Conducting independent audit and assurance assessments at least annually is a critical security practice for organizations. These assessments should adhere to relevant standards and be free from conflicts of interest or undue influence. Regular independent assessments help ensure an organization's security controls are effective and compliant.

Where did this come from?

This control comes from the CSA Cloud Controls Matrix v4.0.10 - 2023-09-26. You can download the full matrix here. The CCM provides a comprehensive set of cloud security controls mapped to various standards and regulations. For more background, check out the CSA CCM Overview.

Who should care?

• CISOs and security leaders responsible for ensuring the organization's security posture
• Compliance officers needing to demonstrate adherence to standards and regulations
• IT auditors tasked with performing independent security assessments
• Risk managers looking to identify and mitigate security risks

What is the risk?

Without regular independent assessments, an organization may have ineffective or non-compliant security controls, leading to:

• Data breaches due to unidentified vulnerabilities
• Regulatory fines and legal liability from non-compliance
• Reputational damage if security incidents become public
• Operational disruption from security-related outages

Independent assessments significantly help manage these risks by proactively identifying issues and providing assurance that controls are appropriate.

What's the care factor?

For most organizations, independent assessments should be considered a high priority. They are often required by regulations, customer contracts, and cyber insurance policies. Even when not strictly mandated, the risks of skipping assessments are too high for the modest cost savings.

Highly security-sensitive organizations like financial institutions, healthcare providers, and critical infrastructure should treat this as an absolute must-have. Smaller, lower-risk organizations can potentially do longer intervals between assessments if budgets are tight.

When is it relevant?

Annual independent assessments are relevant for nearly any organization that relies on IT and faces some level of security risk or compliance requirements. They are especially critical for:

• Highly-regulated industries like finance and healthcare
• Organizations handling sensitive data like PII, PHI, or PCI
• Cloud-hosted systems and applications
• Organizations subject to standards like ISO 27001, SOC 2, etc.

Assessments may be less relevant for small organizations with minimal IT footprint and low inherent risk. But for most, they are essential.

What are the trade-offs?

Cons:

• Assessments have a financial cost, both for auditor fees and internal prep time
• Significant effort is required from IT and security teams to support assessments
• Identified issues create remediation work that can impede other priorities

Pros:

• Proactively surface and address security weaknesses and avoid major incidents
• Provide confidence to customers and stakeholders that security is taken seriously
• Maintain good standing with regulators and cyber insurance providers
• Gain expert external perspective on potential improvements to the security program

How to make it happen?

1. Determine applicable regulations, standards, and other requirements for assessments
2. Get buy-in and budget approval from senior leadership
3. Begin a vendor selection process to identify a qualified independent assessor
   • Look for firms with relevant certifications like CPA or CISSP
   • Ensure no conflicts of interest with the firm providing other services
4. Define the assessment scope - systems, controls, standards to be tested
5. Prepare evidence package and provide access and documentation to auditors
6. Facilitate interviews and any other information gathering by auditors
7. Review draft assessment report and provide management responses to findings
8. Remediate findings and develop go-forward improvement plan based on recommendations
9. Finalize and share assessment report with relevant stakeholders
10. Use results to inform next year's security planning and audit preparation

What are some gotchas?

• Insufficient prep and immature controls can lead to many unfavorable findings
• Auditors require documentation evidence, not just verbal discussion, slowing the process
• Access to sensitive systems and data must be provided without compromising security
• Findings may uncover sensitive issues that need delicate communication
• Scoping the assessment too narrowly undermines the value and assurance provided

What are the alternatives?

Some alternatives and complements to independent assessments:

• Internal self-assessments against a standard or framework like the CCM
• Automated security scanning and testing tools
• Bug bounty programs to crowdsource discovery of vulnerabilities
• Formal certifications like ISO 27001 or SOC 2

But none of these fully replace a thorough independent expert assessment.

Explore further

• PCI DSS Requirement 11.3 mandates annual penetration testing
• HIPAA Audit Protocol details requirements for HIPAA covered entities
• CIS Control 18 provides further guidance on pen testing as part of assessments