CC5.3 COSO principle 12: Deploys control activities through policies and procedures
Deploys control activities through policies that establish what is expected and in procedures that put policies into action.
5
artefacts
0
held by a system
0
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
none for this control
governing documentDocuments that govern the control
- Policies establishing what is expected and the procedures putting them into action, with owners and approval evidence · Policy repository / GRC workspace
- Evidence responsibility and accountability for executing each procedure is established with competent personnel · Policy repository / GRC workspace
- Evidence procedures are performed timely, with records showing when each was performed during the period · Policy repository / GRC workspace
- Evidence corrective action is taken where a procedure identifies an issue · Policy repository / GRC workspace
- Evidence policies and procedures are reassessed periodically and updated as needed · 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
- Policy exists with no corresponding procedure, so nothing tells anyone how to perform the control
- Procedures performed irregularly with records showing large gaps in the period
- Procedures assigned to individuals who have left, so the control lapses silently
- Annual review evidenced by a version date change with no indication anything was reconsidered
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 sheetCC5.2 COSO principle 11: Selects and develops general controls over technology · CC6.1 Implements logical access security software, infrastructure and architectures over protected information assets