3.7.9 Service provider customer key responsibilities
Additional requirement for service providers: cryptographic keys used to protect stored customer account data are managed under a documented agreement with the customer or based on service provider responsibilities.
5
artefacts
0
held by a system
2
at each review
hard
to go live
Vendor register / contract repository
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- Annual confirmation to customers · Policy repository / GRC workspace
- Customer onboarding evidence · HR system / LMS
governing documentDocuments that govern the control
- Customer responsibility matrix per contract · Vendor register / contract repository
- Master agreement clauses · Vendor register / contract repository
- Internal procedure document · Policy repository / GRC workspace
First move
This control is evidenced by people and documents, not systems. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date. Do not try to automate it.
Common gaps auditors find
- No matrix shared with customers
- Inconsistent responsibilities across customers
- No annual confirmation
Do this for your whole sheet
Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.
Build my evidence sheet3.7.8 Custodians acknowledge responsibilities · 4.1.1 All security policies and operational procedures that are identified in Requirement 4 are: • Documented. • Kept up to date. • In use. • Known to all affected parties