Doing Business with Microsoft? Privacy Protection is Key

Date September 9, 2019
Authors HBK CPAs & Consultants

Microsoft executives take security and privacy initiatives seriously. Not just their own, but those of their vendors, as well.

Microsoft is committed to Vendor Risk Management (VRM). Suppliers and business partners are often required to undergo varying levels of attestation to their information security initiatives, including SOC 2 or Microsoft’s Supplier Security and Privacy Assurance (SSPA).

Microsoft has established data protection requirements (DPRs) for suppliers who process Microsoft personal or confidential data. More often than not, suppliers must undergo annual attestation as to their ability to meet the requirements defined in Microsoft’s DPR.

“Process” in Microsoft’s DPR refers to any operation or set of operations performed on any Microsoft personal data or confidential data—and whether or not operations are by automated means. Processes include collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission or dissemination, and alignment or combination, restriction, and erasure or destruction.

SSPA is a Microsoft program that involves not only making sure that suppliers understand these requirements but ensuring their compliance. The program combines Microsoft Procurement, Corporate External and Legal Affairs, and Corporate Security to make certain that suppliers follow privacy and security principles when processing Microsoft personal data or Microsoft confidential data. It covers all global suppliers processing Microsoft personal or confidential data.

Suppliers considered high risk are required to provide independent verification of DPR compliance. Such companies are asked to select an independent auditor affiliated with the American Institute of CPAs (AICPA) or the International Association of Privacy Professionals to assess DPR compliance; that auditor is responsible for providing an unqualified letter of attestation to the Microsoft SSPA.

At HBK, our affiliation with the AICPA is merely one aspect of our capabilities. Our auditors have years of experience performing attestation engagements, including extensive SOC 2 work. We have intimate knowledge of security and privacy best practices and hold these critical credentials: Certified Information Systems Security Professional (CISSP) and Certified Information Systems Auditor (CISA).

Most importantly, we are experienced in navigating businesses through Microsoft’s SSPA and compliance with the company’s Data Protection Requirements.

We can help you if Microsoft is on your business horizon and you want to maximize the value of these efforts–or if you’re preparing for a security audit. Call us at 724.934.5300 or email me at MSchiavone@hbkcpa.comand let’s get started.

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Are You Cyber Secure and Who Wants to Know?

Date January 2, 2019
Authors HBK CPAs & Consultants

This is an update to the original INSIGHT article Are You Cyber Secure?, which was published in July 2017.

System and Organization Controls 1 or SOC 1 (SOC) report provides assurance over controls at a service organization which are relevant to user entities’ internal control over financial reporting. Obtaining a SOC for Cybersecurity report can prove that a cybersecurity risk management program is designed and functioning effectively. It can also reassure everyone a member of a board of directors to a potential customer that information with which your company has been entrusted is being handled in accordance with cybersecurity best practices.

No matter your business or industry, cybersecurity is a concern. If you operate in cyberspace – and what business doesn’t? – you are vulnerable. To guard against the many risks ranging from exposure of confidential information to loss of business reputation, every organization should have a cybersecurity risk management program. However, conveying the maturity of your risk management program to stakeholders is a challenge that needs overcome.

To meet that need the American Institute of Certified Public Accountants (AICPA), the certification and standards organization governing the practice of accounting, has introduced Systems and Organization Controls (SOC) for Cybersecurity. Building upon the profession’s experience in auditing system and organization controls, SOC for Cybersecurity enables CPAs to examine and report on an organization’s cybersecurity risk management program.

HBK CPAs & Consultants (HBK) has been performing SOC 1 and SOC 2 attestations since they replaced the SAS 70 report in 2010. In the area of SOC for Cybersecuity, we offer management two types of assurance services, advisory and attestation.

In an advisory role, we perform a readiness assessment, which helps businesses assess their cybersecurity program against the industry’s leading frameworks, and more appropriately, against the AICPA Cybersecurity criteria. We assist with identifying gaps in the framework and remediating those gaps to further develop or implement an effective cybersecurity program. For more established programs, we help organizations formally align the existing program with the three criteria as established by the AICPA:

Security – The system is protected, both logically and physically, against unauthorized access.

Availability – The system is available for operation and use

Confidentiality – Information designated as confidential is protected as committed or agreed

In an attestation engagement, we examine your cybersecurity program and provide an opinion on whether it is effective. We map your controls to ensure your program complies with the AICPA-established criteria. We review your description of how those criteria are accommodated, then test and validate the effectiveness of these controls and issue a report.

A cybersecurity risk management examination report includes the following three key components:

Management’s description of the entity’s cybersecurity risk management program. The first component is a management-prepared narrative description of its cybersecurity risk management program, The report provides information on how the company identifies its information assets, how it manages the cybersecurity risks that threaten it, and the policies and processes implemented and operated to protect its information assets against those risks.

Management’s assertion. The second component is an assertion provided by management that the description is presented in accordance with the description criteria and the controls within the company’s cybersecurity risk management program achieve its cybersecurity objectives.

Practitioner’s report. The third component is a practitioner’s report, which contains an opinion on whether management’s description is presented in accordance with the description criteria and the controls within the company’s cybersecurity risk management program achieve its cybersecurity objectives.

Our attestation is justification management can use to demonstrate to everyone from the board of directors to a potential customer that their cybersecurity program is in accordance with best practices. The AICPA logo of SOC Cybersecurity certification is a key differentiator for a business, assuring stakeholders the security of the information they handle.

All organizations should have a cybersecurity program in place. Having it assessed for readiness, that is, ensuring your controls are aligned with the AICPA-defined standard and criteria, will afford assurance that it is designed appropriately. Receiving official attestation demonstrates the design is functioning as it should, and only makes sense in providing a level of confidence to your stakeholders that you are a business that has implemented a robust and comprehensive cybersecurity program, that your organization is cyber secure.

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