MRM has woven its data security program into the fabric of the company. Protecting our clients sensitive data is of the utmost importance. We combine employee training, effective policies and procedures and a steadfast commitment to remaining vigilant against new cyber threats to form a comprehensive security program.
Each year, MRM obtains a SOC 2 Type 2 audit report from a certified public accounting firm. Over a 6 month testing period, we must provide evidence about the controls in place on a wide range of security topics. A few of the audited topics are encryption, IT system hardening, business continuity, incidence response and cybersecurity awareness training. The results of this audit are compiled in a detailed report and made available to our partner clients as an assurance of our dedication to safeguarding their data.
In April of 2017, the AICPA announced changes to the Trust Services Criteria of a SOC 2 report. On
December 15th 2018, those changes became required. The Trust Service Criteria was restructured to align with the COSO 2013 framework. COSO is a joint initiative of the American Accounting Association, the American Institute of Certified Public Accountants, the Financial Executives International, The Association of Accountants and Financial Professionals in Business and the Institute of Internal Auditors. The 17 COSO principles are included in the SOC 2 common criteria and supplemented with additional criteria to better address cybersecurity risks.
These changes and additional criteria have resulted in an increase in the number of controls a CPA firm will test for as part of the SOC 2 reporting process. Below are two areas and a few of the actual controls new to a SOC 2 that need to be addressed to maintain compliance.
1)
File Integrity Monitoring (FIM)
– malware, viruses, and hackers are all threats to sensitive files that live on the network. Knowing when these files change and by whom is critical to security posture. Here are just a few of the new SOC 2 controls related to FIM in 2019:
*CC7.1-3 - Implements Change-Detection Mechanisms
The I.T. system includes a change-detection mechanism (for example, File Integrity Monitoring tools) to alert personnel to unauthorized modifications of critical system files, configuration files, or content files.
*CC7.1-4 - Detects Unknown or Unauthorized Components
Procedures are in place to detect the introduction of unknown or unauthorized components.
*CC6.8-2 - Detects Unauthorized Changes to Software and Configuration Parameters
Processes are in place to detect changes to software and configuration parameters that may be indicative of unauthorized or malicious software.
2)
Vulnerability Scanning
– this is a crucial method used to find network security weaknesses. It must be performed regularly and any found vulnerabilities must be remediated. Here are three new controls related to vulnerability scanning in 2019:
*CC3.1-3 - Vulnerability Scanning – Vulnerability scans – both internal and external – are conducted on a regular basis with follow up procedures enacted for remediating any issues as needed.
*CC7.1-5- Conducts Vulnerability Scans
The entity conducts vulnerability scans designed to identify potential vulnerabilities or misconfigurations on a periodic basis and after any significant change in the environment and takes action to remediate identified deficiencies on a timely basis..
*CC7.4-8 - Remediates Identified Vulnerabilities
Identified vulnerabilities are remediated through the development and execution of remediation activities.