The Audit Management Process is a critical control that ensures organizations have a well-defined approach for planning, executing, and reviewing security audits. By implementing a robust audit process, companies can identify and remediate security weaknesses before they lead to data breaches or compliance violations. A proper audit management process is the foundation of a strong security posture.

Where did this come from?

This control comes from the CSA Cloud Controls Matrix v4.0.10 - 2023-09-26. You can download the full matrix here. The CCM provides a comprehensive set of cloud security controls mapped to various industry standards. For more background on the audit process, check out this AWS documentation.

Who should care?

Several roles should be concerned with the Audit Management Process:

• Chief Information Security Officers (CISOs) responsible for overseeing the organization's security program
• Governance, Risk, and Compliance (GRC) managers tasked with ensuring the company meets its compliance obligations
• Internal and external auditors who need a structured methodology for assessing security controls
• Security engineers who must implement the technical controls being audited

What is the risk?

Without a well-defined Audit Management Process, organizations may fail to identify critical security gaps. This could lead to:

• Data breaches resulting in customer PII exposure and reputational damage
• Compliance violations and steep regulatory fines (e.g. GDPR, HIPAA)
• Unidentified insider threats and privilege misuse
• Inconsistent security control implementation across the environment

While audits alone can't prevent incidents, they are crucial for surfacing issues and driving remediation efforts. A risk-based audit plan maximizes impact to security posture.

What's the care factor?

CISOs and GRC managers should prioritize the Audit Management Process for several reasons:

1. Audits are required for compliance with frameworks like SOC 2, ISO 27001, PCI DSS, etc. Inconsistent auditing can lead to failed assessments.
2. Proactive internal audits help identify issues before external auditors or attackers find them. Remediation is easier when you control the timeline.
3. A repeatable audit process saves time and demonstrates security maturity to customers and partners. Point-in-time audits provide less assurance.

While audits require effort, they are a necessary and worthwhile investment in security. Organizations with strong audit practices suffer fewer breaches and handle incidents better when they do occur.

When is it relevant?

An Audit Management Process is relevant for:

• Organizations subject to compliance requirements (SOC 2, HIPAA, GDPR, etc.)
• Companies spanning multiple cloud accounts, environments, and regions
• Businesses pursuing FedRAMP, HITRUST or other stringent certifications
• Enterprises with significant cloud usage and attack surface

It may be less critical for:

• Small businesses with limited IT infrastructure and compliance needs
• Startups still developing their security program and policies
• Organizations at low risk of cyber attacks based on data and industry

However, all organizations benefit from some level of security auditing. The formality and frequency of the process can scale with company size and risk profile.

What are the trade-offs?

Implementing an Audit Management Process does involve costs and trade-offs:

• Staff time to plan audits, coordinate stakeholders, and manage remediation
• Engaging third-party audit firms which can be expensive
• Disruption to engineers during evidence collection and control testing
• Opportunity costs of focusing on audits over feature development

Organizations must strike the right balance, satisfying compliance and security needs without over-burdening teams. Automation can help by streamlining evidence collection and control testing.

How to make it happen?

Here's a high-level process for implementing CCM Control A&A-05:

1. Define an audit charter outlining the mission, scope, and authority of the audit function. Have the CISO and other execs formally approve it.
2. Identify compliance requirements and map them to the relevant security controls. Review CCM, NIST 800-53, ISO 27001, etc.
3. Develop a risk-based audit plan defining the audits to be performed, their frequency, and objectives. Consider factors like regulatory requirements, past audit results, and changes to the environment.
4. Assign roles and responsibilities for audit activities. Designate audit owners, control owners, and evidence collectors. Ensure separation of duties between auditors and auditees.
5. Establish secure evidence collection and storage processes. Use encryption for data at-rest and in-transit. Restrict access based on least privilege.
6. Perform audits by examining policies, interviewing staff, and testing controls. Document results and map issues to specific requirements.
7. Deliver audit reports to stakeholders. Include an executive summary, detailed findings, and recommended remediation actions.
8. Track remediation plans and report on progress. Validate fixes in subsequent audits.
9. Retain audit documentation per your data retention policy. Review past reports as input into future audit planning.
10. Continuously improve the audit process based on lessons learned and changes to requirements/environment.

Some key AWS services to enable this process:

• AWS Audit Manager - automate evidence collection and map to compliance frameworks
• AWS Security Hub - continuously assess security posture and identify top risks
• AWS KMS - encrypt audit data and control access to keys
• Amazon S3 - store audit evidence with tight access controls and encryption

What are some gotchas?

A few things to watch out for when implementing an Audit Management Process:

• Ensure auditors have the necessary access to collect evidence and test controls. This may require adding them to IAM roles/groups with read permissions like security-audit across target accounts.
• Implement controls to prevent tampering of audit logs (e.g. CloudTrail, AWS Config). Enable log file validation and integrate with a SIEM. Restrict DeleteLogStream and similar permissions.
• Coordinate audit schedules with application teams to minimize disruption. Testing some controls may require temporarily taking systems offline or modifying settings.
• Don't expect a "perfect" set of controls initially. Auditing often surfaces legacy issues and technical debt. Use a risk-based approach to prioritize remediation.
• Review the latest version of compliance standards for changes in requirements. For example, new ISO 27001 controls are added periodically.

What are the alternatives?

Some alternatives or complements to a traditional Audit Management Process:

• Automated compliance scanning tools like AWS Security Hub, Prowler, Scout Suite
• Continuous controls monitoring using AWS Config rules and Lambda functions
• Red team exercises and penetration tests to identify weaknesses proactively
• Bug bounty programs engaging external researchers to find vulnerabilities
• Threat modeling during application design to "build security in"
• Implementing a formal Risk Management Framework (RMF)

The best approach combines detective, preventive, and corrective controls across the software development lifecycle. Audits are just one component of a defense-in-depth strategy.

Explore further

• CSA Cloud Controls Matrix (CCM) - Overview
• CCM v4 control ID A&A-05 - Detail page
• ISO 27001:2013 control ID A.12.7 - Auditing Information Systems
• CIS AWS Foundations Benchmark v1.5.0 - Security Checklist
• AWS Config Conformance Packs for CIS Benchmarks - Documentation
• AWS Audit Manager User Guide - Documentation
• NIST 800-53 control ID AU-2 - Audit Events / Logging Monitoring
• PCI DSS 3.2.1 Requirement 10 - Track and monitor all access to cardholder data
• HIPAA Section 164.312(b) - Audit Controls