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v1.13: the same 89 controls and 387 checks, with clearer evidence guidance on 32 checks and in the collection guidance of 15 controls, one new tool, and what the examining firm considers in judging a check

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@ausyinn ausyinn released this 21 Oct 04:00
· 1 commit to main since this release

The same 89 controls and 387 checks, with clearer evidence guidance on 32
checks and in the collection guidance of 15 controls, one new tool, and what
the examining firm considers in judging a check.

  • Managed platforms: the hosting platform's managed edge or its
    provider-enforced ingress restrictions count as boundary protection, with
    evidence that the protection is active and bypass paths are controlled
    (NET-02 A1), and where there is no customer-controlled network,
    provider-enforced isolation and access rules count when they show
    least-privilege paths between the relevant segments (NET-01 A3). A
    resilience consideration can be the provider's managed redundancy, the
    backup and restore approach, or a documented decision to run in a single
    region (BCP-01 A4), and backups can be stored in a separate availability
    zone (BCP-02 A4). The provider's built-in activity log on the current plan
    counts where it records sign-ins, access changes and admin actions, as does
    a paid audit-log add-on (MON-03 A1).
  • Agreements accepted online: BAA terms the customer accepted electronically,
    with the acceptance date (HIP-01 A2), and a subcontractor BAA accepted in
    the provider's console or online terms, with the acceptance record (HIP-01
    A3).
  • Small teams: in a team of one to three engineers, each engineer may hold
    production admin with a documented need for each account, and the CPA-review
    flag still applies (END-02 A2). Where headcount prevents separating duties,
    a risk assessment entry that evaluates this as a fraud measure and names the
    compensating review counts (RSK-01 A9). A confidential email alias reaching
    a named responsible person, such as an outside advisor, is a reporting
    channel (COM-02 A3). The outside reviewer can be one outside advisor, with
    no board seat or equity, and an independent board member counts too (GOV-02
    A6, A7); one person can cover GOV-02 A3, A6 and A7 and the independent
    evaluation check when they are independent of day-to-day management, do not
    build or run the systems, and are not responsible for the controls they
    evaluate.
  • Records a company may already keep: a dated review that kept the incident
    response plan unchanged (INC-01 A3); a tabletop walk-through as the disaster
    recovery test (BCP-01 A6); a tabletop exercise the response team took part
    in, within the audit period, which also serves as their training record
    (INC-01 A6); dated manual checklists recording what was checked and found,
    as ongoing monitoring (EVL-01 A1); merged pull requests and release notes
    showing that affected personnel were notified or took part (POL-02 A4);
    dated completion confirmations (PPL-03 A4) and dated course records within
    the cycle the company's training requirement sets (PPL-03 A5); the building
    or coworking provider's visitor check-in records, with visitor name, date
    and host (NET-03 A4); short-lived credentials that expire on their own
    (IAM-08 A2); each device's automatic update settings, shown for each device
    under a written update rule (END-01 A4); and, where neither applicable law
    nor the company's commitments call for telling customers about subprocessor
    changes, a documented basis for that (VND-04 A3).
  • Intervals: 12 months is named as our audit's own minimum for a recent record
    (RSK-01 A1 and A12, AST-01 A5, NET-03 A5, VUL-02 A1, BCP-01 A6, INC-01 A3
    and A6), and a year for manual credential rotation (IAM-08 A2); RSK-01 A1
    and A12, AST-01 A5, NET-03 A5 and VUL-02 A1 accept a shorter interval the
    company sets. Access reviews follow the frequency the company's own policy
    defines (IAM-05 A3), and red flags read against the company's own scanning
    interval (VUL-01), its backup policy or recovery objectives (BCP-02) and its
    written policy on workload (PPL-04). A configured log export counts when its
    destination keeps logs for the longer of the policy period and 90 days
    (MON-01 A3).
  • What a check covers: one sampled user per in-scope system, drawn from the
    groups the applicable MFA requirement covers (IAM-02 A3); separate
    development and production environments, with or without a staging
    environment (CHG-03 A1); a privacy owner when the Privacy criteria are in
    scope (GOV-03); a data handling level that may state that an area has no
    special requirement, such as disposal of public data (AST-02 A2); single
    sign-on, when any accounts still outside it are listed and justified or the
    evidence shows there are none (IAM-01 A4); and, for a team without device
    management, per-device endpoint encryption with evidenced removable-media
    restrictions, encryption or effective compensating protection (DAT-03 A3).
  • Red flags and examples of weak evidence now match their checks: MFA evidence
    that leaves out enforcement or a permitted, evidenced exception (IAM-02),
    capacity (AVL-01), validation at some processing entry points but not others
    (INT-02), error detection, automated or manual, and code that is not
    deployed or not active in production (INT-03), and direct write access to
    the data store (INT-05).
  • A new tool, remove_system, takes a system added by mistake off a readiness
    account's list, with the reason recorded; on an audit, or once one has
    started, the Chiaro team makes that change through report_problem.
    set_company_profile refuses a not-applicable confirmation for a control
    that follows a trust services category, the HIPAA add-on or physical
    facilities, and names the answer that decides it. record_self_assessment's
    fix_description asks, on a gap, for what to produce or start doing.
    submit_population takes a pull too long to paste as saved files, and for
    dated events expects rows from within the window while raw keeps each record
    the command returned.
  • method/readiness-and-independence.md states that, in judging a check, the
    examining firm considers what SOC 2 itself and the company's own written
    policy require.