Importance of Complementary User Entity Controls for Vendor Relationships

Sometimes, third-party risk management (TPRM) professionals can forget that implementing vendor controls is often a two-way process. Vendor controls will have certain objectives that are only achievable through something called complementary user entity controls (CUECs). A good way to think of CUECs is by comparing them to the safety features of a car. Seatbelts are designed and manufactured by the car maker with the objective of protecting drivers and passengers. However, this objective can only be met if the seatbelt is being used correctly. The CUEC in this scenario would be the proper use of the seatbelt.

Why Complementary User Entity Controls Are Important

In most cases, the control objectives stated in the description can only be achieved in the correct situation. The CUECs must be suitably designed and operate effectively by your organization and function in combination with the vendor’s controls. If your organization fails to implement the provided CUECs, the vendor's control objectives cannot be accomplished. This essentially means that your organization isn't doing its job in protecting itself from known vendor risks.

In most cases, the control objectives stated in the description can only be achieved in the correct situation. The CUECs must be suitably designed and operate effectively by your organization, and function in combination with the vendor’s controls.

CUECs are documented within a SOC report in different ways, usually depending on the preference of the vendor and the audit firm performing the SOC review.

Where to Find Complementary User Entity Controls in a SOC Report

Below is an overview of where you will find CUECs:

• Specific subsection of the description – You can often find the CUECs listed out in the service description section with details on how exactly they relate to the control objectives laid out in the report.
  
• Tested controls section – You can also find the CUECs within the testing section, where they're usually documented along with the control objectives in which they align.
  
  Of course, finding the CUECs in the report is only part of the battle! Understanding what CUECs mean to your organization is critical because they outline to you (the intended user of the product or service) the roles, responsibilities, and obligations you have in ensuring the stated control objectives are effective for your organization.

You’ve Located the CUECs. Now What?

Simply identifying the CUECs isn’t enough. Part of your vendor risk management process should include mapping these CUECs back to your governance documents. Ask yourself, "Do our internal security controls align with the vendor's expectations?" If so, you can be assured that the CUECs will operate as they should. Not every CUEC will be applicable to your organization, and the qualified individual can help make this determination. After you determine which CUECs are applicable, you can proceed with the following steps: 

• Identify any CUECs already in place – You may discover that some CUECs are already implemented within your processes. If so, consider that an easy win!
• Assign to the appropriate role – The CUECs should be assigned to a specific person, team, or role within your organization to ensure that they’re always covered. 
• Document how the CUECs are addressed – It’s essential to document certain details about the CUECs for future reference and reporting. Make sure to document whether the CUEC is similar to an existing control, who is responsible for the control, and the frequency of the control’s testing.
• Reassess CUECs as needed – CUECs may change after the initial review, so you’ll need to reassess them when you receive a new SOC report or when your organization experiences any significant changes. 

CUECs are just another reminder that third-party risk management involves many shared responsibilities between your organization and your vendors. Your vendors may be responsible for defining its control objectives, but your organization must do its part by effectively implementing the CUECs.