Welcome to this week’s Third Party Thursday! My name is Aaron Kirkpatrick and I’m the Information Security Officer here at Venminder. Today we’re going to be talking about three key points to review in service organization control reports, SOC reports for short, as you begin assessing your vendors environment. Let’s get started with the three questions:
1. Is the product you use the vendor for included within the scope of the report?
2. What was the audit period of the most recent audit and was the report issued less than one year ago?
3. Does your vendor have critical vendors of their own that directly impact you?
This first question is here because many vendors, especially large vendors, have many different SOC reports available with different products covered under different SOC reports and some products may not be covered at all. Make sure you read the scope statement and ensure the product you use is called out. If it’s not, make sure to ask your vendor representative.
Related to that, there are many products which require the review of multiple SOC reports in order to gain a full picture of the operating environment of the service or product. We’ll touch on this more in the third item.
Let’s look at question two concerning the period of time that the vendor was under audit. Looking at the answer to the second question you are able to begin to understand two more things:
1. Does the vendor have a SOC audit performed every year, or do they skip years?
2. Does the vendor elect to have full twelve-month audit periods, or are there times when the vendor is not under audit?
Why are either of these important? If vendors are skipping years it’s normally because of financial reasons as SOC audits are not inexpensive so sometimes we’ll see this with smaller companies. Or, the vendor just does not see the value or ROI in performing the exams. If you run into a vendor with a report older than 1 year, you should ask why.
Not unlike the first item we learned, the second item, period of time the audit covers, money usually comes into play. We see this in vendors who are again, typically smaller who do not have the staff to continually manage an audit. Another reason we’ve seen this is that it’s easier to grow and change processes without worrying about the impact to the in-scope control environment, so companies may only do audits every other six months.
The scenario caused by a positive answer to question three is very common and becoming more so. The most common occurrence of where a vendor uses another vendor who is critical to their operations in order to support YOU as a customer, is the outsourcing of their computing environment such as through colocation, data center or a cloud services provider, all of which are sometimes called TSP’s or Technology Service Providers.
These vendors to your vendor are called "sub-service organizations" in the SOC world. Just because your vendor’s SOC doesn’t contain information surrounding the security and availability of the information contained on the computing environment at that sub-service organization, does NOT mean that it is to be ignored. It only means that you as the end customer are only getting half of the picture which is not sufficient to fully view the risks you are exposed to by using that vendor’s products or services.
How does a responsible vendor manager keep up with reviewing all the critical, high, medium risk vendors SOC reports and ensure full comprehension of what those reports are and are NOT saying? Do you really know where your vendors are storing your clients data?
The benefits of reviewing SOC reports are not limited simply to the examiner’s request. There are true strategic business advantages to be gained from it.
Again, I’m Aaron and thank you for watching! Don’t forget to subscribe to the Third Party Thursday series.