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Administrative Controls - Requirements

Verify assessment answers by asking for evidence

Caitlin Fox avatar
Written by Caitlin Fox
Updated over a week ago

Do your due diligence by verifying assessment responses. This is a defensible step that helps ensure you are getting truthful answers. We recommend that you add a few more requirements every year in order to gradually expand the body of evidence.

You can ask for evidence after the assessment has been submitted OR proactively set the requirements in an assessment template. This is the easier method. Learn how to set assessment requirements here.

The recommended list of administrative requirements is below:


Section 1.1 - Risk Management Practices and Integration

Risk decisions (accept, mitigate, avoid, transfer, etc.) are made by executive management personnel with the authority to do so.

If True, ask for a copy of a policy or process with management sign-off

If False, consider pursuing in remediation

If N/A, ask for a note explaining when [date] the policy/process for risk decision-making will be implemented


Section 2.1 - Policies for Information Security

The organization has defined a set of information security policies that are formally approved by executive management.

If True, ask for a copy of an approved policy showing who specifically in executive management approved it

If False, consider pursuing in remediation

If N/A, ask for a note explaining when [date] the information security policy will be implemented


Section 2.3 - Security Roles and Responsibilities

Information security roles and responsibilities are formally defined and documented.

If True, ask for a copy of an organizational chart or information security role definition document

If False, consider pursuing in remediation

If N/A, ask for a note explaining when [date] the information security roles will be defined and documented


Section 2.4 - Separation of Duties

Care has been taken to ensure that no single person can access, modify and/or use information resources without authorization or detection.

If True, ask for a copy of policy or process showing how separation of duties is defined and enforced

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability

Where separation of duties is not feasible, compensating controls such as activity monitoring, audit trails, and management supervision are in place.

If True, ask for a copy of a policy or process showing how compensating controls are defined and enforced

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


Section 3.2 - Management Responsibilities

Personnel activity is monitored to detect potential cybersecurity events.

If True, ask for a copy of a policy or process explaining how monitoring controls are defined and enforced

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date when this will be reviewed for applicability


Section 3.3 - Information Security Awareness, Education, and Training

Employees, contractors, and third party resources receive security awareness training prior to being granted access to information resources.

If True, ask for a copy of a policy or process showing that employees, contractors and third party resources are provided security awareness training prior to being granted access to information resources

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


Section 3.4 - Specialized Information Security Education and Training

Privileged users have received specialized instruction and training.

If True, ask for a copy of a policy or screenshots of training examples provided

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


Section 3.5 - Termination or Change of Employment Responsibilities

Post-employment processes (account removal, password changes, etc.) are processed and validated immediately for involuntary terminations.

If True, ask for a copy of a policy or process showing that post-employment processes (account removal, password changes, etc.) are processed and validated immediately for involuntary terminations

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


Section 4.1 - Inventory of Assets

Physical devices and systems within the organization are all inventoried.

If True, ask for a copy of a policy or process showing that physical devices and systems within the organization are all inventoried

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability

Software platforms and applications within the organization are inventoried.

If True, ask for a copy of a policy or process explaining how inventory is conducted and maintained and/or screenshots of inventory

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


Section 4.5 - Cloud Service Security Management

A complete, up to date, and detailed inventory of all cloud services is maintained.

If True, ask for a copy of a policy or process explaining how inventory is conducted and maintained and/or screenshots of inventory

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability

Data transferred to and from the cloud is all encrypted.

If True, ask for a copy of a policy or process

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


Section 5.1 - Access Control Policy

Segregation of access control roles is sufficient (e.g., access request, access authorization, and access administration).

If True, ask for a copy of a policy or process

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability

A periodic review of user accounts and access rights is conducted according to a defined process and procedure.

If True, ask for a copy of a policy or process and/or screenshots of most current review document with dates of review

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


Section 5.2 - Account Management

The use of shared user accounts is prohibited by the organization.

If True, ask for a copy of a policy or process

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability

System/service accounts are inventoried and specifically authorized.

If True, ask for a copy of a policy or process

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


Section 5.4 - Secure Log-on Procedures

User authentication is required for access to all internal and confidential information resources.

If True, ask for a copy of a policy or process

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


Section 6.1 - Encryption Policy and Control

Encryption requirements for protecting data at rest are documented.

If True, ask for a copy of a policy or process

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability

Encrypted data transfer solutions are provided to users (e.g., encrypted email, SFTP).

If True, ask for a copy of a policy or process and/or a screenshot of secure transfer solution(s) in use

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


Section 7.1 - Mobile Device Policy

The organization requires access controls for mobile devices.

If True, ask for a copy of a policy or process

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability

Remote disable, wipe, and account lockout are documented mobile device security requirements.

If True, ask for a copy of a policy or process

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


Section 7.3 - Documented Operating Procedures

Documented operating procedures for the installation and configuration of server systems exist and are followed.

If True, ask for a copy of a policy or process for configuration and/or screenshots of configuration-matching documented procedures

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability

Detailed operating procedures and instructions for backups are documented, reviewed, and kept up to date.

If True, ask for a copy of a policy or process for backups and/or screenshot of last documented review

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


Section 7.5 - Controls Against Malware

Malicious code protection mechanisms (anti-virus, spam guard, adware, spyware, etc.) are in place, are up to date and rely on multiple software solutions, limiting single points of failure.

If True, ask for a copy of a policy or process for malicious code protection and/or screenshots of solutions in place

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


Section 7.7 - Event Logging

Logging and monitoring settings are applied consistently across all critical/important systems.

If True, ask for a copy of a policy or process for monitoring and/or screenshots of logging solutions in place

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability

Event and security logs are regularly reviewed according to a documented requirement and schedule.

If True, ask for a copy of a policy or process for event review and/or screenshots of solutions in place

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


Section 7.9 - Management of Technical Vulnerabilities

Management engages in proactive vulnerability scanning to identify, assess, and address known and unknown technical vulnerabilities. Monitoring activities are performed to detect and prevent actual attacks against known and unknown vulnerabilities.

If True, ask for a copy of a policy or process for vulnerability scanning and/or screenshots of vulnerability results

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability

A patch management system has been implemented which includes risk assessments against new patches.

If True, ask for a copy of a policy or process for patch management and/or screenshots of solutions in place

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


Section 7.10 - Information Systems Audit Controls

Access control audits (user accounts, rights, privileges, and other access) are performed on a regular basis.

If True, ask for a copy of a policy or process for access control audits and/or screenshots of solutions in place

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability

The results of information security audits are shared with senior management.

If True, ask for a copy of a policy or process for policy security audits reviews and/or screenshots or copy of audit review

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


Section 7.12 - Information Transfer Policies and Procedures

Users are formally trained and made aware of common information transfer mistakes.

If True, ask for a copy of a policy or process for user training on information transfer and/or screenshots of solutions in place

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


Section 7.13 - Information Security Requirements Analysis and Specification

The implementation of new systems includes a method for informing users and operators of their information security duties and responsibilities.

If True, ask for a copy of a policy or process

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability

Contracts with suppliers are in place and the contracts adequately address security requirements.

If True, ask for a copy of a policy or process

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


Section 7.15 - Third-Party Security Risk Management

The organization has developed and maintains a current inventory of all vendors, including purpose, scope, and information security risk requirements.

If True, ask for a copy of a policy or process and/or screenshot of inventory and/or review and validation of its existence and accuracy

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability

Inherent and residual risks related to vendor and third party relationships are reviewed on a regular and ongoing basis.

If True, ask for a copy of a policy or process and/or screenshot of validation of review

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


Section 8.1 - Incident Management Roles and Responsibilities

Formal incident response and escalation procedures have been adequately developed to document actions that must be taken upon knowledge of an information security event.

If True, ask for a copy of a policy or process and/or screenshot of incident response plan and/or review and validation of its existence and accuracy

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability

Incident response procedures are tested on a periodic basis.

If True, ask for a copy of a policy or process explaining how incident response controls are tested

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


Section 9.1 - Planning Information Security Continuity

The organization has developed a formal business continuity plan (BCP) and/or disaster recovery (DR) process.

If True, ask for a copy of a policy or process and/or screenshot of BCP/DR plan and/or review and validation of its existence and accuracy

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability

Business continuity and/or disaster recovery testing and review schedules have been defined.

If True, ask for a copy of a policy or process and/or screenshot of validation of review

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


Section 9.2 - Recovery Plan Details

The organization's recovery plans are tested on a periodic basis, and they have been tested within the past twelve (12) months.

If True, ask for a copy of a policy or process and/or screenshot of validation of testing

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


Section 10.3 - Independent Review of Information Security

Reviews of information security policies, processes, procedures, and practices are periodically performed by an independent reviewer (e.g., internal audit, external audit, or a third party security organization specializing in such reviews).

If True, ask for a copy of a policy or process and/or screenshot of validation of review

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


Section 10.4 - Compliance with Security Policies and Standards

Managers regularly review the level of compliance with information security policies and procedures within their respective areas of responsibility.

If True, ask for a copy of a policy or process and/or screenshot of validation of review

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


Section 10.5 - Protections Against Financial Fraud

Dual control is required for all changes to payment accounts and all payment account setups.

If True, ask for a copy of a policy or process and/or screenshot of validation of review

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability

The use of strong authentication is required for all access to financial systems.

If True, ask for a copy of a policy or process showing that strong authentication is in place for access to financial systems

If False, consider pursuing in remediation

If N/A, ask for a note explaining why this is not applicable and a specific date for when this will be reviewed for applicability


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