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IT Attestation in the
Cloud Era
The need for increased
assurance over outsourced
operations/ controls
April 2013
Symeon Kalamatianos M.Sc., CISA, CISM
Senior Manager, IT Risk Consulting
Contents
© 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent
memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity.
All rights reserved.
1
 Introduction
 SOC Assurance Reporting – Overview & Market Trends
 Effectively using SOC reports
 Conclusion
 Q/A
Speed to Market
Improve
Working Capital
Reduce Invested
Capital
Reduce Cost of
Goods Sold
Reduce SG&A
Cloud Impact on Business
Opportunities to Leverage
Commoditized Enterprise
Applications and
Economies of Scale
Virtualized Business Models
Virtualized Technology
Virtualized
Processes
Virtualized
Organization
Internet-based data access &
exchange
© 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent
memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity.
All rights reserved.
2
Internet-based access to low cost computing
& applications
+
Cloud
Environment =
KPMG Recent Survey
68%
40%
9%
6%
10%
7%
0%
40%
28%
20%
60%
80%
100%
Already using
Cloud
Planning to do so
within next 2 years
Planning to do so Planning to do so No, not at this time Not sure what the
in 2-3 years in 3+ years plans are
68%
Over 2/3 Are Already Using
Cloud or Plan To In Next 2
Years
© 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent
memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity.
All rights reserved.
3
Key Security Challenges
Security has been the greatest concern surrounding Cloud Adoption at enterprises
© 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent
memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity.
All rights reserved.
4
Complexity and Exposure define assurance model
Employees,
Private
Intranet
Internal
External
Strangers,
Public
Internet
Proprietary, Distributed, Complex
Cloud
Computing
Model
Exposure
Reliance on
Internal Controls
Need for Increased
assurance
Private
Cloud
Outsourced
Data Center
Traditional
Familiar, Simple
External
Portal
Virtual
Private
Cloud
Public
Cloud
Corporate
Data Center
© 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent
memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity.
All rights reserved.
5
Service Organization Control
Assurance Reporting –
O
• verview and Market Trends
Service Organization Control (SOC) Assurance Reporting
Scope/Focus Report Summary Applicability
Internal Control
Over Financial
Reporting
(ICOFR)
ISAE3402 /
SOC1*
Detailed report for users and
their auditors
 Focused on financial reporting
risks and controls specified by the
service provider.
 Most applicable when the service
provider performs financial
transaction processing or
supports transaction processing
systems.
Operational
Controls
ISAE3000/
SOC2SM
Detailed report for user
organizations, their auditors,
and specified parties
 Focused on Trust Services
Principles:
- Security
- Availability
- Confidentiality
- Processing Integrity and/or
- Privacy.
 Applicable to a broader variety of
systems.
ISAE3000 /
SOC3SM**
Short report that can be more
generally distributed, with the
option of displaying a web site
seal
* Sometimes also referred to as an SSAE 16, AT 801
** Sometimes also referred to as a SysTrust, WebTrust, or Trust Services report
© 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent
memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity.
All rights reserved.
7
Type 1 and Type 2 Reports
© 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent
memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity.
All rights reserved.
8
 Point in time reports (Type 1) reports cover the suitability of design of controls as of a point
in time. The Type I report is a snapshot in time.
 Period of time (Type 2) reports cover the suitability of design and operating effectiveness of
controls over a period of time, typically 6 or 12 months.
 For example, a service organization providing a new service might start by completing an
initial SOC2 Type 1 examination and then complete recurring SOC2 Type 2 examinations.
Generally, when talking about a service organization control report, a Type II report is meant.
A Type I report should be seen as an informative report.
Contrasting SOC2/SOC3 and SOC1 Report Scope
© 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent
memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity.
All rights reserved.
9
Attribute SOC2/SOC3 SOC1
Required Focus  Operational Controls  ICOFR
Defined Scope of
System
 Infrastructure
 Software
 Procedures
 People
 Data
 Classes of transactions
 Procedures for processing and reporting
transactions
 Accounting records of the system
 Handling of significant events and
conditions other than transactions
 Report preparation for users
 Other aspects relevant to processing and
reporting user transactions
Control Domains
Covered
 Security
 Availability
 Confidentiality
 Processing Integrity and/or
 Privacy
 Transaction processing controls
 Supporting IT general controls
Level of
Standardization
 Principles selected by service
provider.
 Pre-defined criteria used rather
than control objectives.
 Control objectives defined by service
provider and may vary depending on the
type of service provided.
Applicability of Trust Services Principles
© 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent
memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity.
All rights reserved.
10
Domain Trust Services Principle Trends Regarding Applicability
Security
 The system is protected against
unauthorized access (both
physical and logical).
 Most commonly requested area of
coverage.
 Security criteria are also incorporated into
the other principles because security
controls provide a foundation for the other
domains.
 Applicable to all outsourced environments,
particularly where enterprise users require
assurance regarding the service provider’s
security controls for any system, non-
financial or financial.
Availability
 The system is available for
operation and use as committed
or agreed.
 Second most commonly requested area of
coverage, particularly where disaster
recovery is provided as part of the standard
service offering.
 Most applicable where enterprise users
require assurance regarding processes to
achieve system availability SLAs as well as
disaster recovery which cannot be covered
as part of SOC1 reports
Applicability of Trust Services Principles (continued)
© 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent
memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity.
All rights reserved.
11
Domain Trust Services Principle Trends Regarding Applicability
Confidentiality
 Information designated as
confidential is protected as
committed or agreed.
 Most applicable where the user requires
additional assurance regarding the service
provider’s practices for protecting
sensitive business information.
 Applicable where a service provider is
entrusted to maintain the confidentiality of
an enterprise customer’s data of all types.
Processing
Integrity
 System processing is complete,
accurate, timely, and
authorized.
 Potentially applicable for a wide variety of
non-financial and financial scenarios
wherever assurance is required as to the
completeness, accuracy, timeliness and
authorization of system processing.
Privacy
 Personal information is
collected, used, retained,
disclosed, and destroyed in
conformity with the
commitments in the entity’s
privacy notice and with criteria
set forth in generally accepted
privacy principles and
regulatory frameworks.
 Most applicable where the service
provider interacts directly with end users
and gathers their personal information.
 Provides a strong mechanism for
demonstrating the effectiveness of
controls for a privacy program.
SOC2/SOC3 Criteria Summary
© 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent
memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity.
All rights reserved.
12
Security
 Security policies
 Security awareness and
communication
 Risk assessment
 Threat identification
 Information classification
 Logical access
 Physical access
 Security monitoring
 Incident management
 Encryption
 Personnel
 Systems development and
maintenance
 Configuration management
 Change management
 Monitoring / compliance
Availability Confidentiality Processing Integrity Privacy
 Availability policy
 Backup and
restoration
 Environmental
controls
 Disaster recovery
 Confidentiality
policy
 Confidentiality of
inputs, data
processing, and
outputs
 Information
disclosures
 Confidentiality of
Information in
systems
development
 System processing
integrity policies
 Completeness,
accuracy,
timeliness, and
authorization of
inputs, system
processing, and
outputs
 Information tracing
from source to
disposition
 Management
 Notice
 Choice and consent
 Collection
 Use and retention
 Access
 Disclosure to third
parties
 Quality
 Monitoring and
enforcement
Contrasting the level of detail provided by SOC 2
and SOC 3 reports
© 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent
memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity.
All rights reserved.
13
SOC 2 SOC 3
Common
benefits
Detailed examination based on defined Criteria for Security,
Availability, Confidentiality, Processing Integrity, and/ or
Privacy
 Report includes a brief system description
 Report includes management’s assertion regarding controls
Where subservice providers are used,
management may include its monitoring controls
over of those operations.
Unique
benefits
SOC 2 is more flexible than SOC 3 for the service provider
in that it permits carve out of supporting services provided by
subservice providers.
SOC 2 includes detail on the service provider’s controls as
well as the auditor’s detailed test procedures, and test
results, enabling the reader of the report to assess the
service provider at a more granular level.
SOC 3 provides an overall conclusion on whether
the service provider achieved the stated Trust
Services Criteria, and the user does not need to
digest pages of detailed control descriptions, and
test procedures.
If the service provider meets all of the Criteria, it
may choose to display the SOC 3 seal on its Web
site which links to the SOC 3 report.
Potential
drawbacks
 The user may need to obtain additional reports from
significant subservice providers to gain comfort over their
activities.
The user may not want to review the detail of the report
(controls, tests, etc.) rather than an overall conclusion.
Service providers may not be willing to share a detailed
report due to concerns regarding disclosing sensitive
information (i.e., detailed security controls).
SOC 3 does not permit carve-out of significant
subservice provider activities. If it is not feasible to
cover those activities as part of the service
provider’s audit, SOC 3 is not an available option.
If one or more of the Criteria are not met, the
service provider would not be able to display the
SOC 3 seal until the issue(s) are corrected, and
re-audited.
SOC report structure
© 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent
memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity.
All rights reserved.
14
Traditional SAS 70 SOC1 SOC 2 SOC 3
Auditor’s Opinion Auditor’s Opinion Auditor’s Opinion Auditor’s Opinion
- Management Assertion Management Assertion Management Assertion
System Description
(including controls)
System Description
(including controls)
System Description
(including controls)
System Description
(including controls)
Control objectives Control objectives Criteria Criteria (referenced)
Control activities Control activities Control activities -
Tests of operating
effectiveness*
Tests of operating
effectiveness*
Tests of operating
effectiveness*
-
Results of tests* Results of tests* Results of tests* -
Other Information
(if applicable)
Other Information
(if applicable)
Other Information
(if applicable)
-
* Note: Applicable for Type 2 reports
Effectively Using SOC
Reports
SOC Reports for Different Scenarios
SOC1 Financial
Reporting Controls
SOC2/SOC3
Operational Controls
 Financial services
 Asset management and
custody services
 Healthcare claims
processing
 Payroll processing
 Payment processing
 Cloud ERP service
 Data center co-location
 IT systems management
 Cloud-based services
(SaaS, PaaS, IaaS)
 HR services
 Security services
 Email, collaboration
and communications
 Any service where
customers’ primary
concern is security,
availability or privacy
Security
Processing Integrity
Availability
Confidentiality
Privacy
Financial Process and Supporting
System Controls
© 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent
memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity.
All rights reserved.
16
Using SOC Reports to Streamline Vendor Questionnaire
Processing and Assist with Regulatory Compliance
© 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent
memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity.
All rights reserved.
17
 The SOC2 report can serve as a tool to:
 Answer questions that would ordinarily be included in vendor questionnaires
 Assist user organizations in addressing regulatory compliance requirements such
as those imposed by SOX-404 and Data Protection law and other local regulatory
requirements (i.e.BoG Governors’s act 2577/2006)
 As shown below, the service provider could include a mapping table in the Other
Information section of the SOC2 report showing how their controls align with
common vendor security questionnaire topics or the requirements of a specific
standard/regulation (for example, ISO 27001/27002).
SAMPLE – Relation of Service Provider’s Controls to ISO 27001/27002 Control Objectives
Service Provider has developed its controls to align with the ISO 27001/27002 control objectives. Included
below is a mapping of the ISO 27001/27002 topics to related Service Provider controls covered in this report.
ISO 27001/27002 Control Objective Topics Related Service Provider Controls
A.5.1 Information security policy 1.01.01, 1.02.01
A.6.1 Internal organization 1.03.01
A.6.2 External parties 1.02.02
… …
Our IT Attestation Methodology
The following diagram provides an overview of our ITAttestation approach. It reflects our “Manage to
Success” philosophy for first year audits.
• Define the audit scope. Select
relevant principles/criteria and
determine which systems,
processes, and groups are in
scope.
• Identify key controls that are in
place or needed to address the
audit objectives or criteria.
• Conduct interviews; review system
documentation, policies, and
procedures; and perform focused
tests to identify any significant
gaps.
• Provide recommendations to
address identified gaps.
Readiness Review
© 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent
memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity.
All rights reserved.
18
Remediation
• Conduct periodic meetings or
conference calls to review
remediation progress and answer
any questions.
• Plan the timing of the audit.
Attestation
• Provide documentation requests
and schedule interviews.
• Perform test procedures to
determine whether controls are
properly designed and operating
effectively to achieve the audit
objective or criteria.
• Issue KPMG’s examination
report.
• Provide a management report
reflecting any observations and
recommendations.
Conclusion
© 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent
memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity.
All rights reserved.
19
Service Organization
User Organization
- Provide a competitive advantage
- The SO can avoid unexpected audits
- Assist in building trust & confidence
- SOC2/3 can incorporate other publically available
frameworks such as ISO 2700x, PCI/ etc.
- Provide an independent assessment
- Assist with regulatory compliance
- Reduce the possibility of additional audit costs
- Increase audit efficiency
ISAE 3402 ISAE 3000
Q & A
Thank You
© 2013 KPMG Advisors AE, a Greek Societe Anonyme
and a member firm of the KPMG network of independent member firms
affiliated with KPMG International Cooperative ("KPMG International"), a
Swiss entity. All rights reserved.
The KPMG name, logo and "cutting through complexity" are registered
trademarks or trademarks of KPMG International Cooperative ("KPMG
International").

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SOC 2 presentation. Overview of SOC 2 assessment

  • 1. IT Attestation in the Cloud Era The need for increased assurance over outsourced operations/ controls April 2013 Symeon Kalamatianos M.Sc., CISA, CISM Senior Manager, IT Risk Consulting
  • 2. Contents © 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity. All rights reserved. 1  Introduction  SOC Assurance Reporting – Overview & Market Trends  Effectively using SOC reports  Conclusion  Q/A
  • 3. Speed to Market Improve Working Capital Reduce Invested Capital Reduce Cost of Goods Sold Reduce SG&A Cloud Impact on Business Opportunities to Leverage Commoditized Enterprise Applications and Economies of Scale Virtualized Business Models Virtualized Technology Virtualized Processes Virtualized Organization Internet-based data access & exchange © 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity. All rights reserved. 2 Internet-based access to low cost computing & applications + Cloud Environment =
  • 4. KPMG Recent Survey 68% 40% 9% 6% 10% 7% 0% 40% 28% 20% 60% 80% 100% Already using Cloud Planning to do so within next 2 years Planning to do so Planning to do so No, not at this time Not sure what the in 2-3 years in 3+ years plans are 68% Over 2/3 Are Already Using Cloud or Plan To In Next 2 Years © 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity. All rights reserved. 3
  • 5. Key Security Challenges Security has been the greatest concern surrounding Cloud Adoption at enterprises © 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity. All rights reserved. 4
  • 6. Complexity and Exposure define assurance model Employees, Private Intranet Internal External Strangers, Public Internet Proprietary, Distributed, Complex Cloud Computing Model Exposure Reliance on Internal Controls Need for Increased assurance Private Cloud Outsourced Data Center Traditional Familiar, Simple External Portal Virtual Private Cloud Public Cloud Corporate Data Center © 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity. All rights reserved. 5
  • 7. Service Organization Control Assurance Reporting – O • verview and Market Trends
  • 8. Service Organization Control (SOC) Assurance Reporting Scope/Focus Report Summary Applicability Internal Control Over Financial Reporting (ICOFR) ISAE3402 / SOC1* Detailed report for users and their auditors  Focused on financial reporting risks and controls specified by the service provider.  Most applicable when the service provider performs financial transaction processing or supports transaction processing systems. Operational Controls ISAE3000/ SOC2SM Detailed report for user organizations, their auditors, and specified parties  Focused on Trust Services Principles: - Security - Availability - Confidentiality - Processing Integrity and/or - Privacy.  Applicable to a broader variety of systems. ISAE3000 / SOC3SM** Short report that can be more generally distributed, with the option of displaying a web site seal * Sometimes also referred to as an SSAE 16, AT 801 ** Sometimes also referred to as a SysTrust, WebTrust, or Trust Services report © 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity. All rights reserved. 7
  • 9. Type 1 and Type 2 Reports © 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity. All rights reserved. 8  Point in time reports (Type 1) reports cover the suitability of design of controls as of a point in time. The Type I report is a snapshot in time.  Period of time (Type 2) reports cover the suitability of design and operating effectiveness of controls over a period of time, typically 6 or 12 months.  For example, a service organization providing a new service might start by completing an initial SOC2 Type 1 examination and then complete recurring SOC2 Type 2 examinations. Generally, when talking about a service organization control report, a Type II report is meant. A Type I report should be seen as an informative report.
  • 10. Contrasting SOC2/SOC3 and SOC1 Report Scope © 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity. All rights reserved. 9 Attribute SOC2/SOC3 SOC1 Required Focus  Operational Controls  ICOFR Defined Scope of System  Infrastructure  Software  Procedures  People  Data  Classes of transactions  Procedures for processing and reporting transactions  Accounting records of the system  Handling of significant events and conditions other than transactions  Report preparation for users  Other aspects relevant to processing and reporting user transactions Control Domains Covered  Security  Availability  Confidentiality  Processing Integrity and/or  Privacy  Transaction processing controls  Supporting IT general controls Level of Standardization  Principles selected by service provider.  Pre-defined criteria used rather than control objectives.  Control objectives defined by service provider and may vary depending on the type of service provided.
  • 11. Applicability of Trust Services Principles © 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity. All rights reserved. 10 Domain Trust Services Principle Trends Regarding Applicability Security  The system is protected against unauthorized access (both physical and logical).  Most commonly requested area of coverage.  Security criteria are also incorporated into the other principles because security controls provide a foundation for the other domains.  Applicable to all outsourced environments, particularly where enterprise users require assurance regarding the service provider’s security controls for any system, non- financial or financial. Availability  The system is available for operation and use as committed or agreed.  Second most commonly requested area of coverage, particularly where disaster recovery is provided as part of the standard service offering.  Most applicable where enterprise users require assurance regarding processes to achieve system availability SLAs as well as disaster recovery which cannot be covered as part of SOC1 reports
  • 12. Applicability of Trust Services Principles (continued) © 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity. All rights reserved. 11 Domain Trust Services Principle Trends Regarding Applicability Confidentiality  Information designated as confidential is protected as committed or agreed.  Most applicable where the user requires additional assurance regarding the service provider’s practices for protecting sensitive business information.  Applicable where a service provider is entrusted to maintain the confidentiality of an enterprise customer’s data of all types. Processing Integrity  System processing is complete, accurate, timely, and authorized.  Potentially applicable for a wide variety of non-financial and financial scenarios wherever assurance is required as to the completeness, accuracy, timeliness and authorization of system processing. Privacy  Personal information is collected, used, retained, disclosed, and destroyed in conformity with the commitments in the entity’s privacy notice and with criteria set forth in generally accepted privacy principles and regulatory frameworks.  Most applicable where the service provider interacts directly with end users and gathers their personal information.  Provides a strong mechanism for demonstrating the effectiveness of controls for a privacy program.
  • 13. SOC2/SOC3 Criteria Summary © 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity. All rights reserved. 12 Security  Security policies  Security awareness and communication  Risk assessment  Threat identification  Information classification  Logical access  Physical access  Security monitoring  Incident management  Encryption  Personnel  Systems development and maintenance  Configuration management  Change management  Monitoring / compliance Availability Confidentiality Processing Integrity Privacy  Availability policy  Backup and restoration  Environmental controls  Disaster recovery  Confidentiality policy  Confidentiality of inputs, data processing, and outputs  Information disclosures  Confidentiality of Information in systems development  System processing integrity policies  Completeness, accuracy, timeliness, and authorization of inputs, system processing, and outputs  Information tracing from source to disposition  Management  Notice  Choice and consent  Collection  Use and retention  Access  Disclosure to third parties  Quality  Monitoring and enforcement
  • 14. Contrasting the level of detail provided by SOC 2 and SOC 3 reports © 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity. All rights reserved. 13 SOC 2 SOC 3 Common benefits Detailed examination based on defined Criteria for Security, Availability, Confidentiality, Processing Integrity, and/ or Privacy  Report includes a brief system description  Report includes management’s assertion regarding controls Where subservice providers are used, management may include its monitoring controls over of those operations. Unique benefits SOC 2 is more flexible than SOC 3 for the service provider in that it permits carve out of supporting services provided by subservice providers. SOC 2 includes detail on the service provider’s controls as well as the auditor’s detailed test procedures, and test results, enabling the reader of the report to assess the service provider at a more granular level. SOC 3 provides an overall conclusion on whether the service provider achieved the stated Trust Services Criteria, and the user does not need to digest pages of detailed control descriptions, and test procedures. If the service provider meets all of the Criteria, it may choose to display the SOC 3 seal on its Web site which links to the SOC 3 report. Potential drawbacks  The user may need to obtain additional reports from significant subservice providers to gain comfort over their activities. The user may not want to review the detail of the report (controls, tests, etc.) rather than an overall conclusion. Service providers may not be willing to share a detailed report due to concerns regarding disclosing sensitive information (i.e., detailed security controls). SOC 3 does not permit carve-out of significant subservice provider activities. If it is not feasible to cover those activities as part of the service provider’s audit, SOC 3 is not an available option. If one or more of the Criteria are not met, the service provider would not be able to display the SOC 3 seal until the issue(s) are corrected, and re-audited.
  • 15. SOC report structure © 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity. All rights reserved. 14 Traditional SAS 70 SOC1 SOC 2 SOC 3 Auditor’s Opinion Auditor’s Opinion Auditor’s Opinion Auditor’s Opinion - Management Assertion Management Assertion Management Assertion System Description (including controls) System Description (including controls) System Description (including controls) System Description (including controls) Control objectives Control objectives Criteria Criteria (referenced) Control activities Control activities Control activities - Tests of operating effectiveness* Tests of operating effectiveness* Tests of operating effectiveness* - Results of tests* Results of tests* Results of tests* - Other Information (if applicable) Other Information (if applicable) Other Information (if applicable) - * Note: Applicable for Type 2 reports
  • 17. SOC Reports for Different Scenarios SOC1 Financial Reporting Controls SOC2/SOC3 Operational Controls  Financial services  Asset management and custody services  Healthcare claims processing  Payroll processing  Payment processing  Cloud ERP service  Data center co-location  IT systems management  Cloud-based services (SaaS, PaaS, IaaS)  HR services  Security services  Email, collaboration and communications  Any service where customers’ primary concern is security, availability or privacy Security Processing Integrity Availability Confidentiality Privacy Financial Process and Supporting System Controls © 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity. All rights reserved. 16
  • 18. Using SOC Reports to Streamline Vendor Questionnaire Processing and Assist with Regulatory Compliance © 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity. All rights reserved. 17  The SOC2 report can serve as a tool to:  Answer questions that would ordinarily be included in vendor questionnaires  Assist user organizations in addressing regulatory compliance requirements such as those imposed by SOX-404 and Data Protection law and other local regulatory requirements (i.e.BoG Governors’s act 2577/2006)  As shown below, the service provider could include a mapping table in the Other Information section of the SOC2 report showing how their controls align with common vendor security questionnaire topics or the requirements of a specific standard/regulation (for example, ISO 27001/27002). SAMPLE – Relation of Service Provider’s Controls to ISO 27001/27002 Control Objectives Service Provider has developed its controls to align with the ISO 27001/27002 control objectives. Included below is a mapping of the ISO 27001/27002 topics to related Service Provider controls covered in this report. ISO 27001/27002 Control Objective Topics Related Service Provider Controls A.5.1 Information security policy 1.01.01, 1.02.01 A.6.1 Internal organization 1.03.01 A.6.2 External parties 1.02.02 … …
  • 19. Our IT Attestation Methodology The following diagram provides an overview of our ITAttestation approach. It reflects our “Manage to Success” philosophy for first year audits. • Define the audit scope. Select relevant principles/criteria and determine which systems, processes, and groups are in scope. • Identify key controls that are in place or needed to address the audit objectives or criteria. • Conduct interviews; review system documentation, policies, and procedures; and perform focused tests to identify any significant gaps. • Provide recommendations to address identified gaps. Readiness Review © 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity. All rights reserved. 18 Remediation • Conduct periodic meetings or conference calls to review remediation progress and answer any questions. • Plan the timing of the audit. Attestation • Provide documentation requests and schedule interviews. • Perform test procedures to determine whether controls are properly designed and operating effectively to achieve the audit objective or criteria. • Issue KPMG’s examination report. • Provide a management report reflecting any observations and recommendations.
  • 20. Conclusion © 2013 KPMG AdvisorsAE, a Greek Societe Anonyme and a memberfirmof the KPMG network of independent memberfirmsaffiliatedwith KPMG InternationalCooperative("KPMG International"),a Swiss entity. All rights reserved. 19 Service Organization User Organization - Provide a competitive advantage - The SO can avoid unexpected audits - Assist in building trust & confidence - SOC2/3 can incorporate other publically available frameworks such as ISO 2700x, PCI/ etc. - Provide an independent assessment - Assist with regulatory compliance - Reduce the possibility of additional audit costs - Increase audit efficiency ISAE 3402 ISAE 3000
  • 21. Q & A
  • 22. Thank You © 2013 KPMG Advisors AE, a Greek Societe Anonyme and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative ("KPMG International"), a Swiss entity. All rights reserved. The KPMG name, logo and "cutting through complexity" are registered trademarks or trademarks of KPMG International Cooperative ("KPMG International").