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Controls

Every Trust Services Criteria control in scope. Click a row for the detailed test plan, evidence list, and review history.

Status
Category
CodeCategoryTitleStatusOwnerEvidenceReviewed
CC1.1SecurityDemonstrates commitment to integrity and ethical values

The entity demonstrates a commitment to integrity and ethical values through its tone at the top, code of conduct, and disciplinary processes.

ImplementedCEO432d
CC1.2SecurityBoard exercises oversight responsibility

The board of directors demonstrates independence from management and exercises oversight of the development and performance of internal control.

ImplementedCEO365d
CC1.3SecurityEstablishes structure, authority, and responsibility

Management establishes structures, reporting lines, and authorities and responsibilities in pursuit of objectives.

ImplementedCOO288d
CC1.4SecurityDemonstrates commitment to competence

The entity demonstrates a commitment to attract, develop, and retain competent individuals in alignment with objectives.

PartialVP People241d
CC1.5SecurityEnforces accountability

The entity holds individuals accountable for their internal control responsibilities in the pursuit of objectives.

ImplementedVP People2110d
CC2.1SecurityObtains or generates relevant, quality information

The entity obtains or generates and uses relevant, quality information to support the functioning of internal control.

ImplementedDirector, Security324d
CC2.2SecurityInternal communication of objectives and responsibilities

The entity internally communicates information, including objectives and responsibilities for internal control, necessary to support the functioning of internal control.

ImplementedDirector, Security217d
CC2.3SecurityExternal communication with relevant parties

The entity communicates with external parties regarding matters affecting the functioning of internal control.

PartialVP Engineering1195d
CC3.1SecuritySpecifies suitable objectives

The entity specifies objectives with sufficient clarity to enable the identification and assessment of risks relating to objectives.

ImplementedDirector, Security251d
CC3.2SecurityIdentifies and assesses risk

The entity identifies risks to the achievement of its objectives across the entity and analyzes risks as a basis for determining how the risks should be managed.

PartialDirector, Security373d
CC3.3SecurityConsiders fraud in risk assessment

The entity considers the potential for fraud in assessing risks to the achievement of objectives.

Not implementedDirector, Security0210d
CC3.4SecurityIdentifies and assesses changes

The entity identifies and assesses changes that could significantly impact the system of internal control.

ImplementedVP Engineering412d
CC4.1SecurityPerforms ongoing and separate evaluations

The entity selects, develops, and performs ongoing and/or separate evaluations to ascertain whether the components of internal control are present and functioning.

ImplementedDirector, Internal Audit519d
CC4.2SecurityCommunicates and remediates deficiencies

The entity evaluates and communicates internal control deficiencies in a timely manner to those parties responsible for taking corrective action.

PartialDirector, Internal Audit247d
CC5.1SecuritySelects and develops control activities

The entity selects and develops control activities that contribute to the mitigation of risks to the achievement of objectives to acceptable levels.

ImplementedDirector, Security360d
CC5.2SecuritySelects and develops technology controls

The entity also selects and develops general control activities over technology to support the achievement of objectives.

ImplementedVP Engineering428d
CC5.3SecurityDeploys policies and procedures

The entity deploys control activities through policies that establish what is expected and procedures that put policies into action.

ImplementedDirector, Security336d
CC6.1SecurityLogical access security software, infrastructure, and architectures

The entity implements logical access security software, infrastructure, and architectures over protected information assets.

ImplementedVP Engineering59d
CC6.2SecurityUser registration and authorization

Prior to issuing system credentials and granting system access, the entity registers and authorizes new internal and external users.

ImplementedVP Engineering414d
CC6.3SecurityRemoves access for terminated users

The entity authorizes, modifies, or removes access to data, software, functions, and other protected information assets based on roles, responsibilities, or the system design and changes.

PartialVP Engineering222d
CC6.4SecurityRestricts physical access

The entity restricts physical access to facilities and protected information assets to authorized personnel.

N/ADirector, Facilities0
CC6.5SecurityDiscontinues physical protections after use

The entity discontinues logical and physical protections over physical assets only after the ability to read or recover data and software has been diminished and is no longer required.

ImplementedVP Engineering295d
CC6.6SecurityImplements logical access security measures against threats

The entity implements logical access security measures to protect against threats from sources outside its system boundaries.

ImplementedDirector, Security48d
CC6.7SecurityRestricts the transmission, movement, and removal of information

The entity restricts the transmission, movement, and removal of information to authorized internal and external users and processes, and protects it during transmission, movement, or removal.

PartialDirector, Security254d
CC6.8SecurityPrevents or detects unauthorized or malicious software

The entity implements controls to prevent or detect and act upon the introduction of unauthorized or malicious software to meet the entity's objectives.

ImplementedDirector, Security316d
CC7.1SecurityDetects and monitors changes that could introduce vulnerabilities

To meet its objectives, the entity uses detection and monitoring procedures to identify changes to configurations that result in the introduction of new vulnerabilities, and susceptibilities to newly discovered vulnerabilities.

ImplementedVP Engineering321d
CC7.2SecurityMonitors system components and the operation of those components

The entity monitors system components and the operation of those components for anomalies that are indicative of malicious acts, natural disasters, and errors affecting the entity's ability to meet its objectives.

ImplementedDirector, Security46d
CC7.3SecurityEvaluates security events to determine response

The entity evaluates security events to determine whether they could or have resulted in a failure of the entity to meet its objectives, and, if so, takes actions to prevent or address such failures.

PartialDirector, Security238d
CC7.4SecurityResponds to identified security incidents

The entity responds to identified security incidents by executing a defined incident response program to understand, contain, remediate, and communicate security incidents.

PartialDirector, Security1188d
CC7.5SecurityRecovers from identified security incidents

The entity identifies, develops, and implements activities to recover from identified security incidents.

Not implementedDirector, Security0220d
CC8.1SecurityAuthorizes, designs, develops, configures, documents, tests, approves, and implements changes

The entity authorizes, designs, develops or acquires, configures, documents, tests, approves, and implements changes to infrastructure, data, software, and procedures to meet its objectives.

ImplementedVP Engineering511d
CC9.1SecurityIdentifies, selects, and develops risk mitigation activities

The entity identifies, selects, and develops risk mitigation activities for risks arising from potential business disruptions.

PartialCOO278d
CC9.2SecurityAssesses and manages risks associated with vendors and business partners

The entity assesses and manages risks associated with vendors and business partners.

PartialDirector, Procurement264d
A1.1AvailabilityMaintains, monitors, and evaluates current processing capacity

The entity maintains, monitors, and evaluates current processing capacity and use of system components to manage capacity demand and to enable the implementation of additional capacity to help meet its objectives.

ImplementedVP Engineering318d
A1.2AvailabilityAuthorizes, designs, develops, implements, operates, approves, maintains, and monitors environmental protections, software, data backup, and recovery infrastructure

The entity authorizes, designs, develops or acquires, implements, operates, approves, maintains, and monitors environmental protections, software, data backup processes, and recovery infrastructure to meet its objectives.

PartialVP Engineering344d
A1.3AvailabilityTests recovery plan procedures supporting system recovery

The entity tests recovery plan procedures supporting system recovery to meet its objectives.

Not implementedVP Engineering0198d
C1.1ConfidentialityIdentifies and maintains confidential information

The entity identifies and maintains confidential information to meet the entity's objectives related to confidentiality.

ImplementedDirector, Security242d
C1.2ConfidentialityDisposes of confidential information

The entity disposes of confidential information to meet the entity's objectives related to confidentiality.

PartialDirector, Security1105d
PI1.1Processing IntegrityObtains or generates, uses, and communicates information about processing

The entity obtains or generates, uses, and communicates relevant, quality information regarding the objectives related to processing, including definitions of data processed and product and service specifications, to support the use of products and services.

ImplementedVP Product230d
PI1.2Processing IntegrityInputs are complete, accurate, and authorized

The entity implements policies and procedures over system inputs, including controls over completeness and accuracy, to result in products, services, and reporting to meet the entity's objectives.

PartialVP Engineering249d
PI1.3Processing IntegritySystem processing is complete, valid, accurate, timely, and authorized

The entity implements policies and procedures over system processing to result in products, services, and reporting to meet the entity's objectives.

ImplementedVP Engineering325d
PI1.4Processing IntegrityOutputs are complete, accurate, distributed, and retained

The entity implements policies and procedures to make available or deliver output completely, accurately, and timely in accordance with specifications to meet the entity's objectives.

PartialVP Engineering171d
PI1.5Processing IntegrityStores inputs, items in processing, and outputs completely, accurately, and timely

The entity implements policies and procedures to store inputs, items in processing, and outputs completely, accurately, and timely in accordance with system specifications to meet the entity's objectives.

Not implementedVP Engineering0185d