With the June 15, 2011 implementation deadline now here, service organizations must address the new requirements imposed by Statement on Standards for Attestation Engagements (SSAE) 16. One such requirement is that management identifies the risks that threaten the achievement of the control objectives stated in the description of the service organization’s system.
While SSAE 16 states that this process may be formal or informal, as a best practice and to ensure that all such risks have been identified, management of service organizations should strongly consider implementing a formal process to document the identification of these risks. Such a process would address the points in processing, recording, and reporting customer information and transactions where something could go wrong, and identifying the controls that the service organization has implemented to prevent or detect the “what could go wrongs” from occurring.
By using a formal risk assessment process, service organization management will have documentation in place to support the management assertion required by SSAE 16. In addition, the risk assessment documentation would highlight any unmitigated risks. A formal process would allow service organization management to evaluate whether the unmitigated risks could result in undesirable or even detrimental effects to the service organization or its customers. In addition, it will give them the opportunity to take the appropriate measures to address unmitigated risks before they become the Achilles’ heel for the service organization and its customers.
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