In a nutshell, the Risk Based Planning Assessment control is all about making sure that audits and assurance checks are done based on a well thought out plan that takes into account the risks facing the organization. It's kind of like making a game plan before heading into battle.

Where did this come from?

CSA Cloud Controls Matrix v4.0.10 - 2023-09-26. You can download the full document here. This control was inspired by industry standards like COSO and ISO 31000 which provide guidance on risk management and planning.

Who should care?

• Audit managers with responsibility for planning and executing audits
• Compliance officers needing to ensure assessments cover key risks
• CISOs and security leaders overseeing the organization's risk posture

What is the risk?

Without a risk-based audit plan, there's a good chance that:

• High risk areas may be overlooked, leaving the org exposed
• Audits may focus on the wrong things and waste time/resources
• Assessments won't be tailored to the org's specific risk profile

This control helps avoid those issues by ensuring audits are planned strategically based on risk. It increases the likelihood that the most critical risks will be addressed.

What's the care factor?

For organizations operating in the cloud, this should be a high priority control. Cloud environments introduce unique risks that need to be factored into audit planning. A generic, one-size-fits-all approach won't cut it.

Taking the time upfront to develop a thoughtful, risk-based plan will pay dividends in terms of more effective, efficient audits that provide real assurance over the risks that matter most.

When is it relevant?

This control applies any time an organization is conducting internal audits or engaging external parties for assurance work. It's especially important for:

• Organizations with complex, multi-cloud environments
• Highly regulated industries like finance and healthcare
• Companies with valuable data/IP to protect

On the flip side, it may be overkill for a small startup with a simple architecture and few compliance demands. But in general, most orgs can benefit from taking a risk-based approach to audit planning.

What are the trade offs?

Developing a risk-based plan takes time and effort. It requires:

• Thorough risk assessments to identify key risks
• Collaboration between audit, security, and business teams
• Ongoing monitoring of the risk landscape to stay current

There's also a learning curve for auditors used to a more checklist-based approach. And there may be pushback from stakeholders who are used to audits covering certain areas, even if they're low risk.

But while there are upfront costs, they're outweighed by the long-term benefits of more targeted, value-added assurance.

How to make it happen?

1. Assign ownership of the risk-based audit planning process to a senior leader, ideally in the audit function
2. Conduct a comprehensive risk assessment covering the entire org. Partner with security and business teams for input
3. Prioritize risks based on likelihood and impact. Use a risk rating scale (e.g. high, medium, low)
4. Determine audit frequency for each risk area based on the rating. Higher risks warrant more frequent audits
5. Define the audit scope and objectives for each area, focusing on the key controls that mitigate the risks
6. Develop a multi-year audit plan outlining the schedule and resource requirements. Get sign-off from leadership
7. Assign audits to qualified staff and provide training on the risk-based approach
8. Execute audits according to the plan, using data analysis to zero in on risk areas
9. Report findings to stakeholders and track remediation. Escalate high risks promptly
10. Refresh the risk assessment and audit plan annually or as major changes occur (e.g. new cloud services)

What are some gotchas?

• The risk assessment must cover all in-scope systems and services. Partner closely with IT and security for a complete inventory
• Risks should be defined specifically. Vague risks like "data security" are hard to audit against
• Audit teams need a mix of business and technical skills to assess risks and controls effectively. Co-sourcing or outsourcing may be needed to fill gaps
• Audits should use a mix of manual testing and data analysis for maximum assurance. Relying too heavily on either is a red flag
• The audit plan and risk assessment should be formally reviewed and approved by leadership. No rubber stamps

What are the alternatives?

Some organizations take a cyclical approach, auditing all areas on a fixed schedule regardless of risk. Others use a purely controls-based approach, testing a standard set of controls each audit.

While these methods are simpler, they're less effective at addressing the dynamic nature of risk in a cloud environment. A hybrid approach incorporating both cyclical and risk-based audits may be a happy medium for some.

Explore further

• COSO Enterprise Risk Management Framework - Guidance on risk management practices
• ISO 31000 Risk Management Guidelines - Standards for risk management
• CIS Control 13: Audit Log Management - Guidance on audit logging practices to support risk-based audits
• AWS Cloud Audit Academy - Training for auditing AWS environments

Ultimately, taking a thoughtful, risk-based approach to audit planning is key to getting the most assurance bang for your buck. By focusing on what matters most, you can up your cloud security game without breaking the bank.