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IT Auditing: Using Controls to Protect Information Assets, Second Edition
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2 Request your service provider to produce independent assurance from reputable third parties regarding the effectiveness of their internal controls and compliance with applicable regulations Review the documentation for issues that have been noted Also, determine how closely these certifications match your own company s control objectives and identify gaps
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Although you are attempting to perform your own audit of your service provider s controls, experienced service providers will already be engaging third parties for regular assessments These assessments can be used to reduce your need to audit the service provider s functions, thereby reducing the scope of your audit In fact, many service providers, especially the larger ones, will insist that you use these assessments in lieu of performing your own audit This step is most applicable to cloud computing, dedicated hosting, and offsite service outsourcing
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Request this information from your vendor The type of independent assurance you ask for will vary depending on your industry, but the most common assessment you should look for will be a SAS 70 report Make sure you request a Type 2 SAS 70 assessment Another common assessment you may see is ISO 27001, which is a standard dealing with information security that is intended to form a basis for a third-party audit of security You will need to determine what assessment(s) should be expected based on your industry, the type of outsourcing being performed, and the type of auditing you re performing For example, if you re performing an audit of an outsourced website, you should expect to see some form of web security certification As part of this exercise, you will need to determine whether your vendor subcontracts any relevant functions to additional third parties (for example, if you re using a SaaS vendor and it uses another vendor s data center facilities to host its systems) If so, request that your vendor obtain applicable independent assessments from those subcontract vendors and provide them to you Once you receive whatever assessments are available, you must review them in a number of areas First, obviously, you must review the results of the assessment to understand any issues noted and the vendor s remediation plans You will want to track these items to ensure that they have been remediated satisfactorily (which again you may need to determine via a third-party assessment) It is also important to ensure that the assessment was performed by a qualified independent third party and to determine the time period covered by the assessment to be sure it is still relevant You will also need to review the scope of the assessment performed and determine how many of your control objectives were addressed by the assessment You will likely see some gaps between your company s control objectives and the control objectives addressed by the independent assessment Once you identify these gaps, you can attempt to perform your own assessments of those items not covered by the third-party assessment You will have to negotiate each instance separately and enlist the aid of your procurement, legal, and operations groups to see how far you can push for the
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14: Auditing Cloud Computing and Outsourced Operations
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ability to perform your own audit This again emphasizes the importance of placing a right to audit clause in your contracts If you find that your vendor does not have appropriate third-party assessments, you will have to attempt to perform all pertinent audit steps yourself (which may be limited by your right to audit) If this is the case, you should push your vendor to obtain a SAS 70 Type 2 and/or other pertinent independent assessments, possibly making this a negotiating point at contract renewal time You should expect to see this type of assessment for any form of IT systems and infrastructure outsourcing (such as cloud computing) It may not be reasonable to expect it for IT service outsourcing models where you are providing significant guidance on day-to-day activities (such as when you outsource a function but leave it onsite using your own systems)
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