CC3.4 COSO principle 9: Identifies and assesses changes that could impact internal controls
Identifies and assesses changes that could significantly impact the system of internal control.
5
artefacts
0
held by a system
4
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
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- Records of changes identified in the period and the assessment of their impact on the control environment · Cloud console / configuration management
- Evidence of reassessment of risks following those changes · Policy repository / GRC workspace
- Evidence the process covers changes at vendors and business partners · Vendor register / contract repository
- Records of controls added or amended as a result · Policy repository / GRC workspace
governing documentDocuments that govern the control
- The process for identifying and assessing changes that could significantly affect internal control, covering the external environment, the business model, leadership and technology · 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
- Change assessment limited to technical change management, missing business, leadership and regulatory change
- Significant changes such as an acquisition, a new product or a cloud migration occurring with no reassessment of risk
- Vendor changes, including a vendor changing subprocessor or location, never identified
- Process defined with no evidence it operated during a period in which the entity plainly changed
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 sheetCC3.3 COSO principle 8: Considers potential for fraud · CC4.1 COSO principle 16: Selects and develops ongoing and separate evaluations