Compliance Framework Alignment
SOC 2 — CC4.1 (ongoing and separate evaluations; COSO Principle 16) SOC 2 — CC4.2 (evaluate and communicate control deficiencies; COSO Principle 17) This document is a configurable template intended to help you author an internal policy; it is not a certification, an audit opinion, or professional compliance advice, and it should be reviewed by a qualified assessor before reliance.
ACME TECHNOLOGIES PVT LTD CONTINUOUS CONTROL MONITORING & DEFICIENCY MANAGEMENT POLICY
Effective Date [Effective Date]
Policy Owner Head of Compliance / GRC Lead (Chief Information Security Officer )
Reporting Body Risk & Compliance Committee
Classification Internal — Governance, Risk & Compliance 1. Purpose and Scope
This policy establishes how Acme Technologies Pvt Ltd continuously monitors the design and operating effectiveness of its internal controls, identifies control deficiencies, classifies them by severity, and drives them to remediation. It operationalises the monitoring feedback loop required by SOC 2 CC4.1 and CC4.2 (COSO Principles 16 and 17), under which the organisation must perform ongoing and separate evaluations to confirm that controls are present and functioning, and must evaluate and communicate identified deficiencies to the parties responsible for corrective action. The policy applies to all controls within the SOC 2 audit boundary — including controls over security, availability, confidentiality, processing integrity, and privacy where in scope — and to every business unit, system owner, and third party whose activities support those controls.
2. Monitoring Approach: Ongoing and Separate Evaluations
The organisation adopts a layered monitoring model combining ongoing automated monitoring with periodic separate evaluations, consistent with CC4.1. Ongoing monitoring is embedded in day-to-day operations through automated control checks — configuration drift detection, access-review reminders, log and alert correlation, vulnerability scanning, and a continuous control monitoring (CCM) platform that tests defined controls on a scheduled basis and raises exceptions in near real time. Separate evaluations are conducted independently of routine operations and include periodic manual control testing, internal audit assessments, penetration tests, and independent third-party assessments such as the SOC 2 examination itself. Neither layer replaces the other: automated monitoring provides breadth and frequency, while separate evaluations provide independent, judgement-based assurance over control design and the reliability of the automated evidence.
3. Control Inventory and Ownership
A central control inventory is maintained that maps each control to its Trust Services Criteria reference, the risk it mitigates, its designated control owner, its testing method (automated or manual), and its monitoring frequency. Every control has a single accountable owner responsible for the control operating as designed and for producing evidence on request. The Chief Information Security Officer owns the inventory as a whole and reviews it at least annually and whenever a material change to systems, processes, or the risk landscape occurs, so that new or changed controls are brought under monitoring without delay.
4. Control Testing Cadence by Risk
The frequency of separate evaluations is risk-based: controls that protect customer data, authentication, or the integrity of production systems are tested more frequently than lower-risk administrative controls. The table below sets the minimum testing cadence by control risk tier. Automated monitoring may run continuously regardless of tier, but the cadence below defines the minimum interval for a documented, evidenced test.
Control risk tier Examples Automated monitoring Minimum manual test Critical Access provisioning, encryption, production change control, backup restoration Continuous Quarterly High Logging & alerting, vulnerability management, vendor access Continuous / daily Semi-annually Moderate Security awareness, asset inventory, capacity monitoring Weekly / monthly Annually Low Documentation upkeep, periodic policy attestation Monthly Annually
5. Deficiency Identification
A control deficiency exists whenever a control is missing, is not designed to meet its objective, or is not operating as designed. Deficiencies may surface from any monitoring source: an automated exception raised by the CCM platform, a failed manual test, an internal audit finding, a penetration-test result, a security incident or near-miss, a customer or regulator query, or a self-reported gap. All suspected deficiencies are logged centrally on identification, with the detection date, source, affected control(s), and a description of the observed condition captured before any triage. No deficiency is closed informally; every item entered into the register follows the lifecycle defined in this policy.
6. Deficiency Classification (Severity)
Each deficiency is assigned a severity based on the significance of the affected control, the sensitivity of the data or systems exposed, the likelihood of the control failing when relied upon, and whether compensating controls reduce the residual risk. Severity determines the remediation timeline and the level of management to which the deficiency is escalated. Severity is assigned by the Chief Information Security Officer (or delegate) at triage and may be revised as more information becomes available.
Severity Definition Remediation due within Escalation Critical Failure of a key control protecting customer data or production integrity; no effective compensating control 30 days Risk & Compliance Committee and executive leadership on identification High Significant control weakness with limited or partial compensating controls 90 days Chief Information Security Officer ; summarised to Risk & Compliance CommitteeMedium Isolated or lower-impact weakness with effective compensating controls 180 days Control owner; tracked in periodic reporting Low Minor or administrative gap with negligible residual risk Next review cycle Control owner
7. Remediation Tracking, Owners, and Due Dates
For every deficiency, a remediation plan is recorded in the deficiency register that names a single accountable remediation owner, describes the corrective action, and sets a target due date derived from the severity timeline in Clause 6. Remediation owners provide status updates at a frequency proportionate to severity, and any request to extend a due date must be justified in writing, capture the revised date and interim risk-reduction measures, and be approved by the Chief Information Security Officer . A deficiency is only closed once the corrective action has been implemented and the control has been re-tested and evidenced as operating effectively; the register retains the detection date, assignment date, closure date, and re-test evidence to demonstrate timely resolution.
Register field Purpose Deficiency ID Unique, traceable reference Affected control(s) & TSC ref Links the gap to CC4 monitoring scope Source & detection date Records how and when it was found Severity Drives timeline and escalation path Remediation owner Single accountable person for the fix Corrective action & due date Defines the plan and deadline Status & re-test evidence Tracks progress and validates closure
8. Escalation and Communication to Management
In line with CC4.2 (COSO Principle 17), deficiencies are communicated to the parties responsible for taking corrective action and, where warranted by severity, escalated to senior management and the Risk & Compliance Committee. Critical deficiencies are escalated on identification rather than at the next scheduled review. The Chief Information Security Officer presents a consolidated monitoring report to the Risk & Compliance Committee on a regular cadence covering open deficiencies by severity, ageing against due dates, overdue items, and remediation trends. Any deficiency assessed as potentially material to the reliability of controls relied upon by customers is escalated to executive leadership and, where applicable, considered for disclosure in the SOC 2 report and in communications to affected stakeholders.
9. Linkage to Internal Audit and Independent Assessment
Internal audit performs separate evaluations that are independent of control owners and management of the monitored process, providing objective assurance over both control effectiveness and the reliability of the ongoing monitoring itself. Internal audit findings feed the same deficiency register and severity model as automated and self-identified issues, so that all sources converge on a single view of control health. Findings from independent external assessments — including the SOC 2 examination, penetration tests, and, where applicable, ISO 27001 audits — are likewise recorded, classified, tracked to closure, and reported to the Risk & Compliance Committee through this policy's process.
10. Linkage to the CAPA Register
Where a deficiency reflects a systemic or recurring weakness rather than an isolated lapse, a Corrective and Preventive Action (CAPA) entry is raised in addition to the immediate remediation task. The CAPA record captures root-cause analysis, the corrective action that resolves the specific instance, and the preventive action that reduces the likelihood of recurrence. The deficiency register and the CAPA register are cross-referenced so that a monitoring exception can be traced to its root-cause treatment, and a CAPA is not closed until effectiveness has been verified through subsequent monitoring or re-testing.
11. Metrics and Reporting
The organisation tracks monitoring and remediation metrics to demonstrate that the control environment is being evaluated and improved over time. Reported metrics include the count of open deficiencies by severity, mean time to remediate by severity, percentage of remediations closed within the required timeline, count of overdue items, coverage of the control inventory by automated monitoring, and the volume and status of linked CAPAs. These metrics are reviewed by the Risk & Compliance Committee and used to prioritise investment in control automation and process improvement.
12. Roles and Responsibilities
Control owners operate their controls, produce evidence, and remediate assigned deficiencies. The Chief Information Security Officer owns the control inventory, the deficiency register, severity classification, and monitoring reporting. Internal audit performs independent separate evaluations. Remediation owners execute corrective actions by the due date. The Risk & Compliance Committee provides oversight, reviews monitoring results, and holds owners accountable for timely closure. Executive leadership ensures the monitoring function is adequately resourced and acts on escalated or material deficiencies.
13. Policy Review and Exceptions
This policy is reviewed at least annually and after any significant change to the organisation's systems, obligations, or risk profile. Exceptions to this policy must be formally requested, risk-assessed, time-bound, and approved by the Chief Information Security Officer , with each exception recorded and reviewed on expiry. Non-compliance with this policy may result in remedial action up to and including disciplinary measures in accordance with the organisation's applicable procedures.
Approved by
Head of Compliance / GRC Lead
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Reviewed by
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