Regulatory Compliance Readiness Review

It is needless to state that today’s organizations are facing more intense pressure from increasing regulation and investigations by federal regulators, state attorneys generals, and others prompting extensive reviews, audits, and litigation in a variety of industry practices. Whether dealing with an urgent issue or addressing compliance more broadly, organizations need to have comprehensive programs in place to address their risks of noncompliance with state, federal, and international laws. Organizations need the expertise required to review their cybersecurity related operations from all perspectives to ensure that applicable regulatory requirements are being met.

• CryptoForensics’ Regulatory Compliance Readiness Review offerings include the following:
• Health Information Portability and Accountability Act (HIPAA)
• The Sarbanes-Oxley Act of 2002 (SOX)
• SSAE 16 SOC II & ISAE 3402 Readiness Review
• Privacy Gap Assessment

Concrete benefits of our services include:

i. HIPAA Compliance Review
HIPAA was passed 1996 to address the security and privacy of health care data. Following this, the government then enacted the Health Information Technology for Economic and Clinical Health Act (HITECH Act) as part of the American Recovery and Reinvestment Act of 2009 (ARRA) and signed it into law on February 17, 2009. The HITECH Act amended HIPAA with significant changes to data breach notification, enforcement, and penalties. CryptoForensics’ HIPAA compliance review is carried out as a gap assessment to review the client’s operational systems and processes to identify areas of noncompliance. Our experienced team members have worked with many organizations in the commercial, government, and health and human services sectors, including providers and service organizations.
The benefits of our approach include:

• Ascertainment of Compliance with the HIPAA/HITECH
• Precise identification and articulation of non-compliant areas and specification of actions are needed to comply with the HIPAA Security and Privacy Rules
• Clear avoidance of likely punitive damages that could result from a ePHI/PHI compromise
• Credible third party objective demonstration of HIPAA/HITECH compliance
• Drastic reduction of the cost, confusion, and complexity of HIPAA/HITECH compliance
• CryptoForensics’ multi-stage Approach and Methodology to HIPAA Gap Assessment include the following:
• Pre-Audit Stage during which we map out critical information processes in order to determine if regulatory controls have an impact on your business. The goals here are to:
  • Evaluate the effectiveness of the organization’s HIPAA compliance program
  • Validate the current HIPAA controls
  • Keep the organization up-to-date on any new HIPAA requirements, threats, and liabilities
• Onsite Visit Stage during which we:
  • Introduce engagement participants and define roles
  • Review engagement activities
  • Review any applicable documentation
  • Document the in-scope HIPAA business process and supporting technologies
  • Perform data flow analysis and map HIPAA processes to technical infrastructure
  • Document the existing controls used to protect ePHI/PHI
  • Identify gaps against the NIST 80-53 framework for HIPAA Security Rule
  • Identify gaps against the GAPP framework for HIPAA Privacy Rule
• The Documentation (Reporting) Stage during which we:
  • Conduct on-site interview and information gathering to assess HIPAA compliance status
  • Outline strategic recommendations to mitigate identified control gaps

ii. The Sarbanes-Oxley Act of 2002 (SOX) Section 404 Compliance Review

CryptoForensics’ SOX Readiness Review is designed to assess an organization’s preparedness for compliance. By conducting a thorough gap analysis, our consultants will assess the current control environment by identifying strengths and providing recommendations for areas that need improvement. As part of our detailed recommendations, we will provide a prioritized listing of controls for implementation or enhancement prior to the audit.

In addition, CryptoForensics will provide SOX-specific process documentation examples (flowcharts and Risk Control Matrices), test script templates, an inventory of baseline policies and procedures required, and key forms. A SOX Readiness Review is a valuable, cost effective assessment that will give you a good idea of where you currently are and where you need to be

CryptoForensics’ SOX compliance review is focused on section 404 and designed around the COSO internal control framework, the IT Governance Institute’s CobiT, and industry best practices. CryptoForensics will apply a top-down, risk-based approach to identify the most effective and efficient ways to appropriately reduce effort and compliance cost through better risk assessment, scoping, and use of technology. Our offerings are designed to meet each client’s unique needs. Whether our arrangement is full outsourcing, co-sourcing, or consulting, our team will work closely with the process owners, management, and external auditors to ensure all compliance initiatives are met on schedule, on budget, and in the highest quality. Our offerings here include:

• Project planning and management
• Risk assessment, scoping and materiality
• Documentation, testing and remediation of risks and controls
• Communication with external auditors, executive management and the audit committee
• Cost reduction by evaluating risks, optimizing controls, implementing risk-based testing and streamlining the overall compliance effort

At Cryptoforensics, we regard SOX as an opportunity to continuously improve business processes and performance rather than a mere exercise in compliance. Our consultants will thus help your organization to achieve compliance in the most efficient and cost effective manner.

iii. SSAE 16 SOC II & ISAE 3402 Preparedness Review

CryptoForensics can perform a readiness assessment that can help your organization assess the controls in place to meet the Trust Services Principles and Criteria with the goal of ensuring preparedness for the SOC 2 examination. In addition, CryptoForensics can help reduce or eliminate the possibility of a qualified opinion or reporting exceptions.

CryptoForensics’ experts will work collaboratively with your management teams to perform a detailed readiness review and provide a gap matrix that identifies controls that would pass right away, controls that would partially fail, and controls that would fail and require remediation. Organizations that fall into the following categories would benefit from our offerings:

• Any service organization that seeks a cost-effective method to assess its preparedness for an eventual service audit
• Any service organization that has not recently undergone a financial or regulatory audit
• Any service organization that prefers an internal-use-only report for the purposes of identifying any current controls deficiencies
• Any service organization that plans to perform a Type 2 service audit as its initial audit

The benefits of our service offerings:

• Clear identification of expectations for future audit, including time commitments that may be necessary from key client personnel, will be clearly communicated
• An internal-use-only report is provided to the client that creates the basis for improving the overall control environment
• The description of controls is drafted and ready to be used for the subsequent audit
• Strengths and weaknesses in the current control structure are clearly communicated to the client
• The client has sufficient time to remediate any gaps in the control structure
• The client has access to obtain immediate responses from CryptoForensics’ professionals regarding the impact potential changes to services or controls may have on the upcoming audit
• The scope of the subsequent audit—and specifically the control objectives and related control activities—are refined based upon the Readiness Assessment results

Concrete deliverables from our engagement will include:

• Detailed project plan for the project
• Comprehensive questionnaires and an information request list allowing the client’s personnel to gather documentation in advance of fieldwork
• A Readiness Assessment report containing the description of controls for use in the subsequent service audit
• Any additional reporting requirements specific to the new SSAE 16 and/or ISAE 3402 standards
• Identification of controls currently in place for each in-scope control objective
• A prioritized listing of controls that should be considered for implementation or enhancement prior to the execution of the service audit
• Additional observations and gaps noted during the assessment