Validate that risk owners have formulated and approved an information security risk treatment plan and have authorized residual information security risks. This involves a series of steps and the collection of various types of evidence. Here’s a structured approach to this validation process:
Steps to Validate Risk Treatment Plan Approval and Residual Risk Authorization
Review Risk Treatment Plan Documentation
Risk Treatment Plan: Ensure there is a comprehensive and documented risk treatment plan. This plan should include identified risks, selected treatment options, and the rationale for these selections.
Signatures and Approvals: Check for documented evidence of approval, such as signatures or electronic approvals from the designated risk owners.
Examine Meeting Minutes and Records
Approval Meetings: Review minutes from meetings where the risk treatment plan was discussed and approved by risk owners. Look for clear indications of discussions, decisions made, and approvals granted.
Risk Management Committee: If applicable, review the records of risk management committee meetings where risk treatment plans were reviewed and authorized.
Verify Residual Risk Authorization
Residual Risk Acceptance: Ensure that the risk treatment plan includes a section where residual risks are identified and formally accepted by the risk owners.
Authorization Documentation: Look for documented authorization of residual risks, including risk acceptance forms or statements signed by the risk owners.
Conduct Interviews with Risk Owners
Interviews: Conduct interviews with risk owners to confirm their understanding of their role in the risk treatment process and their approval of the treatment plans and residual risks.
Decision-Making Process: Verify through interviews that the risk owners were involved in the decision-making process and that they formally approved the residual risks.
Review Risk Management Policy and Procedures
Policies: Check the organization’s risk management policies to ensure they outline the requirement for risk owners to approve risk treatment plans and authorize residual risks.
Procedures: Verify that there are established procedures detailing how risk treatment plans should be approved and how residual risks should be authorized.
Audit and Compliance Checks
Internal Audits: Perform or review internal audits to assess whether the risk treatment plans, and residual risk authorizations are following the organization’s policies and procedures.
Compliance Reports: Examine reports from compliance checks that indicate whether risk owners are adhering to the defined process.
Review Continuous Improvement and Feedback Mechanisms
Feedback: Ensure there is a mechanism for collecting and addressing feedback on the risk treatment process, including any issues related to the approval and authorization by risk owners.
Improvements: Check documentation showing that improvements have been made to the process based on feedback and audit findings.
Example of Evidence to Collect
Risk Treatment Plan Documentation
· Copies of the risk treatment plan with risk owners’ signatures or electronic approvals.
· Version history showing updates and approvals over time.
Meeting Minutes and Records
· Minutes from risk management meetings showing discussions and approvals.
· Records of decisions made during these meetings.
Residual Risk Authorization Documentation
· Signed risk acceptance forms.
· Statements or memos indicating acceptance of residual risks by the risk owners.
Interview Notes
· Notes or transcripts from interviews with risk owners confirming their involvement and approval.
· Summary of their understanding and acceptance of residual risks.
Risk Management Policies and Procedures
· The organization’s risk management policy document.
· Procedural documents outlining the risk treatment and approval process.
Audit and Compliance Reports
· Internal audit reports assessing compliance with the risk treatment process.
· Compliance checklists and findings related to risk treatment plan approvals.
Continuous Improvement Documentation
· Records of feedback collected on the risk treatment process.
· Documentation of changes made to the process based on feedback and audit findings.
By systematically gathering and reviewing this evidence, you can validate that risk owners have formulated and approved the information security risk treatment plan and have authorized the residual information security risks.
