Risk of Not Reviewing Your Vendor's SOC Report

Thoroughly reviewing your vendors’ system and organization controls (SOC) reports is a critical due diligence step and a vital component in the initial vendor selection stage and the ongoing monitoring stage. A SOC report is used to help identify any gaps or faults in the vendor’s control environment.

Don’t make the mistake of rushing through this important step, or worse, skipping it altogether. Maybe you received the SOC report but didn’t have a subject matter expert thoroughly analyze it, or maybe you didn’t request it at all. Either way, you’re facing the possibility of great risk and regulatory trouble for your organization.

What’s the Risk of Not Analyzing Your Vendor’s SOC Report?

Reviewing this critical document requires great attention to detail, but it’s a worthwhile effort that provides a lot of value. By neglecting to analyze your vendor’s SOC report, you’re putting your organization at risk for some serious consequences:

• Overlooked Red Flags and Concerns: An important part of any SOC report is to help identify red flags or concerns in your vendor’s control environment. The service auditor’s report section may include words like “inadequate”, “qualified” or “misrepresentation” which are red flags that should be investigated so you can better understand what needs to be done to protect your organization and customers. These issues can only be identified by performing a thorough review of the vendor’s SOC report.
• Missed Key Controls: Failing to review your vendor’s SOC report means that you won’t know whether key controls were identified and audited. Additional evidence might be required if these controls weren’t included.
• Unimplemented Complimentary User Entity Controls: SOC reports will also contain the vendor’s complimentary user entity controls (CUECs ), if applicable. CUECs are the controls that your organization will be expected to implement to help the vendor maintain a secure environment. So, if you neglect to review the SOC report, you won’t be aware of these, and in turn, will also be to blame for not having proper controls in effect.
• Untested controls: Not only is it important to identify what controls are covered in the vendor’s SOC report and if they are tested, but you should also pay attention to what’s NOT in their report. Recognizing gaps in what should be tested is just as important. By not reviewing the report, you’ll be missing this critical information.
• Regulatory Risk: Finally, your organization will be exposed to regulatory risk if you neglect a vendor’s SOC report. Regulatory agencies require that organizations establish and maintain a third-party risk management program , which includes initial due diligence and ongoing management throughout the relationship.

Maintaining a secure environment for your customers is a team effort. Each member of your team, the vendor and their subservice providers play an important role in protecting your organization from unnecessary risk and regulatory trouble. By taking the time and effort to review your vendor’s SOC report, you’ll have a better understanding the vendor’s overall risk profile.