The AICPA’s Assurance Services Executive Committee (ASEC) recently released an exposure draft, proposing revisions of the Trust Services Criteria (TSC) for Security, Availability, Processing Integrity, Confidentiality, and Privacy. The changes will take effect for SOC 2 reports that are published after June 15, 2018. Even though the changes won’t take effect until 2018, service organizations should start planning for the changes now to ensure that their internal controls are appropriate to meet the new Trust Services Criteria. The following summarizes the most significant changes that will take place as a result of the changes:
Renames the Trust Services Principles and Criteria. The COSO 2013 framework uses the term principles to refer to the elements of internal control. To avoid confusion, the Trust Services Principles and Criteria will remove the term Principles and will be renamed as the Trust Services Criteria. In addition, the five principles (Security, Availability, Processing Integrity, Confidentiality, and Privacy) will now be referred to as the Trust Services Categories.
Restructures and aligns the TSC with the COSO 2013 framework. This is a significant change that will most likely require service organizations to restructure their controls. Service organizations will have to ensure that their controls meet the 17 principles in the COSO 2013 framework and the additional supplemental criteria noted below.
Restructures and adds supplemental criteria to better address cybersecurity risks in engagements using the TSC. In addition to the 17 principles in the COSO 2013 framework, new supplemental criteria were developed and organized into the following categories:
Logical and physical access controls. The TSC relevant to how an entity restricts logical and physical access, provide and removes that access, and prevents unauthorized access.
System operations. The TSC relevant to how an entity manages the operation of system(s) and detects and mitigates processing deviations, including logical and physical security deviations.
Change management. The TSC relevant to how an entity identifies the need for changes, makes the changes using a controlled change management process, and prevents unauthorized changes from being made.
Risk mitigation. The TSC relevant to how an entity identifies, selects, and develops risk mitigation activities and how the entity assesses and manages risks associated with vendors and business partners.
Adds points of focus to all TSC. The points of focus may assist management and the practitioner in evaluating whether the controls are suitably designed and operating effectively; however, use of the TSC does not require management or the practitioner to separately assess whether points of focus are addressed.
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Material discussed is meant for informational purposes only, and it is not to be construed as investment, tax, or legal advice. Please note that individual situations can vary. Therefore, this information should be relied upon when coordinated with individual professional advice.