Sensiba LLP, a Top 75 U.S. accounting and advisory firm, and leader in cybersecurity and compliance services, announced today the launch of its new Penetration Testing service. With this addition, Sensiba provides and end-to-end security framework to help organizations identify vulnerabilities, safeguard their operations, and strengthen their cyber resilience.

This offering expands and complements the firm’s robust portfolio, which already includes ISO 27001, SOC, HIPAA, and NIST, and is mandated for others such as FedRAMP, HITRUST, PCI.

Penetration Testing will allow clients to proactively identify vulnerabilities within their systems, networks, and applications before bad actors can exploit them. By simulating real-world attack scenarios, Sensiba will offer deep insights into potential threats and deliver actionable recommendations to address security gaps. 

This strategic launch underscores Sensiba’s ongoing commitment to supporting CTOs and IT leaders, with highly adaptable, scalable, and comprehensive solutions to meet the complex security needs of today’s businesses.

“With the addition of penetration testing to our cybersecurity service portfolio, we’re ensuring our clients can stay one step ahead of potential vulnerabilities and risks. In addition, this offering allows our current clients and prospects to consolidate their security needs with Sensiba, streamlining the process for compliance audits such as SOC, ISO, and HIPAA,” says Brian Beal, Risk Assurance Services Partner. “By offering this service, we’re helping clients strengthen their security posture while simplifying risk management and improving overall efficiency.”

Determining In-Scope Headcount for Your ISO 27001 Audit 

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Determining the in-scope headcount for your ISO 27001 Information Security Management System (ISMS) is an essential step in preparing for certification. Your headcount reflects the number of people directly involved in performing the processes covered by your ISMS, and its accuracy influences the required audit time and overall management of the ISMS.  

Ensuring this headcount is well-defined and comprehensive will streamline your audit, help your certification body adequately budget time for the audit process, and support the successful implementation of security measures aligned with your business operations. 

What Is In-Scope Headcount? 

The term “in-scope headcount” refers to the employees and contractors directly involved in performing the activities governed by your ISMS. This includes people across various departments who contribute to the development, maintenance, and security of the systems, processes, or services within the defined scope.  

For example, if your ISMS covers the development and operation of a Software-as-a-Service (SaaS) application, your in-scope headcount would include developers, DevOps engineers, system administrators, and, depending on how they interact with the development process, potentially corporate IT. 

Key Considerations for Determining Headcount 

When identifying your in-scope headcount, consider these critical factors: 

  • Processes Involved: Identify all processes that are part of your ISMS. For a SaaS platform, this might include software development, system operation, and incident response management. 
  • Dependencies Between Departments: Consider how different departments interact. For example, while development may be the primary process, corporate IT may also fall under the ISMS if their activities support or influence development. 
  • Third-Party Involvement: If external partners or vendors play a role in your information security processes, include them where relevant. 
  • Workforce Structure: Include full-time, part-time, and contract workers who contribute to ISMS activities. Even part-time workers should be accounted for, based proportionally on their contribution to relevant tasks. 

5 Steps to Define Your In-Scope Headcount 

Step 1: Identify Core ISMS Processes 

Start by identifying the processes that fall under your ISMS. For example, if your ISMS covers a SaaS platform, you would include software development, operations, and maintenance. Focus on the roles directly involved in these processes. 

Step 2: List Departments Involved 

Once the core processes are defined, determine which departments or teams are responsible for these activities.

Step 3: Map Dependencies 

Evaluate the dependencies between departments. For example, if corporate IT provides critical support for the SaaS platform’s security or infrastructure, they should be included in the in-scope headcount and noted within the scope statement interfaces and dependencies. 

Step 4: Include External Parties 

If any external contractors, consultants, or service providers are responsible for aspects of the ISMS processes (e.g., outsourced security monitoring), be sure they are accounted for in the headcount. 

Step 5: Determine Your In-Scope Headcount 

While it’s not a requirement of the standard to document your headcount formally, you should have a clear number in mind to provide your certification body. This headcount is essential for helping them accurately determine the number of days required for the audit and ensuring that all critical components of your ISMS are covered. 

Common Pitfalls to Avoid When Determining In-Scope Headcount 

  • Underestimating Third-Party Involvement: Forgetting to include external vendors or consultants can lead to incomplete ISMS coverage. 
  • Excluding Support Teams: Teams such as IT or HR may not appear directly linked to your ISMS at first glance, but they often provide crucial support, especially in areas like security or access management. 
  • Overcomplicating the Headcount: Including roles that don’t impact the ISMS directly can inflate the headcount unnecessarily, leading to longer audits and higher costs. 

Who Can Be Excluded From Your ISMS Headcount 

In many cases, departments like sales, marketing, or customer service may have little to no impact on the ISMS and can often be excluded from the headcount. These departments typically do not handle sensitive information or perform activities that fall within the ISMS’s security scope. However, it’s important to assess each department based on their involvement with information security to ensure there are no overlooked risks. 

While it’s common to exclude non-relevant departments, some organizations choose to include the entire company within the ISMS scope. If you decide to include all departments, including those with minimal information security involvement, there are options to reduce the audit days based on the reduced risk associated with certain activities.  

In these cases, you should speak with your certification body to explore opportunities for reducing audit time while ensuring the ISMS remains effective and compliant. 

The Role of Cross-Departmental Teams 

In many cases, multiple departments contribute to the activities under your ISMS. Involving cross-departmental teams during the headcount determination process ensures no critical roles are overlooked.  

Collaboration across departments can also help identify any indirect roles that contribute to maintaining the security of information assets or systems. By involving stakeholders from different areas, such as HR, IT, and legal, you ensure a more comprehensive view of who should be included in the ISMS scope. 

By carefully identifying the personnel involved, whether selectively or company-wide, and documenting their roles clearly, you can optimize the audit process and align your ISMS with both business and security objectives. 

If you have questions about defining your ISO audit scope or need assistance with your compliance efforts, we’re here to help.  

ISO/IEC 27001 Updated for Climate Change Risks

With climate considerations playing a larger role in corporate risk management and strategic planning, the ISO/IEC 27001 cybersecurity standard has been updated to include the potential impacts of climate change on an organization’s Information Security Management Systems (ISMS).

Under an amendment issued in February 2024, organizations preparing for an ISO/IEC 27001 audit are required to consider the potential risks climate change can present to their ISMS, as well as any potential implications for interested parties.

In a joint statement, ISO and the International Accreditation Forum highlighted the need for organizations to consider the effects of climate change on their ability to achieve the intended results of the management system.

The statement explained that some climate-related risks, such as regulatory compliance or organizational resilience, may have a general effect on an organization’s ISMS. Some organizations will face more specific climate-related ISMS risks related to their industry (such as energy production or agriculture) or factors such as their geographic location.

How Does ISO/IEC 27001 Address Climate Change?

The ISO/IEC 27001 standard adds two references to climate change within Clause 4, “Context of the Organization.” Clause 4.1 (Understanding the Organisation and its Context) adds a sentence reading “The organisation shall determine whether climate change is a relevant issue.” Clause 4.2 (Understanding the Needs and Expectations of Interested Parties) adds the sentence “Relevant interested parties can have requirements related to climate change.”

The changes are designed to help organizations address several climate-related risks to their ISMS and its operations. If, for instance, a severe weather event such as a windstorm or flooding affects an organization’s data center, the availability of its systems and data can be disrupted.

Similarly, vendor or supply chain disruptions following climate-related events could affect an organization’s ability to maintain an ISMS and its performance. Customers may also have concerns about whether a climate-related disruption to a service organization can affect their operations.

How Should Companies Alter Risk Assessments?

To comply with the revised standard, organizations need to consider whether climate change can affect their ISMS, and whether they’ve implemented controls or other measures to address climate-related risks. For many organizations without material climate exposures, this can be addressed with language similar to:

“The organization acknowledges the potential impact of climate change on its operations and has considered these risks in the context of its Information Security Management System (ISMS). While no specific mitigation actions are committed at this stage, the organization remains aware of climate-related factors that may affect its business environment.”

Similarly, organizations should also consider addressing climate risk with policy statements in their Management System’s risk assessment documentation. Management should include language saying it has considered the impact of climate risk on the ISMS and whether that risk meets a threshold for mitigation. (If it does, the organization should outline the mitigation measures it has taken.)

If an organization has more than one ISO/IEC Management System, it needs to conduct separate climate risk assessments for each one.

To learn more about ISO 27001 certification and its valuable role in helping your organization protect its systems and information, contact us.

ISO/IEC 27701 vs. 27018: Privacy Data Protection Standards

Organizations must handle personally identifiable information (PII) data responsibly within their networks and cloud services to maintain trust with customers and business partners, while complying with an expanding array of state and international laws and regulations.

The ISO/IEC 27701 and ISO/IEC 27018 standards provide valuable guidance in helping organizations improve privacy data security and regulatory compliance—and build trust and credibility with customers and prospects—by aligning their data-protection policies, procedures, and controls with recognized global frameworks.

What Is ISO/IEC 27701?

The ISO/IEC 27701 standard guides organizations on managing personal information securely. The standard extends ISO/IEC 27001, which focuses on general information security, by adding specific requirements for handling personal data. 

ISO/IEC 27701, applicable to any entity that processes or controls personal information, builds on the extensive security practices outlined in ISO/IEC 27001 by focusing on privacy management that provides guidance on handling personal data responsibly.

What Is ISO/IEC 27018?

The ISO/IEC 27018 standard, which provides guidelines for protecting personal data in cloud services, is designed for cloud service providers who process data on behalf of others. This standard helps ensure that personal information stored or processed in the cloud is secure.

By ensuring data privacy in cloud services, complying with the standard helps providers build trust and confidence with customers and prospects.

Similarities Between ISO/IEC 27701 and ISO/IEC 27018

Both standards offer strong data protection guidance designed to help companies secure personal information against unauthorized access, alteration, theft, or destruction. Organizations that are certified against 27701, or in compliance with 27018, demonstrate compliance with legal and regulatory requirements for maintaining information security and customer privacy, as well as an ongoing commitment to safeguarding the data they’ve been entrusted to process and store.

Both standards are based on ISO/IEC 27001 and use that general information security framework as a foundation.

How Are ISO/IEC 27701 and ISO/IEC 27018 Different?

The two standards differ in the scope of their application. ISO/ICE 27701, for instance, is a certifiable standard. With ISO/IEC 27018, auditors are evaluating the organization’s compliance with the standard.

ISO/IEC 27701 applies broadly to any organization handling personal data, including data controllers and processors. This can include any organization, regardless of its industry or size, that wants to approach information security management systematically. The standard’s framework can be adapted to the specific needs of each organization seeking certification.

In contrast, ISO/IEC 27108 applies specifically to organizations that process PII in public cloud environments. These can be cloud service providers that process PII on behalf of their customers or provide support services for cloud service providers.

It can also be applicable to organizations that handle personal data in cloud environments, such as companies that develop or provide security software or services to protect PII in the cloud.

The standards also have a different regulatory alignment. ISO/IEC 27701 is aligned with several global privacy regulations, offering a comprehensive framework.

By providing guidelines for protecting PII, 27701 aligns with several global privacy regulations, including the EU’s General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other regional privacy laws.

Most acts share broad principles such as mandating data protection and privacy controls, restrictions on data use or sharing without consumer consent, transparency in data processing, and similar provisions.

The standards also differ in their timing. Including ISO/IEC 27018 essentially adds one additional day to an in-progress ISO/IEC 27001 audit. A 27701 certification can add from 2.5 days to 50% additional time to their 27001 audit if the organization under review is a processor and controller of PII.

Which Standard Is Right for You?

Both ISO/IEC 27701 and ISO/IEC 27018 are important for protecting personal information, but they serve different purposes. ISO/IEC 27701 offers a broad framework for privacy management that’s suitable for any organization. ISO/IEC 27018 provides specific guidance for cloud service providers to protect data in the cloud.

Choose ISO/IEC 27701 if:Choose ISO/IEC 27018 if:
You want a comprehensive approach to privacy management. You’re a cloud service provider focusing on data protection in the cloud.
Your organization processes personal data in multiple contexts.You want to assure customers about the security of their data in your cloud services.
You aim to integrate privacy practices into your overall security management. Building trust and transparency with clients is a priority.

Understanding your organization’s needs, along with customer and regulatory expectations, will help you choose the right standard to enhance your data protection efforts.

Contact us to learn more about ISO/IEC 27701 and 27018.

ISO/IEC 27001:2022 Readiness Checklist

A successful ISO/IEC 27001 certification starts with careful preparation, policy creation, and documentation. Our detailed readiness checklist breaks down the audit process to help you develop a comprehensive plan.

Key Highlights of Our Readiness Checklist

  • An overview of the ISO/IEC 27001 standard
  • A typical certification timeline
  • Descriptions of the standard’s clauses and controls
  • Insights to increase efficiency and reduce interruptions
  • Common mistakes to avoid

Understanding AI Roles to Promote ISO 42001 Compliance

As artificial intelligence (AI) continues to transform industries, understanding the roles within the AI lifecycle— production, development, provision, and use—is crucial for organizations involved in AI development, deployment, and usage to manage risk effectively and obtain ISO/IEC 42001 certification.

These roles are defined in the ISO/IEC 42001 and ISO/IEC 22989 standards, which offer a clear breakdown of the key responsibilities within the AI ecosystem. By adopting ISO compliance, organizations can demonstrate their commitment to responsible AI development and usage. This can enhance trust with stakeholders, mitigate risks, and improve overall performance.

Each role is distinct, so it is important to understand their contributions and responsibilities to ensure the creation, implementation, and application of AI systems meet the organization’s goals while maintaining high standards of reliability and performance.

What Is ISO 42001?

The ISO 42001 standard provides guidance for successful development and use of an Artificial Intelligence Management System (AIMS), including creating and documenting effective policies, processes, and controls. An ISO 42001 certification audit will examine several areas, including AI-specific ethical, security, and operational considerations, system lifecycle management, performance optimization, documentation, and others.

To achieve ISO/IEC 42001 certification, an organization needs to be able to define their role within the AI ecosystem. An organization can perform more than one of the roles listed below.

AI Producer

An AI producer is an organization or entity responsible for designing, developing, testing, and deploying products or services that use one or more AI systems. This role involves the full lifecycle of AI creation, from conceptualizing the AI model to putting it into practical use in real-world applications. AI producers are critical in ensuring AI systems are not only functional, but also meet specified performance and ethical guidelines.

AI Provider

An AI provider focuses on enabling access to AI technologies for other organizations, either by offering AI platforms or delivering specific AI services or products. This role is essential for making AI technologies widely available and supporting stakeholders in building, deploying, and using AI.

Sub-roles include:

  • AI platform provider: Provides the infrastructure or services necessary for other organizations to produce AI services or products. This role is critical for organizations that need the tools and platforms to develop their own AI solutions but do not build the infrastructure themselves. For example, cloud-based AI platforms provide development environments for companies to create AI models and applications.
  • AI service/product provider: Delivers AI services or products directly to customers or users, either as standalone AI solutions or as part of a larger system. This provider ensures AI solutions are ready for deployment and use, offering technologies that are either pre-packaged or customizable for specific client needs.

AI User

An AI user is any organization or entity that uses AI products or services, either directly or as part of its operations. AI users leverage AI to automate processes, gain insights, improve decision-making, or enhance products and services. This role encompasses a wide range of activities, from companies using AI-driven software for internal operations to those deploying AI in customer-facing solutions.

AI users rely on the outputs of AI systems, without necessarily being involved in the technical development of those systems. They focus on applying AI tools and services to improve organizational efficiency, product quality, or service delivery. In doing so, they play a crucial role in realizing the benefits of AI technologies across various industries.

Defining the AI Lifecycle Roles

Understanding the specific roles within the AI lifecycle is vital for organizations involved in any part of AI development, provision, or use. The AI producer designs and deploys AI models, with the AI developer playing a key role in implementing and verifying these models. The AI provider enables access to AI services and platforms, while the AI user applies these technologies to achieve operational and business goals.

AI Lifestyle Roles

By defining these roles clearly, organizations can collaborate, allocate resources, and streamline their AI strategies more effectively and facilitate ISO 42001 compliance. Whether building an AI model, offering AI services, or using AI solutions, each role is essential to the broader AI ecosystem.

With AI continuing to evolve, the distinctions between these roles will help organizations manage their AI initiatives more effectively, ensuring that AI technologies are developed, delivered, and applied in ways that maximize their potential impact.

To learn more about ISO compliance within AI applications, contact us.

How to Define Your ISO 27001 Scope (and Write Your Scope Statement)

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Defining the scope of your ISO 27001 Information Security Management System (ISMS) or Privacy Information Management System (PIMS) is a crucial early step for certification. The scope sets the boundaries of what your audit will cover, ensuring your most valuable information and processes are protected and aligned with your business goals.

After defining your scope, the next step is creating a scope statement—a concise declaration that will appear on your certification certificate. This statement outlines the specific boundaries within which your ISMS or PIMS operates and publicly affirms your commitment to information and privacy security.

What Is the Audit Scope?

Your audit scope defines the parts of your organization, processes, locations, and information assets included in your ISMS or PIMS. This scope must be clear and aligned with your business objectives to ensure your ISMS/PIMS is operating ethically and is effective in protecting your critical information.

A well-defined scope helps your organization focus its efforts where they matter most and makes the certification process smoother by preventing unnecessary complexity.

Key Considerations When Defining the Scope

When defining your audit scope, consider these key factors:

  • Organizational context: Align the scope with your objectives, external obligations, and critical processes, ensuring regulatory compliance.
  • Locations: Identify all locations where sensitive information is handled or AI development takes place. This usually includes offices, data centers, and third-party sites.
  • Information assets: Determine which assets, such as databases, software, and documents, need protection under your ISMS or are part of your PIMS.
  • Processes: Define crucial processes for information and privacy security, from HR handling data to IT managing storage and transmission.
  • Third-party relationships: Include any suppliers, vendors, or partners who access or manage your information assets.

5 Steps to Define the Audit Scope

Step 1: Analyze Your Organizational Context

Understand the business objectives, stakeholders, and legal requirements that may impact your information security or PIMS.

Step 2: Identify Critical Assets and Processes

List key digital and physical assets, as well as processes vital to your operations. Focus on what needs protection.

Step 3: Define Boundaries

Clearly outline the geographical and operational boundaries of your ISMS or PIMS. Specify which departments or locations are covered.

Step 4: Consider External Parties

Assess third-party relationships. Include any vendors or service providers that may impact your information security or PII.

Step 5: Document Your Scope

Write a clear document covering all locations, processes, and assets within your ISMS and PIMS. This will form the basis for your scope statement.

How to Write Your Scope Statement

Once you’ve defined your scope, it’s time to write your scope statement. This statement, which will appear on your certificate, is a public declaration of what is covered by your ISMS or PIMS. It should be clear and concise and reflect the boundaries you’ve established.

ISO 27001 Scope Statement Template

The scope of certification encompasses the Information Security Management System (ISMS) governing [insert key processes, services, or products covered by the ISMS, e.g., the organization’s SaaS application]. This includes [list key activities or departments involved, e.g., the design, development, deployment, and maintenance of the application]. The organization [insert operational details, e.g., operates entirely remotely / has operations across multiple sites / includes specific locations], with [insert any relevant details about physical locations, e.g., a designated mailing address used solely for correspondence purposes].

This certification aligns with ISO 27001 standards and is based on the Statement of Applicability (SoA) [insert version number and date, if desired—e.g., version 1.1 dated March 25, 2024].

Instructions for Completing the Scope Statement Template

Key Processes, Services, or Products:

Clearly state what the ISMS governs. This might include specific products (e.g., a SaaS application), services (e.g., managed IT services), or general operations (e.g., data processing).

Activities or Departments Involved:

List the activities or departments included in the scope. This could involve the design, development, maintenance, operations, support, or other relevant activities tied to information security.

Operational Details:

Specify whether your organization operates remotely, across multiple sites, or in specific locations. If the organization is remote, mention any physical mailing addresses and clarify if these are not operational locations.

Statement of Applicability (SoA) (Optional):

Including the SoA version and date is common but optional. If included, mention the version and date of the SoA your certification is based on.

Sample Scope Statements

Sample Scope Statement for ISO 27001 (ISMS) with locations

The scope of certification encompasses the Information Security Management System (ISMS) governing the organization’s “SecureVault 360” cloud-based data security and storage solution. This includes the development, operation, and customer support processes involved in managing the “SecureVault 360” platform. The organization operates across three sites in the United States and Europe, with the headquarters located in Austin, Texas. This certification aligns with ISO 27001 standards and is based on the Statement of Applicability (SoA) version 2.0 dated January 10, 2024.

Sample Scope Statement for ISO 27001 (ISMS) for a Remote Organization

The scope of certification encompasses the Information Security Management System (ISMS) governing the organization’s “SecureVault 360” cloud-based software development services. This includes the design, development, deployment, and support processes related to the “SecureVault 360” platform. The organization operates entirely remotely, with no physical office locations. The designated mailing address in New York, NY, United States, is used solely for correspondence purposes. This certification aligns with ISO 27001 standards and is based on the Statement of Applicability (SoA) version 3.0 dated April 1, 2024.

ISO 27701 Privacy Information Management System (PIMS) Scope Statement Samples

In addition to the ISO 27001 scope statement examples, it’s also useful to explore how organizations can define their scope under ISO 27701. As an extension to ISO 27001, ISO 27701 focuses specifically on privacy management for organizations acting as data controllers, processors, or both. Below, you’ll find sample scope statements for ISO 27701 to help you navigate this area effectively.

ISO 27701 (PIMS) Scope Statement Template

The scope of certification encompasses the Privacy Information Management System (PIMS) governing [insert key processes, services, or products covered by the PIMS, e.g., the organization’s data processing and privacy management operations]. This includes [list key activities or departments involved, e.g., the collection, processing, storage, and management of personal data]. The organization [insert operational details, e.g., operates entirely remotely / has operations across multiple sites / includes specific locations] and functions as a [declare whether the organization is a data controller, processor, or both]. This certification aligns with ISO 27701 standards and is based on the Statement of Applicability (SoA) [insert version number and date, if desired—e.g., version 1.1 dated March 25, 2024].

Sample Scope Statement for ISO 27701 (PIMS)

The scope of certification encompasses the Privacy Information Management System (PIMS) governing the organization’s customer data management services for “SecureVault 360,” a cloud-based data security and storage solution. This includes the collection, processing, storage, and deletion of personal data related to the “SecureVault 360” platform. The organization operates as both a data controller and data processor, with operations across three sites in the United States and Europe, including headquarters in Austin, Texas. This certification aligns with ISO 27701 standards and is based on the Statement of Applicability (SoA) version 2.0 dated January 10, 2024.

This template provides a flexible structure that can be customized to fit various organizational contexts and will help in crafting a clear and comprehensive ISO 27001 or ISO 27701 scope statement.

Common Pitfalls to Avoid When Defining Your Scope

When defining your scope, watch out for these pitfalls:

  • Overly broad scope: Including too much information can make your ISMS or PIMS hard to manage and audit. Focus on critical areas aligned with your business goals.
  • Too narrow scope: Excluding key processes or locations can expose your organization to risks. Cover all essential areas.
  • Vague language: Be clear and precise. Avoid vague terms that could create confusion about what your ISMS or PIMS covers.

The Role of Stakeholders

Defining your ISO 27001 or 27701 scope and writing your scope statement shouldn’t be done in isolation. Involve key stakeholders, including senior management, IT teams, legal advisors, and department heads. Collaboration ensures the scope is comprehensive, realistic, and aligned with your organization’s goals.

Defining your audit scope and writing a clear scope statement are key steps toward certification. By understanding your organization’s context, identifying key assets and processes, and involving stakeholders, you can create a scope that aligns with your business objectives and protects valuable information.

This article offers a proven approach to help you get started, but every organization is unique. Be sure to explore additional resources or seek professional advice to tailor your scope statement to your specific needs.

Streamlining ISO 27001 With a Virtual Audit

Lucidworks turned to Sensiba and Drata for a smoother, more efficient recertification.

Lucidworks powers the search and discovery experience for the world’s largest and most successful companies. Lucidworks’ solutions personalize the search and discovery experience to reveal actionable insights
about user intent and rapidly deliver them to the relevant channels of engagement. Customers rely on Lucidworks’ products to power commerce, customer service, and
workplace applications that delight customers and empower employees.

  • ISO 27001 Recertification Audit
  • SOC 2 Type II Audit

Challenge

Following a less than ideal situation with an ISO 27001 auditor that relied on manual processes and communication, AI-powered search and product discovery software provider Lucidworks turned to Sensiba for a smoother, more efficient audit to provide its ISO 27001 recertification.

Lesley Heizman, Manager of Risk & Compliance, says Lucidworks’ previous audit firm didn’t offer a modern virtual audit option, instead relying on voice calls and swapping audit files via email. The firm did not communicate outside of the audit, and the Lucidworks team didn’t feel comfortable asking questions about the process.

Overall, the firm was a poor cultural fit with a vibrant Bay Area tech startup like Lucidworks.

“Working with a company of a similar size and that offered startup experience was important to us. We were comfortable the Sensiba team was open to our questions, and they were very responsive.”

Lesley HeizmanManager of Risk & Compliance, Lucidworks
Lucidworks 1

Solution

To streamline the audit process, Lucidworks implemented the Drata GRC compliance platform to map its controls and automate audit documentation. Drata, in turn, recommended four potential audit firms and Sensiba quickly stood out.

“Working with a company of a similar size and that offered startup experience was important to us,” Heizman says. “We were comfortable the Sensiba team was open to our questions, and they were very responsive.”

Lucidworks also appreciated Sensiba’s virtual audit methodology. For instance, the Sensiba and Lucidworks teams leveraged the Drata platform to exchange documents throughout the process.

“There was a lot of information that could be shared directly within Drata, which saved hours of time on our part,” Heizman says. “And our conversations were much more productive because everyone had the materials they needed and we could dive right in.”

Sensiba’s audit approach included a virtual walkthrough of Lucidworks’ location in San Francisco’s Financial District, saving time and costs.

Result

Achieving ISO 27001 recertification provides important validation of Lucidworks’ information security controls and processes.

“We have customers in the engineering and manufacturing sector, the financial space, and outside the United States,” Heizman says. “They expect to see compliance with a variety of quality management and security frameworks, but ISO 27001 is especially important.”

The Drata platform enabled Lucidworks to streamline other security-related audits, such as SOC 2 Type II (also conducted by Sensiba). Lucidworks was able to leverage SOC 2 evidence to provide a headstart on its ISO 27001 recertification audit.

“Doing the ISO audit gave us a strong starting point from which we could branch out,” Heizman says. “And now we’re seeing concerns about privacy and AI, and other components that are available within ISO.”

Heizman recommends companies exploring the ISO 27001 audit process look for audit firms that can provide a collaborative relationship. While the auditors have to maintain their independence and won’t provide prescriptive advice, they can help clients understand the process and discuss accepted practices in general terms.

“I’d say to anyone that even if you feel you’re not ready, it’s never too early to engage someone,” she says. “The only way you can get a true feeling where you stand is talking with your auditors and figuring out if you need to shore up processes or controls.”

Ready to get started?

Find out how our Risk Assurance team can help you with your compliance. Contact us to learn more about how we can work together toward your goals.

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How Penetration Testing Improves Industry Standards Compliance

Penetration testing plays an important role in compliance audits as well as ongoing security reviews by helping organizations identify, assess and remediate security vulnerabilities. Also known as a pen test, a penetration test is a security evaluation or exercise performed to discover security weaknesses that malicious actors could use to gain access to an organization’s systems and sensitive data.

Penetration testing is also informally called “ethical hacking” because the goal of the test is to remediate vulnerabilities, not to perform malicious actions.

The Importance of Cyber Penetration Testing

Penetration testing is a vital part of an organization’s cybersecurity strategy. It helps organizations identify and fix security weaknesses before criminals can exploit them.

For compliance purposes, pen testing is conducted to help organizations meet well-known industry standards and frameworks, such as SOC, ISO, HITRUST, FedRamp, PCI, or other frameworks.

In this context, pen testing complements the organization’s vulnerability management program and demonstrates to third parties that active security evaluations are being done to identify potential risks and impacts to the business.

Pen testing allows a third party to identify system vulnerabilities and threats. In turn, this evaluation helps organizations prioritize the most impactful security risks, and to design and implement controls to mitigate these risks.

Who Can Perform the Test?

Penetration testing is typically performed by external resources or specialized firms who bring not only technical experience and abilities, but also an objective assessment of any discovered vulnerabilities and their seriousness. It’s important for pen testers to be certified and to have relevant qualifications including experience.

Penetration Testing vs. Vulnerability Scanning

Penetration tests are often conducted with vulnerability scans, but the techniques have different purposes. A vulnerability test is an automated process that looks for missing patches, misconfigurations, or other issues a hacker could exploit maliciously.

In contrast, a penetration test simulates a real-world attack on a system or network by humans who combine a variety of techniques to probe a system for vulnerabilities.

How Often Should Testing Be Done?

Along with regular vulnerability scans, penetration tests are good controls to help address vulnerabilities consistently. Sensiba typically recommends that organizations perform regular vulnerability scans monthly or, at maximum, quarterly, with pen testing occurring annually.

Types of Penetration Tests

Penetration tests fall into three categories:

Internal Penetration Testing

White box (also referred to as internal penetration testing): Penetration testers will have full access and detailed knowledge of the target systems or environments to identify vulnerabilities. The review will also include evaluations of the code and the internal structure of the organization’s software or applications. From a security evaluation perspective, this type of test typically yields the most findings for organizations to remediate.

External Penetration Testing

Black box (also referred to as external penetration testing): Penetration testers will have no knowledge of the target systems or environments. The main goal of this approach is to simulate a real attack from an external threat. The tester probes the system and observes how the system reacts and performs under the test. Typically, this type of test yields the lowest findings.

Blended Testing

Grey box: Blending white and black box techniques, penetration testers will have partial knowledge or access to target systems or environments. This type of test typically involves escalating their privileges, if possible, to systems. The tester typically knows the internal components of an application, but not how those components interact. This ensures that testing reflects the experiences of potential attackers and users.

Choosing the type of pen test depends on several factors, including the organization’s risk level, desired scope, and budget. Each the testing approach involves different access levels and systems knowledge, with white box testing being the most expensive, followed by grey box and black box.

Need Assistance?

Penetration testing is an essential component of enhancing your security controls and compliance with industry standards. We provide cost-effective pen testing services to help you improve your organization’s overall security posture. 

If you want to learn more about how penetration testing can benefit your organization, don’t hesitate to contact us.

Your First SOC 1 Audit: Essential Prep Steps for Success

A SOC 1 audit examines the internal controls over financial reporting (ICFR) a service provider has in place to ensure transaction processing or data manipulation on behalf of its customers is done consistently and reliably. A clean SOC 1 report provides assurance that transaction and data processing is performed consistently, and the information and can be relied upon by the service organization’s customers and their financial statement auditors.

Planning for an effective SOC 1 audit involves answering a series of questions:

  • Which teams should be involved? This will depend on the product features and processes that can affect client financials.
  • What monitoring period dates should we choose? This will depend on how soon you need a completed audit.
  • How do we identify relevant controls? Focus on the product features that affect your client’s financials and the controls in place to make sure those features operate appropriately.

Scoping conversations about your SOC 1 audit should take place early in the process and will typically involve your auditors. Often times, the scope of the SOC 1 can be determined by the purpose of the SOC 1, who is requesting the SOC 1, and what business functions they want coverage over.

Mastering SOC 1 Readiness

An effective SOC 1 audit starts with the readiness phase. Before the audit, you’ll want to establish control objectives, identify the appropriate controls to meet those objectives, and draft control language. Ensuring your controls are best suited and assigned for the purpose of your software and planning for your auditors to walk through your processes, paves the way for a smooth and successful SOC 1 audit.

Most service organizations will have controls within several broad categories:

  • Internal controls over financial reporting. These will typically include the organization’s structure, policies, and procedures; access controls; transaction processing controls; segregation of duties; system monitoring; and other controls to support effective risk management and financial reporting.
  • Entity-level controls that describe how the organization is governed and managed. Common examples include controls over employee onboarding and offboarding, tone at the top, and other key processes and policies.
  • IT general controls, such as customer data at rest being encrypted and the approval process for system changes.

If a service organization has a completed SOC 2 audit, many of these controls can be mapped over to a SOC 1 report.

If your company only needs a SOC 1, it may make sense to obtain project management resources to work with the company on the core elements of a SOC 1 control environment, such as policies and procedures, entity-level controls, and other key details. Someone with SOC and controls experience can greatly benefit the company.

To learn more, our guide, Getting Your First SOC 1 Report, highlights the compelling benefits a SOC 1 report provides service organizations, and the value of leveraging a completed SOC 2 audit to launch a SOC 1 audit. 

Understanding Bridge Letters for SOC 2: What They Are and Why They Matter

When it comes to maintaining the integrity and trustworthiness of your organization’s information security practices, SOC 2 attestation is a critical component to help provide assurance to customers, their auditors, and potential business partners.

However, there are instances where the reporting period of a SOC 2 audit does not align perfectly with a company’s fiscal year or dating requirements of other stakeholders. This is where bridge letters come into play.

What Is SOC 2?

Before diving into bridge letters, let’s recap what SOC 2 is. SOC 2 (System and Organization Controls 2) is a type of audit report that evaluates an organization’s controls relevant to the AICPA’s Trust Services Criteria: security, availability, processing integrity, confidentiality, and privacy.

Obtaining SOC 2 attestation is crucial for service organizations that handle sensitive customer data because doing so assures clients and stakeholders that the service organization maintains robust data security measures. Many customers, especially large enterprises, consider a clean SOC 2 report as a basic requirement as they evaluate potential service providers.

To gain a deeper understanding of SOC 2 reports and their components, please refer to our article, “Key Elements of a SOC 2 Report”.

What Is a Bridge Letter?

A bridge letter, also known as a gap letter, is a document provided by a service organization (not the service auditor) to address the gap between the SOC 2 audit reporting period and the current date. The bridge letter provides interim (and unverified) assurance that the controls evaluated in the last SOC 2 audit report are still in place and operating effectively.

What is a bridge letter graphic. It shows a bridge between when you get a SOC report and the current date.

Why Are Bridge Letters Important?

Bridge letters provide several benefits, including continuity of assurance. Clients and stakeholders rely on SOC 2 reports to assess the security posture of a service organization. A bridge letter ensures there is no gap in assurance between the end of the audit period and the next scheduled audit.

Bridge letters also help service organizations meet their Contractual obligations. Many contracts and regulatory requirements stipulate continuous compliance with internal controls. Bridge letters help organizations provide assurance they are meeting these obligations during the interim period.

They also support business continuity during situations such as mergers, acquisitions, or new business deals, where having an up-to-date assurance of SOC 2 compliance is crucial. A bridge letter provides the necessary assurance for participants to proceed with confidence.

Key Elements of a Bridge Letter

A well-crafted bridge letter typically includes the following elements:

  • Statement of Continuity: A declaration that the controls outlined in the most recent SOC 2 report remain in place and are operating effectively.
  • Period Covered: A clear indication of the dates covered by the bridge letter. This is typically from the end of the last audit period to the current date, or the date of the next audit.
  • Changes and Updates: Disclosures of any significant changes in the organization’s control environment since the last SOC 2 report.
  • Signatory: The bridge letter should be signed by an authorized representative of the service organization, typically the chief information security officer (CISO), compliance officer or a similar authority.

Best Practices for Issuing Bridge Letters

Service organizations issuing bridge letters should keep the following in mind:

  • Timeliness: Ensure the bridge letter is issued promptly to avoid gaps in assurance.
  • Transparency: Outline clearly any changes or incidents that may have affected the service organization’s internal control environment since the last audit.
  • Regular Updates: Revise bridge letters as needed, especially if there are significant changes in the control environment.
  • Consultation with Auditors: Engage with your auditors to ensure the bridge letter reflects the current state of controls accurately and addresses any concerns they may have.

Bridge letters play a crucial role in maintaining continuous assurance of a service organization’s SOC 2 control environment. They provide customers, stakeholders, and regulatory bodies with assurance the organization’s controls remain robust and effective between audit periods.

By understanding and using bridge letters effectively, service organizations can provide ongoing trust and compliance in their data security practices.

To learn more about SOC 2 audits and the role of bridge letters, get in touch with our team.

Everything You Must Know About SOC 1 Reports

For service organizations that process transactions, manipulate data or store financial information on behalf of their customers, a SOC 1 (short for Service Organization Controls) report provides assurance that the processing of those transactions and data is done consistently and can be relied upon by your customer, and even more relevantly, your customer’s auditors.

What Is a SOC 1 Report?

A SOC 1 examination centers on the internal controls over financial reporting (ICFR) a service provider has in place to ensure transaction processing or data manipulation is done consistently and reliably. The SOC 1 standard is established and maintained by the American Institute of Certified Public Accountants (AICPA) and the examination is typically conducted by auditors from an independent accounting firm.

SOC 1 engagements require specialized auditor skills, including understanding the relevant standards as well as the business processes of their clients. The auditor provides an opinion upon completion of a SOC 1 engagement with the objective of a successful engagement offering a “clean” opinion that is attached to the SOC 1 report.

SOC 1 Type 1 vs. SOC 1 Type 2

A SOC 1 report may be completed in one of two forms. A SOC 1 Type 1 report examines the service organization’s ICFR at a specific point in time and provides evidence on whether the controls are designed properly. A SOC 1 Type 1 report is usually done, if at all, on the initial SOC 1 engagement and as a precursor to the SOC 1 Type 2 report.

However, when your customer asks you for a SOC 1 report, they almost invariably mean a SOC 1 Type 2 report. The fundamental difference is that a SOC 1 Type 2 report tests those controls and their performance over a period such as six months or a year. As such, the SOC 1 Type 2 not only covers whether the controls are properly designed; the controls are also tested to determine if they are operating effectively over the relevant period. SOC 1 Type 2 engagements are by far the most common report, with most covering one year.

SOC 1 vs. SOC 2

SOC 1 and SOC 2 reports have some overlap, but there are fundamental differences with SOC 1 vs. SOC 2.

A SOC 2 report reviews the controls that address the Trust Services Criteria (primarily security, but there are five criteria to choose from) and is relevant for service organizations that have custody of their customer’s data. The Trust Services Criteria provide a framework that can be applied to a wide range of service providers.

On the other hand, a SOC 1 report is focused on business processes specific to the service organization and thus there is significantly more variability because the control environment, and the related controls, will be specific to the service organization.

The testing procedures for a SOC 1 will focus on financial controls and transaction processing, while a SOC 2 will examine general IT controls (ITGC) testing and validation. This is where the overlap comes in. As most SOC 1 systems are built on information technology systems, many controls from a SOC 2 report can be mapped to a SOC 1 report.

Depending on the industry a service organization serves and its customer expectations, a provider may need to obtain both types of reports. If so, there can be efficiency and cost benefits to undergoing both types of audits at the same time.

Who Needs a SOC 1 Report?

Because a SOC 1 report is focused on financial reporting controls, it’s best suited for organizations that process or store financial data on behalf of their customers. Typical types of service organizations that may need a SOC 1 include:

  • Software-as-a-Service (SaaS) providers that process financial data.
  • Payment processors.
  • Payroll processors.
  • Claims processing and billing providers.
  • Benefits administrators.
  • Collections organizations.

Beyond these organizations, any company that processes or stores financial data for a customer may be asked for a SOC 1 report. Often the request for a SOC 1 report will be generated from your customer’s accounting and finance function, or you may get direct requests from a customer’s financial statement auditors (the intended reader of a SOC 1 report). For more information on who needs SOC 1 reports and why they matter watch the video below.

The Benefits of a SOC 1 Report

Obtaining independent verification that a service organization’s ICFR is performing effectively, known as a “clean” audit report, can provide several benefits such as:

  • Ensuring the organization is protecting customer and partner financial information. An audit can verify that the organization’s controls and processes are operating as designed, or it can identify areas that need remediation.
  • Demonstrating the organization’s commitment to data security and governance.
  • Assuring customers your systems are processing transactions consistently and reliably.
  • Identifying opportunities to increase risk management and operating efficiency within your systems and processes.
  • Reducing overhead from multiple auditors of your customers asking to meet with you to understand your system and how you process transactions.

Beyond compliance, a clean SOC 1 report can provide compelling benefits in attracting and retaining customers:

  • Providing a SOC 1 report is becoming a common contractual requirement, especially among large enterprise customers. These organizations want to ensure their data will be processed consistently and accurately, and increasingly rely on SOC 1 reports for that assurance.
  • Obtaining a SOC 1 report can differentiate a service organization from competitors that have not undergone a SOC audit.
  • Having a SOC 1 report can help service organizations properly respond to your customers and their auditors’ inquiries as to how your environment reliably processes transactions.

To learn more about SOC 1 reports and the benefits they can provide your service organization, contact us.

Getting Your First SOC 1 Report

SOC 1 reports, which describe how service organizations process data and transactions that can affect their customers’ financial reporting, have emerged as important tools in vendor selection and risk management.  

Our guide, Getting Your First SOC 1 Report, highlights:

  • The Importance of SOC 1 in Auditing 
  • How SOC 1 Interplays With SOC 2 
  • Types of Controls 
  • SOC 1 Starting Point Scenarios 
  • Scoping Your First SOC 1

Learn how to leverage the similarities between SOC 1 and SOC 2 to streamline the process and make it more manageable.  

SOC 1 Reporting for SaaS Companies

One of the most effective ways for Software as a Service (SaaS) companies to demonstrate the reliability, accuracy, and security of their services is by obtaining a SOC 1 report.

The Service Organization Controls (SOC) 1 report centers on the controls an outsourced service provider has in place to ensure the transactions or data processing that affect a customer’s financial reporting are completed accurately and reliably. A SOC 1 report focuses on processes and controls specific to the service organization and demonstrates that the provider uses industry-recognized best practices to assess and manage data accuracy risks.

The service organization’s customer is commonly known as a user entity, who typically uses a SOC 1 report’s findings during vendor selection and reviews. Additionally, a SOC 1 report is generally requested in financial reporting audits.

Why SaaS Companies Need SOC 1 Reports

SaaS companies vary from email and CRM providers to companies offering accounting and ERP applications. The risk profile of the SaaS provider varies according to the applications they provide and the data they generate or process for their customers. SaaS platforms that affect their customers’ financial reporting (i.e., commission platforms, or sales and revenue platforms) need to reassure their customers and prospects that their data is accurate, and transactions are processed reliably.

The scope of a SOC 1 audit will include the SaaS provider’s internal controls over financial reporting (ICFRs) and its IT general controls (i.e., change management, logical access, system operations). The provider’s management will identify control objectives that address specific risks they wish to mitigate, as well as controls that are in place to support these control objectives.

Examples of ICFR-related controls for SaaS providers may include data input validation, record maintenance, and transaction reconciliations, or any other measure designed to ensure the validity of financial data and the provider’s security practices.

During the examination, the independent audit firm will review those objectives, test controls, and issue an opinion on the operating effectiveness of the controls that are in place.

SOC 1 Flexibility

Unlike a SOC 2 report, in which a service organization’s practices are compared against specific Trust Services Criteria, SOC 1 control objectives are flexible so providers can align with specific services affecting customer data and industry best practices.

In order to design SOC 1 control objectives effectively, SaaS providers need to focus on the features that effect their clients’ financials. Often times, this can be a daunting and overwhelming task that takes time and effort from the company. However, with the help of Sensiba and our SOC 1 readiness program, we provide consulting services for designing control objectives and identifying supporting controls.

The Benefits of a SOC 1 Report

For SaaS companies, a SOC 1 report can provide several benefits:

  • Ensuring the provider has controls in place ensuring the accuracy of client data.
  • Demonstrating a commitment to data security and governance.
  • Assuring customers that the platform is processing transactions consistently and reliably.
  • Identifying opportunities to increase risk management and operating efficiency within your systems and processes.

Providing a SOC 1 report is becoming a common contractual requirement as customers want assurance their financial data will be processed consistently and accurately.

To learn more about SOC 1 reporting for SaaS companies and how it can benefit you, contact us.

ISO 27001 vs. SOC 2: Do You Need Both? 

The ISO 27001 certification and the SOC 2 report are perhaps the leading frameworks for companies to demonstrate their commitments to securing customer data. Some service providers, depending on their customers and the types of information they handle, can benefit from obtaining both.  

Understanding the uses of each framework, where they overlap, their intended audiences—and whether an organization needs one, the other, or both—can play a large role in helping a service organization enhance its risk management efforts and highlight its security capabilities to current and prospective customers. 

What is SOC 2?

A SOC 2 report provides service organizations with an external opinion on their compliance with a standardized set of industry-neutral controls based on the AICPA’s Trust Services Criteria—security, availability, processing integrity, confidentiality, and privacy.  

Under SOC 2, only the security criterion is mandatory. Deciding whether to include any of the other criteria depends on the types of information a service provider handles and its customers’ requirements.  

SOC 2 is not a certification. Instead, it is an audit opinion on the description of the system (a written narrative describing the infrastructure, data, people, processes, and boundaries of the system), and the controls implemented. 

What is ISO 27001? 

An ISO 27001 Information Security Management System certification provides service organizations with a framework that’s more prescriptive than the SOC 2 criteria. ISO 27001 helps organizations manage and protect their information assets by developing policies, procedures, and controls to protect information from unauthorized access, alteration, theft, or destruction. 

An ISO certification requires a statement of applicability, risk assessment, internal audit, and management review. The certification also prescribes the number of days, primarily based on the organization’s headcount, an audit will require.  

Certification vs. Attestation 

A key difference between the two is that SOC 2 is not a certification. A SOC 2 report is an attestation by an independent audit firm as to whether the organization under review reasonably meets the standards outlined in the SOC 2 criteria.  

Required Information for Each Review 

Both reviews look at the following:

  • Risk assessment 
  • Vulnerability management 
  • Policies and procedures 
  • Internal controls 
  • Monitoring and review
  • Third-party risk management
  • Compliance 

ISO 27001 adds the following requirements:

  • Statement of applicability 
  • Internal audit 
  • Management review 

SOC 2 adds the following:

  • Written system description
  • Higher sample requirements than ISO 27001 
  • Processing integrity (optional)

The ISO 27001 Process  

The ISO certification is a three-year certification standard, starting with two stages in the first year. The stage one process is essentially a readiness review to ensure the organization has the information needed for the stage two audit. This will include, for example, items such as the organization’s internal audit function, risk assessment, and key policies and procedures.  

If this initial review identifies any areas of concern, the organization will typically have 30 to 60 days to remediate those issues. Once the areas of concern are addressed, the deeper-dive stage two audit will occur.  

After an organization receives ISO 27001 certification, surveillance audits are required for two years before its compliance needs to be recertified.  

ISO 27001 Process

Which Organizations Need ISO Certification?  

ISO is an international standard, while SOC 2 focuses on North America. Service organizations supporting international customers outside of North America will benefit from an ISO certification.   

Similarly, companies based outside North America hoping to do business in the U.S., Canada, or Mexico will likely have an ISO certification but should consider obtaining a SOC 2 report to capture market opportunities in those markets.  

Service organizations operating globally would benefit from undergoing both audits. The good news is the types of information each review requires are similar enough that an organization undergoing one review will be about 70% of the way toward completing the other.  

ISO 27001 Internal Audit 

Under the ISO 27001 standard, internal audits are required annually and must be conducted by someone who is both competent in auditing against the 27001 standard, as well as independent from the information security management system being reviewed.  

Because of these two requirements, most organizations interested in ISO certification outsource their internal audit function to a third party. For all but the largest organizations, someone on staff who is competent in the ISO standard is unlikely to be independent. In addition, outsourcing the internal audit function often results in a more thorough evaluation of their management system.  

Optimizing Audit Scheduling  

Organizations interested in pursuing ISO 27001 and SOC 2 reviews can streamline the process by scheduling both examinations carefully. For instance, SOC 2’s higher sampling requirement means the information gathered for that audit can also be used as part of the ISO certification, if the audits are timed correctly.   

Similarly, the organization should align the periods when auditors will be reviewing evidence with less-busy times of the fiscal year. Conducting both reviews at once can reduce the administrative overhead on their internal teams.   

Service organizations that process personal health information and need to demonstrate compliance with Health Insurance Portability and Accountability Act (HIPAA) security and privacy safeguards can also incorporate that examination with a SOC 2 audit.  

To learn more about ISO 27001, SOC 2, and the potential benefits of undergoing both reviews, contact us.  

ISO 27001 vs SOC 2: Do I Need Both?

Join us as we explore ISO 27001 and SOC 2. We’ll discuss the elements that businesses need to consider and ultimately answer the important question “do I need both?” Gain powerful insights to leverage both certifications.