Remote auditing is increasingly becoming a preferred method for conducting cybersecurity assessments. Remote audits are typically more convenient and can help organizations evaluate their security posture much faster than traditional audits. Read on to learn more about how you can conduct virtual audits.
How Can You Conduct Effective Remote Audits?
Virtual auditing is a fast and reliable cybersecurity testing tool from which your organization can benefit. To understand how it works and how it can benefit your organization, we will provide:
- A general overview of remote auditing
- A deep dive into remote auditing for PCI DSS compliance
- A breakdown of virtual audit tools commonly used for remote audits
Whether you are new to remote auditing or looking to optimize current audits, partnering with a managed security services provider (MSSP) will help you achieve a high audit ROI.
What is Remote Auditing?
Cybersecurity audits evaluate the security posture of an organization’s cybersecurity program relative to a defined set of assessment criteria. Although cybersecurity audits are traditionally conducted on-site, remote auditing takes the same processes for on-site audits and tailors them to a virtual audit setting. But, just like on-site audits, virtual audits are meant to be independent, unbiased assessments of your security controls and may be conducted internally or externally.
Why Should You Conduct Remote Audits?
Remote auditing, unlike on-site auditing, provides greater flexibility for assessments. The need for remote audits was more evident during the COVID-19 pandemic, as more organizations looked to virtual auditing to assess their security controls and achieve robust security assurance standards in the midst of quarantine and work-from-home mandates.
You may need to conduct remote audits for several reasons:
- Travel restrictions that prevent access to physical facilities to conduct on-site audits
- Failure to access difficult-to-reach geographic locations
- Operating primarily in a virtual environment with no physical business facilities
- Testing of operational processes does not have to be in-person and on-site
- Shortage of resources to promptly conduct on-site audits
- A strong business need to conduct frequent audits when processing large volumes of sensitive data, especially in industries such as financial services or healthcare
Some of the widely applicable regulatory standards that offer the option to audit remotely are:
- PCI DSS, for organizations that process card payments
- HITRUST CSF, for organizations within and adjacent to the healthcare industry
Conducting remote audits can be just as effective for evaluating your cybersecurity controls as on-site audits. However, you need to assess your business and compliance environment to determine that the remote auditing will comprehensively assess your security controls.
Benefits of Conducting Remote or On-Site Audits
Whether they are conducted on-site or remotely, audits will point out the gaps in the security controls implemented by your organization and help you identify areas needing optimization.
According to ISACA, conducting audits of your cybersecurity infrastructure will help you:
- Identify gaps and vulnerabilities in security controls
- Create baselines for future audits
- Meet the requirements of regulatory compliance standards
- Comply with the requirements of internal security policies
- Evaluate the effectiveness of security training
- Assess cybersecurity resource utilization
Most crucially, security audits should be treated as ongoing processes. Cybersecurity systems are consistently evolving and their effectiveness must be routinely evaluated.
Determining the Scope of a Remote or On-Site Audit
For both remote and on-site audits, it is critical to identify the components in your cybersecurity infrastructure you would like to assess for vulnerabilities. Audits evaluate vulnerabilities in:
- Network security, via the assessment of:
- Email services
- Web applications
- Network transmission protocols
- Systems architecture integrity
- Software systems, via the assessment of:
- Data processing controls
- Software development applications
In some cases, on-site audits might be more feasible than remote audits.
However, it is critical to evaluate the scope of a remote or on-site audit with an experienced MSSP, who can advise on the most applicable audit type for your cybersecurity needs.
Remote Auditing with the PCI DSS Framework
Audits serve as the primary means of assessing an organization’s compliance with regulatory standards. Although most regulatory standards require on-site audits, some frameworks provide the option for organizations to remotely audit their cybersecurity controls.
For example, the Payment Card Industry (PCI) Data Security Standards (DSS) framework allows organizations to conduct remote audits when on-site testing is not feasible. However, organizations participating in PCI DSS remote audits must follow the framework’s virtual audit guidelines, which are critical to developing a virtual audit checklist.
What is the PCI DSS Framework?
The PCI DSS framework helps organizations safeguard cardholder data (CHD). Organizations that store, transmit, or process CHD are required to comply with the 12 PCI DSS Requirements:
- Requirement 1 – Implement network security
- Requirement 2 – Establish secure system controls
- Requirement 3 – Safeguard stored account data
- Requirement 4 – Secure the transmission of CHD over public networks
- Requirement 5 – Safeguard systems and networks from malware
- Requirement 6 – Establish secure systems and software
- Requirement 7 – Prevent unauthorized access to systems and CHD
- Requirement 8 – Implement user access authentication for all systems
- Requirement 9 – Safeguard physical CHD environments
- Requirement 10 – Monitor access to CHD and system components
- Requirement 11 – Conduct routine network and system testing
- Requirement 12 – Develop and implement a PCI security policy
Compliance with the PCI DSS Requirements is critical to mitigating data breaches that can compromise CHD and result in significant legal, financial, and reputational consequences.
Virtual Audit Feasibility Assessment for PCI DSS Compliance
Before considering remote audits of their PCI DSS compliance, organizations must conduct feasibility assessments to ensure that remote auditing tools that will meet testing objectives.
Once an organization has determined that it is not feasible to conduct on-site testing of its cybersecurity controls, it must work with a Security Assessor to identify and implement remote audit best practices. Feasibility assessments can differ but are typically conducted via:
- Documentation reviews – To determine if they provide sufficient information to conduct the audit virtually. Examples of documents to be reviewed include:
- Internal organization security policies
- Proposed and existing training documents
- Acknowledgment of personnel security responsibilities
- Interviews – To determine if they fully understand the policies and procedures that must be implemented to comply with the PCI DSS Requirements.
Per the PCI DSS, virtual audits should only be conducted if a feasibility analysis finds that remote auditing is the most effective way to assess an organization’s security controls.
Conducting a comprehensive and informative feasibility analysis requires an understanding of the various assessment criteria, including:
- People involved in implementing security controls such as:
- IT security teams
- Personnel at each level of the organization
- Management and leadership teams
- Processes used in handling sensitive CHD, including:
- Collection of CHD at payment terminals
- Transmission of CHD internally and externally
- Storage of CHD for legal or business needs
- Disposal of CHD when storage is no longer required
- Technologies used to handle CHD from collection to disposal
For any remote audit, conducting a feasibility assessment will help ensure that all parties involved in the audit are well-prepared for it.
Criteria for a Virtual PCI DSS Feasibility Assessment
Working with a Qualified Security Assessor (QSA), an organization should conduct a remote audit feasibility assessment based on the following criteria:
- The level to which data will be kept confidential and secure during the virtual assessment, ensuring that:
- Requirements for meeting security and confidentiality standards are clearly defined
- Processes for maintaining data sensitivity can be maintained throughout the remote audit
- Availability of the tools used in conducting the remote audit, ensuring:
- Agreement between the assessor and the assessee on the types of technologies used during the assessment
- Personnel are fully trained to comfortably use the assessment technologies and tools
- Presence of a stable online connection for the entirety of the assessment
- The ability of the assessors to access necessary information critical to the success of the remote audit
- Verification of the identity of the personnel participating in the remote audit is possible
- Virtual observation of processes and activities will not be limited
- Availability of personnel participating in the audit, ensuring:
- Personnel are available for interviews with assessors
- Personnel can provide walkthroughs of facilities
- Availability of operational support for virtual assessment, ensuring:
- Personnel have sufficient resources to facilitate a remote audit
- Accuracy in operational representation, should a contingency hinder the normal flow of operations
- Personnel involved in the assessment fully understand its scope
- A comprehensive evaluation of systems and processes is possible
- High-quality and reliable evidence of compliance can be collected
Once a virtual audit feasibility assessment is conducted, an organization can then make the following conclusions:
- The audit can be conducted via:
- Remote tools alone
- On-site tools alone
- Both on-site and remote tools
- Part of the audit may be conducted remotely.
- The audit cannot be conducted remotely.
The outcomes of a remote audit feasibility assessment will then determine the best possible route for conducting an audit. Remote audits may not always be effective and provide the level of security assurance necessary for a security assessor to evaluate an organization’s PCI DSS compliance. Furthermore, both security assessors and the entities being audited should work together to ensure that the remote testing methods are working effectively.
Planning for a PCI DSS Remote Audit
When planning for a remote audit, the assessor conducting the audit and the entity being audited must engage in open communication throughout the assessment to achieve a high audit ROI. Assessors and entities should discuss each step of the remote audit, agreeing on:
- Objectives of the audit
- Timing and duration of the audit
- Roles and responsibilities of participants of the audit, including:
- Individuals providing oversight
- Procedures for escalating decisions
- Technologies and tools to be used during the audit, including:
- Types of testing activities
- Best practices for using the tools
- Permission for capturing video or audio of participants
- Privacy considerations for video and image recording
- Individuals, processes, and locations involved in the remote audit
- Details of schedules and interview objectives
- Access considerations for sensitive data environments
Organizations must also confirm that they have met all the requirements necessary for PCI DSS compliance before starting the remote audit.
Overview of PCI DSS Remote Auditing Tools
Although virtual audits are similar to those conducted on-site, remote auditing relies heavily on virtual audit tools to optimize the effectiveness of remote audits. The best such tools will:
- Minimize security risks to the cybersecurity infrastructure being tested
- Increase confidence in the outcomes of the remote audit
- Provide evidence that meets a high degree of:
- Plan for variability due to human factors
When it comes to deciding which remote auditing tools will work best for an assessment, organizations and security assessors should agree upon:
- The types of tools used for audits, such as:
- Security protocols that must be followed throughout the assessment
- Practice sessions to prepare for the audits and minimize technical issues
- Contingency plans to anticipate technological issues
It is critical to select the right tools for remote audits to ensure that the outcomes of audits are reliable and accurate.
Types of Virtual Audit Tools
Virtual audit tools that are typically used for PCI DSS remote auditing include:
- Synchronous documentation reviews – Personnel will walk an assessor through internal documents, files, or systems via an online collaboration tool (e.g., a call).
- Asynchronous documentation reviews – Through a tool or portal, an assessor will download the necessary documentation provided by an entity and conduct the audit.
- Synchronous video observation – Personnel at entities being audited can provide live stream video and a guided tour of their sites for the auditor to evaluate:
- Performance of tasks on-site
- Physical characteristics of the facility
- Asynchronous video observation – Personnel record videos of activities being performed on-site for the assessors to download and review during the remote audit.
Working with a PCI security assessor will help organizations prepare for and conduct remote audits effectively. Beyond PCI compliance audits, a leading MSSP will provide security audit services to help organizations achieve desired security assurance via remote or on-site audits.
Get Started with Virtual Audits
Remote auditing can be leveraged to evaluate the effectiveness of your security controls, much like on-site audits. Partnering with an MSSP will help you get the most value out of remote audits to keep your security posture up-to-date with industry and regulatory standards.
Contact RSI Security today to learn more and get started with virtual audits!