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SSAE 16 Type I Report Background Information

There are significant differences between a Type I and Type II report, however, we aren’t going to discuss that here, thats for another day. We will discuss the basics of a SSAE 16 Type I Report and some areas that should be focused on if this is the direction your company wants to take.

While the Type I Report doesn’t carry much weight, there are benefits, and that’s why it exists as an option. A Type I Report is specifically defined by the SSAE 16 guidance as a “report on a description of a service organization’s system and the suitability of the design of controls”, essentially, a determination of if your company’s controls designed appropriately. When performing a Type I report, the auditors will test the design effectiveness of your company’s defined controls by examining a sample of 1 item per control. This provides a user organization with some comfort that your company (the service organization) has at least some controls in place. This can be useful when trying to obtain a contract and to show good faith to the potential user organization that your company is moving in the right direction. Most user organizations will require a Type II Report before contracting your company as a service organization of theirs.

The Type I Report is made up of 3 major areas, per the SSAE No. 16 Guidance:

a description of the service organization’s system prepared by management of the service organization.

– Management will need to prepare a description of the control objectives that are in place and being tested at their organization, as it relates to the process that is being reviewed for use by a User Organization. This will read sort of like a narrative of the process and how your control objectives tie in to each other and the process as a whole, giving a User Organization an overview of what and how, at a high level, their data will be handled.

a written assertion by the Service Organization’s management about whether, in all material respects, and based on suitable criteria:

1. the description of the service organization’s system fairly presents the service organization’s system that was designed and implemented as of a specified date.
2. the controls related to the control objectives stated in the description were suitably designed to achieve those control objectives as of the specified date.

– Management will need to prepare a written assertion attesting to the fair presentation and design of controls. Previously under SAS 70, it was the auditors who reported directly on the controls and management was not required to attest to anything. (There will be a separate post describing this in detail as this is a major difference)
The final component:

a service auditor’s report that expresses an opinion on the matters in b1-2.

– The auditors that are hired to perform the testing will need to review the Management’s assessment of the design of controls and attest to the validity of Management’s opinion. The auditors will walk through the control objectives and control activities in place at your company and verify they are, in fact, designed as Management noted. This is where the auditors will obtain a sample of 1 to support each control activity and express the results of their testing.

Specifics of reporting details for a SSAE Type I will be discussed later on!

This information is also consistent with SSAE-18 which is effective as of May 1, 2017.

SSAE 16, The New Standard

So you have been performing a SAS 70 for the last couple years, or, are getting ready prepared to embark on your first SAS 70, and all of a sudden you hear that a brand new standard has been issued!

Don’t worry about it!
SSAE 16 is an improvement to the current standard for Reporting on Controls at a Service Organization, the SAS70, with some changes that will help bring your company and the rest of the companies in the US up to date with new international service organization reporting standards, ISAE 3402. This will help allow you and your counterparts in the US be able to compete on an international level, allowing for companies around the world to be able to use YOU as their service organization with complete comfort.
One very important issue that you should be very aware of is that SSAE 16 will formally be issued in June 2010 with an effective date of June 15, 2011, meaning that if you are not on top of this new standard soon, you need to be. Many organizations have a 12 month testing period that begins in July, and if this sounds like your company, you will be required to be compliant with the New Standards as of July 1, 2010.

Major differences between SAS 70 and the New Standard, SSAE 16 and ISAE 3042:

1) Management of the Service Organization will be required to provide the service auditor with a written assertion about the following, when performing either a Type I or Type II engagement, which the service auditor will then attest to:

  • The fairness of the presentation of the description of the service organization’s system;
  • The suitability of the design of the controls to achieve the related control objectives stated in the description; and
  • The operating effectiveness of those controls to achieve the related control objectives stated in the description (Type II Only)

2) During the process of understanding the service organization’s system, the Service Auditor would be required to obtain information that would identify risks that the description of the service organization’s system is not fairly presented or that the control objectives stated in the description were not achieved due to intentional actions by service organization personnel.

Changes that Directly Impact Type II Engagements

1) The Service Auditor’s opinion on the fairness of the presentation of description of the service organization’s system and on the suitability of the design of the controls would be for a full period, as opposed to a specified date. (i.e. Your report would be for the 6 months covering July 2010 through December 2010.)

  • The Type II report would identify the customers to whom use of the report is restricted as “customers of the service organization’s system during some or all of the period covered by the service auditor’s report”

2) Evidence obtained in prior engagements related to the satisfactory operation of controls in prior periods will not be sufficient to reduce the amount of testing performed.

Expected Change Which Didn’t Occur:

While it was expected that SSAE 16 would build upon the previous SAS 70 standard of reporting only on financial reporting activities and allow a service organization to branch out in to other areas of their business, such as regulatory compliance and performance metrics, this was not included within the initial final version of the New Standard and there has been no guidance as to when it would be expected, if ever, to be.

The Previously Expected Change Which Didn’t Occur, Now Has with SSAE-18!

The long awaited update that was needed, but, left unaddressed the during the last update has now been addressed, allowing a service organization to branch out into other areas of their business. This allows coverage of regulatory compliance, performance metrics, and any other set of agreed-upon procedures with definable metrics.

This is a very welcomed enhancement to the standard and service organizations should contact a service provider today to learn more about how SSAE-18 can benefit them.

SSAE-18 reports will be effective for reports issued after May 1, 2017.

SSAE 18 (SSAE 16) Preparation Tips

This tip is focused on designing controls that reflect the process being testing, if they don’t, a headache of massive proportions will be created once testing begins.

What do you do to make sure you don’t screw this up? Have as many meetings as it takes to get it right.
What you need to do is sit down with the auditors, the department lead, the main employees responsible for performing the process, and anyone else whom could either play a role in testing or modifying the control in the future. Once that is done, Management should discuss what they determined the control to be and how it should operate, that is then reviewed by the auditors, and then the employees performing the tasks should be reconsulted to verify that the control still reflects their process accurately.

Many times people try to speed this process up and slack on it, leaving many open items which upon testing could easily blow up into a huge problem. When the control isn’t 100% agreed upon prior to testing and a deviation is noted, it’s a tough call between failing the control and the ability to adjust it to accurately reflect the process. The problem is modifying a control after testing has begun is not proper and needs to be avoided at all costs.

Locking the controls locked down early on could save weeks in wrapping up your new SSAE 16 Report.
We have seen issues like this cause delays in issuing of the report to the client and running additional fees, since adjusting controls isn’t free. Coming from the perspective of the auditor, we can let you know the pitfalls, consequences and how to best navigate the audit process. If you have any comments or questions please leave them below!

Example SSAE 16 Controls – Firewall

Another series we will have periodic posts about will be related to potential controls that would be expected to be in place, almost regardless of the entity in question.
This will be a real basic one to help get everyone up to speed, we will delve into other areas that may be a little more advanced in the future.
Example: Firewalls are in place at all externally facing access points.
The point of this control is to ensure that firewalls are being used at the organization to help prevent hacking attempts, thus, the theft of data. Companies outsourcing their workloads want to have comfort that the company performing the work has adequate security measures in place to lower the chance of their data being stolen.
Firewalls are some of the most basic devices that need to be in place at a business to protect data and if your business does not currently employ firewalls on their network, it is a must do and should be looked into immediately.