Guide: Reporting on an Entity's Cybersecurity Risk Management Program and Controls

Table of contents

1. Cover Page
2. Title Page
3. Copyright Page
4. Contents
5. Chapter 1: Introduction and Background
   1. Introduction
   2. Potential Users of Cybersecurity Information and Their Interests
   3. Cybersecurity Risk Management Examination
   4. Difference Between Cybersecurity and Information Security
   5. Description of the Entity’s Cybersecurity Risk Management Program
      1. The Entity’s Cybersecurity Objectives
   6. Effectiveness of Controls Within the Entity’s Cybersecurity Risk Management Program
   7. Overview of the Cybersecurity Risk Management Examination
      1. Other Information About the Cybersecurity Risk Management Examination
      2. Time Frame of Examination
      3. Comparison of the Cybersecurity Risk Management Examination With an Audit of Internal Control Over Financial Reporting That is Integrated With an Audit of Financial Statements
      4. Cybersecurity Risk Management Examination that Addresses only a Portion of the Entity’s Cybersecurity Risk Management Program
      5. Cybersecurity Risk Management Examination That Addresses Only the Suitability of the Design of Controls (Design-Only Examination)
   8. Other Engagements Related to Controls Over Security, Availability, Processing Integrity, Confidentiality, or Privacy
      1. SOC 2 Engagements
      2. Comparison of a Cybersecurity Risk Management Examination and a SOC 2 Engagement
      3. Engagements Under the AICPA Consulting Standards
   9. Professional Standards
      1. Attestation Standards
      2. Code of Professional Conduct
   10. Quality in the Cybersecurity Risk Management Examination
6. Chapter 2: Accepting and Planning a Cybersecurity Risk Management Examination
   1. Introduction
   2. Understanding Management’s Responsibilities
   3. Practitioner’s Responsibilities
   4. Accepting or Continuing an Engagement
      1. Preconditions of a Cybersecurity Risk Management Examination
   5. Determining Whether the Subject Matter is Appropriate for the Cybersecurity Risk Management Examination
      1. Determining Whether the Subject Matter of the Engagement is Appropriate When the Cybersecurity Risk Management Examination Addresses Only a Portion of the Entity’s Cybersecurity Risk Management Program
      2. Determining Whether the Subject Matter is Appropriate When the Examination Addresses Only the Suitability of the Design of Controls Within the Entity’s Cybersecurity Risk Management Program (Design-Only Examination)
      3. Determining Whether Management is Likely to Have a Reasonable Basis for the Assertion
      4. Consideration of Third Parties
   6. Assessing the Suitability and Availability of Criteria and the Related Cybersecurity Objectives
      1. Description Criteria
      2. Control Criteria
      3. Assessing the Suitability of the Entity’s Cybersecurity Objectives
   7. Requesting a Written Assertion and Representations From Management
   8. Considering Practitioner Independence
   9. Considering the Competence of Engagement Team Members
   10. Establishing the Terms of the Engagement
       1. Accepting a Change in the Terms of the Engagement
   11. Establishing an Overall Examination Strategy and Planning the Examination
       1. Considering Materiality During Planning
   12. Performing Risk Assessment Procedures
       1. Obtaining an Understanding of the Entity’s Cybersecurity Risk Management Program and Controls Within That Program
       2. Assessing the Risk of Material Misstatement
   13. Understanding the Internal Audit Function
   14. Planning to Use the Work of Internal Auditors
       1. Evaluating the Competence, Objectivity, and Systematic Approach Used by Internal Auditors
       2. Deterining the Extent to Which to Use the Work of Internal Auditors
       3. Coordinating Procedures With the Internal Auditors
       4. Evaluating Whether the Work of Internal Auditors is Adequate for the Practitioners’ Purposes
   15. Planning to Use the Work of an Other Practitioner
   16. Planning to Use the Work of a Practitioner’s Specialist
7. Chapter 3: Performing the Cybersecurity Risk Management Examination
   1. Responding to Assessed Risks and Obtaining Evidence
      1. Considering Materiality in Responding to the Assessed Risks and Planning Procedures
      2. Designing Overall Responses to the Risk Assessment
   2. Obtaining Evidence About Whether the Description of the Entity’s Cybersecurity Risk Management Program Is Presented in Accordance With the Description Criteria
      1. Materiality Considerations When Evaluating Whether the Description is Presented in Accordance With the Description Criteria
      2. Considering Whether the Description is Misstated or Otherwise Misleading
      3. Evaluating the Description When the Cybersecurity Risk Management Examination Addresses Only a Portion of the Entity’s Cybersecurity Risk Management Program
      4. Procedures to Obtain Evidence About the Description
      5. Considering the Suitability of the Entity’s Cybersecurity Objectives
   3. Materiality Considerations When Evaluating the Effectiveness of Controls to Achieve the Entity’s Cybersecurity Objectives
   4. Obtaining and Evaluating Evidence About the Suitability of the Design of Controls to Achieve the Entity’s Cybersecurity Objectives
      1. Identifying and Evaluating Deficiencies in the Suitability of Control Design
   5. Obtaining Evidence About the Operating Effectiveness of Controls to Achieve the Entity’s Cybersecurity Objectives
      1. Designing and Performing Procedures to Evaluate the Operating Effectiveness of Controls
      2. Nature of Procedures to Evaluate the Effectiveness of Controls
      3. Evaluating the Reliability of Information Produced by the Entity
      4. Timing of Procedures
      5. Extent of Procedures
      6. Selecting Items to Be Tested
      7. Testing Changes to Controls
   6. Risk Mitigation and Control Considerations Related to Third Parties
   7. Controls Did Not Need to Operate During the Period Covered by the Practitioner’s Report
   8. Revising the Risk Assessment
   9. Using the Work of a Practitioner’s Specialist
   10. Evaluating the Results of Procedures
   11. Responding to and Communicating Known or Suspected Fraud, Noncompliance With Laws or Regulations, Uncorrected Misstatements, or Internal Control Deficiencies
       1. Known or Suspected Fraud or Noncompliance With Laws or Regulations
       2. Communicating Incidents of Known or Suspected Fraud, Noncompliance With Laws or Regulations, Uncorrected Misstatements, or Internal Control Deficiencies
   12. Obtaining Written Representations From Management
       1. Requested Written Representations Not Provided or Not Reliable
       2. Subsequent Events and Subsequently Discovered Facts
       3. Subsequent Events Unlikely to Have an Effect on the Practitioner’s Opinion
   13. Documentation
   14. Management’s Responsibilities at or Near Engagement Completion
       1. Modifying Management’s Assertion
8. Chapter 4: Forming the Opinion and Preparing the Practitioner’s Report
   1. Responsibilities of the Practitioner
   2. Forming the Practitioner’s Opinion
      1. Considering the Sufficiency and Appropriateness of Evidence
      2. Considering Material Uncorrected Description Misstatements and Deficiencies
      3. Expressing an Opinion on the Subject Matters in the Cybersecurity Risk Management Examination
   3. Preparing the Practitioner’s Report
      1. Elements of the Practitioner’s Report
      2. Tailoring the Practitioner’s Report in a Design-Only Examination
   4. Modifications to the Practitioner’s Opinion
      1. Emphasis of Certain Matters
      2. Controls Did Not Operate During the Period Covered by the Report
   5. Material Misstatements
      1. Qualified Opinion
      2. Adverse Opinion
      3. Separate Paragraphs Because of Material Misstatements in the Description
      4. Separate Paragraphs Because of Material Deficiencies in the Effectiveness of Controls to Achieve the Entity’s Cybersecurity Objectives
   6. Scope Limitation
      1. Qualified Opinion
      2. Disclaimer of Opinion
   7. Restricting the Use of the Practitioner’s Report
      1. Restricting Use When Required by Professional Standards
      2. Restricting Use in Other Situations
   8. Distribution of the Report
   9. Reporting When Using the Work of an Other Practitioner
   10. Reporting When a Specialist is Used for the Cybersecurity Risk Management Examination
   11. Report Date
   12. Other Information
9. Appendix
   1. A: Information for Entity Management
   2. B: Illustrative Comparison of the Cybersecurity Risk Management Examination with a SOC 2 Examination and Related Reports
   3. C: Description Criteria for Use in the Cybersecurity Risk Management Examination
   4. D: Trust Services Criteria for Security, Availability, and Confidentiality for Use as Control Criteria in the Cybersecurity Risk Management Examination
   5. E: Illustrative Management Assertion in the Cybersecurity Risk Management Examination
   6. F-1: Illustrative Accountant’s Report in the Cybersecurity Risk Management Examination
   7. F-2: Illustrative Accountant’s Report in a Cybersecurity Risk Management Examination that Addresses Only the Suitability of the Design of Controls Implemented Within the Entity’s Cybersecurity Risk Management Program (Design-Only Report) as of a Point in Time
   8. G: Illustrative Cybersecurity Risk Management Report
   9. H: Definitions
   10. I: Overview of Statements on Quality Control Standards
10. Index of Pronouncements and Other Technical Guidance
11. Subject Index