EvidenceSheet

CC1.5 Accountability for internal control responsibilities (COSO principle 5)

People are held answerable for the internal control duties assigned to them. Points of focus: structures and authority are used to communicate duties and apply corrective action; performance measures, incentives and rewards reflect control responsibilities and expected conduct across short and longer terms; those incentives are reviewed for continued relevance; pressures created by targets are weighed when assigning work and measuring performance; and performance of control duties, including conduct and competence, is evaluated with reward or discipline as warranted. The 2022 revision adds, for privacy engagements, a defined sanctions process used when staff breach privacy policies or cause a privacy incident through negligence.

Source: SOC 2 (2017 Trust Services Criteria), CC1.5. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open SOC 2 (2017 Trust Services Criteria) in the compliance library.

These are criteria, not controls: you design controls that meet them, and which criteria are in scope follows the categories your report covers (Security always; Availability, Confidentiality, Processing Integrity and Privacy only if chosen). A Type 2 report tests that the controls operated across the period, so the evidence asked for is samples across that period, not one copy.

5
artefacts
0
held by a system
2
at each review
hard
to go live
Policy repository / GRC workspace
where the evidence lives
teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

  • Periodic review of incentive schemes against control objectives · Policy repository / GRC workspace
  • Evidence of corrective action after control owners missed duties · Policy repository / GRC workspace

governing documentDocuments that govern the control

  • Performance objectives that include security or control responsibilities · Policy repository / GRC workspace
  • Documented disciplinary policy and examples of its application to control failures · HR system / LMS
  • Sanctions procedure covering privacy policy breaches, with case records where it was applied (privacy engagements) · Policy repository / GRC workspace

First move

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

Common gaps auditors find

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.

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CC1.4 Attracting, developing and retaining competent people (COSO principle 4) · CC2.1 Relevant, quality information to support internal control (COSO principle 13)