EvidenceSheet

CC5.3 Deploying controls through policies and procedures (COSO principle 12)

Control activities are put into practice through policies that state expectations and procedures that carry them out. Points of focus: policies and procedures embed management's directives in daily work; responsibility and accountability sit with the managers of the unit where the risk lives; controls are performed on time; issues found while performing controls are investigated and acted on; competent people with enough authority perform them diligently; and policies and procedures are reviewed periodically and refreshed when needed.

Source: SOC 2 (2017 Trust Services Criteria), CC5.3. 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.

4
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

  • Evidence of annual policy review and approval · Policy repository / GRC workspace
  • Records showing exceptions found during control operation were followed up · Policy repository / GRC workspace

governing documentDocuments that govern the control

  • Approved information security policy set with owners and review dates · Policy repository / GRC workspace
  • Operating procedures for key controls · 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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CC5.2 General controls over technology (COSO principle 11) · CC6.1 Logical access security over protected information assets