CC4.1 COSO principle 16: Selects and develops ongoing and separate evaluations
Selects, develops, and performs ongoing and/or separate evaluations to ascertain whether the components of internal control are present and functioning.
5
artefacts
0
held by a system
3
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
- Results of evaluations performed in the period, such as internal audit reports, control self assessments, vulnerability assessments and penetration tests · Vulnerability scanner / patch tooling
- Evidence evaluators are objective and knowledgeable, and independent of the activity evaluated · SIEM / log platform
- Evidence of the mix and rate of change, showing evaluations are adjusted as risk changes · SIEM / log platform
governing documentDocuments that govern the control
- The plan for ongoing and separate evaluations, showing scope, type, frequency and who performs them · Policy repository / GRC workspace
- Evidence a baseline understanding of the control system exists and is used to scope evaluations · 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
- Only one annual assessment performed, with no ongoing evaluation between times
- Evaluations performed by the people who operate the controls, so objectivity fails
- Scope repeated year on year with no adjustment for change in the environment
- Penetration testing treated as the whole of the monitoring activity, leaving process controls unevaluated
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 sheetCC3.4 COSO principle 9: Identifies and assesses changes that could impact internal controls · CC4.2 COSO principle 17: Evaluates and communicates deficiencies in a timely manner