RA-01: Internal Control Audits

Control Description

Internal audits that assess the design and operating effectiveness of controls and compare them against the Company's security, availability, confidentiality, processing integrity, and privacy (update as applicable) commitments, requirements, and policies and procedures are performed based on a risk-based assessment plan. Corrections and other necessary actions related to any identified deficiencies, including updates to the Company's policies and procedures, are implemented within the quarter.

Plain Meaning

This control requires regular internal audits to evaluate how well your security controls are working. You must check if your controls are properly designed and operating effectively against your security commitments. When problems are found, you must fix them within three months and update your policies and procedures accordingly.

Implementation: Comprehensive Internal Auditing

Attack-Based Security Audits

We conduct internal audits using attack simulations to test the effectiveness of our security controls and identify potential vulnerabilities in our systems.

Penetration Testing

• Regular Testing: Quarterly penetration testing of critical systems
• Attack Scenarios: Simulated attacks against web applications, APIs, and infrastructure
• Vulnerability Assessment: Automated and manual vulnerability scanning
• Social Engineering: Phishing and social engineering attack simulations

Red Team Exercises

• Realistic Scenarios: Simulate real-world attack scenarios
• Multi-Vector Attacks: Test multiple attack vectors simultaneously
• Incident Response Testing: Evaluate incident response capabilities
• Control Effectiveness: Assess how well controls detect and respond to attacks

Third-Party Dependency Management

Dependency Audits

• Regular Updates: Monthly review and update of third-party dependencies
• Vulnerability Scanning: Automated scanning for known vulnerabilities
• Security Assessment: Evaluate security posture of third-party vendors
• Risk Assessment: Assess risks associated with third-party dependencies

Update Procedures

• Automated Scanning: Continuous monitoring of dependency vulnerabilities
• Patch Management: Prompt application of security patches
• Testing Process: Test updates in staging environment before production
• Rollback Procedures: Ability to rollback problematic updates

Lessons Learned and Problem Reflection

Historical Analysis

• Previous Incidents: Review and analyze previous security incidents
• Root Cause Analysis: Identify underlying causes of past problems
• Control Gaps: Assess where controls failed or were insufficient
• Improvement Tracking: Track improvements made based on past issues

Continuous Improvement

• Process Refinement: Update processes based on lessons learned
• Control Enhancement: Strengthen controls that were previously bypassed
• Training Updates: Update security training based on incident patterns
• Policy Updates: Revise policies and procedures based on findings

Audit Reporting and Remediation

Quarterly Audit Cycle

• Q1: Attack simulation and penetration testing
• Q2: Third-party dependency assessment and updates
• Q3: Lessons learned review and process improvement
• Q4: Comprehensive control effectiveness assessment

Remediation Timeline

• Critical Issues: Immediate remediation (within 24 hours)
• High Priority: Remediation within 2 weeks
• Medium Priority: Remediation within 1 month
• Low Priority: Remediation within 3 months

Related Controls

Risk Assessment

• RA-02: Risk Assessment Procedures: Risk assessment methodologies and procedures
• RA-03: Third-Party Risk Assessment: Third-party vendor risk assessment

Monitoring and Security Scanning

• COM-08: Quarterly Internal Network Scans: Internal security scanning and assessment
• COM-09: Annual External Scanning: External security assessments
• COM-10: Security Event Monitoring: Security event detection and monitoring

Access Management

• LS-04: Access Authorization: Access authorization controls
• LS-05: Access Review: Regular access reviews and audits
• LS-14: Administrative Access Restrictions: Administrative access controls
• LS-16: Encrypted Transmissions: Network security controls

Change Management

• CM-1: Source Code Access Review: Code access security controls
• CM-3: Change Authorization: Change management controls
• CM-4: Change Testing: Change testing and validation

Incident Response

• IR-01: Monthly Incident Review: Incident review and lessons learned
• IR-02: Incident Management Process: Incident response procedures

Third-Party Management

• TPM-01: Third-Party Risk Assessment: Third-party vendor assessment
• TPM-02: Third-Party Access Controls: Third-party access management
• TPM-03: Third-Party Monitoring: Third-party performance monitoring

Security Monitoring and Audit Tools

AWS CloudTrail Event Monitoring

AWS GuardDuty Threat Detection

Related Links

Leadline Architecture Design

• SSDLC Security Practices: Security toolchain, threat modeling, and security testing for risk assessment
• Observability & Monitoring: Monitoring and alerting for risk detection and assessment

Security Resources

• NIST Risk Management Framework
• OWASP Testing Guide