Importance of Complementary User Entity Controls

Video Transcript

Welcome to this week’s Third Party Thursday! My name is Des Ericksen and I’m the Senior Information Security Specialist here at Venminder. Today we are going to talk about Complementary User Entity Controls and why they are important to your organization. 

First, what are Complementary User Entity Controls? 

Also called CUE controls, these controls are a critical component of any SOC Report, as they illustrate to the intended user that the organization has certain roles, responsibilities and obligations in helping the service organization achieve the control objectives stated in the description of the system.

So, exactly what does this mean to you and your organization?

This means that your organization is responsible for reviewing and implementing all applicable controls. Ultimately, your organization plays an active part in supporting the operating effectiveness of your vendor. Without implementing the Complimentary User Entity (CUE) Controls, the service organization’s controls will not operate as intended, thus potentially producing material weaknesses. 

So what do you do with Complementary User Entity Controls? 

First – review your service organization’s SOC reports for a list of Complementary User Entity Controls and list them by vendor and product. 

Secondly - has the Complementary User Entity Controls been implemented? For example, a common control is: User entities should establish controls to supervise, manage and monitor the use of vendor’s services by user entity personnel. Access to subsystems and sensitive transactions is granted and restricted to authorized individuals. 

Are you regularly reviewing who has access to your system internally? 
Are you documenting these access reviews? 
Is there are process for adding, removing or modifying a users access?

Finally - who is responsible for monitoring the Complementary User Entity Controls? 

Using the same example as before...

Has Senior Management established guidance on the access review process? 
Are the results of the reviews being provided to senior management?
Has someone in your organization been assigned the task of verifying that these controls are being monitored?

Please note that not all SOC reports require a list of Complementary User Entity Controls. But understanding Complementary User Entity Controls and why they are important to your organization is just one piece of the vendor management process. 

The security of your vendor does not entirely rest on your vendor’s shoulders, it is up to your organization to assist them in meeting their control objectives by implementing the Complementary User Entity Controls, thus creating a secure environment.

Again, I’m Des and thank you for watching! Don’t forget to subscribe to the Third Party Thursday series.