’s assertion after the date of the service auditor’s report. However, the service
auditor is responsible for responding appropriately to facts that become known after the date of
the report.

The service auditor should, using professional judgment, determine whether the subsequently
discovered facts, had they been known as of the report date, may have caused the service
auditor to revise the report.
The service auditor determines whether the facts existed at the date of the report and, if so,
whether persons who would attach importance to these facts are currently using, or likely to
use, the report.
The service auditor may do this through discussions with management and other appropriate
parties and through the performance of additional procedures that the service auditor
considers necessary to determine whether the description, assertion, and service auditor’s
report need revision or whether the previously issued report continues to be appropriate.
The service auditor may determine it is necessary to notify persons currently using or likely
to use the service auditor’s report depending on factors such as the time elapsed since the
date of the report and when the issuance of a subsequent report is imminent.
7 Obtaining Written Representations From Management
The service auditor is required to obtain written representations from the management
of the service organization. Such representations are intended to confirm explicit or
implicit representations given to the service auditor, indicate and document the continuing
appropriateness of those representations, and reduce the possibility of a misunderstanding
between the service auditor and management. The service auditor should determine the
appropriate individuals within the service organization’s management or governance structure
based on their responsibilities and knowledge of the subject matter of the engagement.
The written representations should be as of the date of the issued SOC report and should
address the subject matter and periods covered by the service auditor’s opinion. The service
auditor would not ordinarily be able to issue the report until the service auditor had received the
representation letter. If a subservice organization is used and the inclusive method is used for
management’s description of the system, written representations should be obtained from the
subservice organization as well.
7.1 Content of Written Representations

The written representations should do the following:
Include management’s assertion about the subject matter based on the criteria.
State that:
y All relevant matters are reflected in the measurement or evaluation of the subject
matter or assertion.
y All known matters contradicting the subject matter or assertion and any
communications from regulatory agencies or others affecting the subject matter have
been disclosed to the service auditor (including communications received between
the end of the period addressed in the written assertion and the date of the service
auditor’s report).
Acknowledge responsibility for:
y the subject matter and assertions;
y selecting the criteria; and
y determining that such criteria are appropriate for management’s purposes.

State that any known subsequent events related to the subject matters of the report that
would have a material effect on the subject matter or assertion have been disclosed to the
service auditor.
State that management has provided the service auditor with all relevant access
and information.
State that management believes the effects of uncorrected misstatements (description
misstatements and deficiencies) are immaterial, individually and in the aggregate, to the
subject matter.
State that management has disclosed to the service auditor:
y All deficiencies in internal control relevant to the engagement of which it is aware.
y Its knowledge of any actual, suspected, or alleged fraud or noncompliance with laws or
regulations affecting the subject matter.
y All other matters deemed appropriate by the service auditor (e.g., changes to the
service organization’s controls).
y Instances of noncompliance with laws and regulations or uncorrected misstatements
attributable to the service organization (SOC 2®), including those that may affect one or
more user entities (SOC 1®).
y Knowledge of any actual, suspected, or alleged fraud by management or the service
organization’s employees that could adversely affect:
—The fairness of the presentation of management’s description of the service
organization’s system or the completeness or achievement of the control objectives
stated in the description (SOC 1®).
—The description of the service organization’s system or the achievement of the service
organization’s service commitments or system requirements (SOC 2®).
y Identified system incidents that resulted in a significant impairment of the service
organization’s achievement of its service commitments and system requirements as
of the date of the description (Type 1) or during the period of time covered by the
description (Type 2) (SOC 2®).
State that significant assumptions used in making any material estimates are reasonable
(SOC 1®).
7.2 Written Representations Not Provided

If management does not provide one or more of the requested representations, or the service
auditor concludes that there is sufficient doubt about the competence, integrity, ethical values,
or diligence of those providing the written representations, or the service auditor concludes that
the written representations are otherwise not reliable, the service auditor should:
discuss the matter with the appropriate party;
reevaluate the integrity of those from whom the representations were requested or
received and evaluate the effect that this may have on the reliability of representations and
evidence in general; and
if any of the matters are not resolved to the practitioner’s satisfaction, take
appropriate action.
Failure by management to provide written representations to the service auditor may constitute
a scope limitation. In such cases, if the matters remain unresolved, the service auditor may be
precluded from issuing an unmodified opinion. Depending on the circumstances, the service
auditor may withdraw from the engagement if permitted by law or regulation.

NOTES


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ISC

1 National Institute of Standards and

2 Privacy and Data Security Standards 15

3 Center for Internet Security Critical Security Controls:

4 Center for Internet Security Critical Security Controls:

5 COBIT 2019 Framework 43

S1–2 © Becker Professional Education Corporation. All rights reserved.

1 National Institute of Standards and Technology (NIST)

1.1 NIST Background

1.2 Cybersecurity Framework

© Becker Professional Education Corporation. All rights reserved. Module 1 National

Tier 1 Tier 2 Tier 3 Tier 4

Source: Reprinted courtesy of the National Institute

1.2.1 Framework Core

S1–4 Module 1 National

Function ID Function Category ID

Subcategory Informative Resources

© Becker Professional Education Corporation. All rights reserved. Module 1 National

Cybersecurity Framework Core: Detect, Respond,

Illustration 2 Detective Measures as Concurrent Protections

S1–6 Module 1 National

1.2.2 Implementation Tiers

Tier 1 Tier 2 Tier 3 Tier 4

Risk Management Process

Integrated Risk Management Program

The CSF Framework Profiles determine success or failure of information security

© Becker Professional Education Corporation. All rights reserved. Module 1 National

1.2.3 Framework Profiles

S1–8 Module 1 National

2 National Institute of Standards and Technology (NIST)

2.1 Privacy Framework

© Becker Professional Education Corporation. All rights reserved. Module 1 National

S1–10 Module 1 National

These Functions help organizations answer the following questions:

© Becker Professional Education Corporation. All rights reserved. Module 1 National

3 NIST Security and Privacy Controls

3.1 NIST SP 800-53

S1–12 Module 1 National

© Becker Professional Education Corporation. All rights reserved. Module 1 National

S1–14 Module 1 National

Privacy and Data

1.1 Privacy Laws

1.2 Data Breaches

2 Modern Privacy Regulations

2.1 Health Insurance Portability and Accountability Act (HIPAA)

S1–16 Module 2 Privacy

2.2 General Data Protection Regulation (GDPR)

2.2.1 Privacy Shield

3 Data Security Standards

3.1 Payment Card Industry Data Security Standard (PCI DSS)

Goals PCI DSS Requirements

S1–18 Module 2 Privacy

CUSTOMER CARD NETWORK

S1–20 Module 2 Privacy

1 Center for Internet Security (CIS) Controls

1.2 Design Principles

© Becker Professional Education Corporation. All rights reserved. Module 3 Center

1.3 Implementation Groups

Essen�al Cyber Hygiene