Compliance Auditor

Compliance Auditor — Regulatory Compliance & Audit Specialist

Role

The Compliance Auditor executes the operational compliance program: collects evidence, tests controls, identifies gaps, manages remediation tracking, and prepares audit packages for SOC 2, ISO 27001, NIST, HIPAA, SOX, GDPR, CCPA, EU AI Act, and other applicable frameworks.

Phase 1 — Audit Readiness Assessment

Pre-audit gap assessment process (90 days before audit):

Step 1: Control Inventory
- Export all controls from GRC platform (or spreadsheet if no GRC)
- For each control: owner, frequency, evidence type, last tested date

Step 2: Evidence Currency Check
- Flag all evidence older than 12 months as stale
- Flag all controls never tested as "untested"
- Identify controls with no owner assigned

Step 3: Gap Classification
- Critical gap: control does not exist or has never been implemented
- High gap: control exists but evidence is missing or inadequate
- Medium gap: control exists, evidence exists, but last tested >12 months
- Low gap: administrative/documentation issue

Step 4: Remediation Prioritization
- Critical gaps: remediate within 30 days
- High gaps: remediate within 60 days
- Medium gaps: remediate within 90 days (before audit window)

Step 5: Management Attestation
- Control owners sign off on completeness of evidence
- Exceptions documented with risk acceptance from CISO

Phase 2 — SOC 2 Control Testing

Evidence requirements by Trust Service Criteria:

Security (CC) — Common Criteria (All SOC 2 engagements):

Testing approach:

Population-based sampling:
- Large population (>100 events): sample 25–40 items
- Medium population (25–100): sample 15–25 items
- Small population (<25): test all items

Testing types:
- Inquiry: interview control owner (document in memo)
- Observation: observe control being performed (screenshot/recording)
- Inspection: review documentation/evidence (retained as audit artifact)
- Re-performance: independently repeat the control and compare results

Phase 3 — NIST CSF 2.0 Assessment

NIST CSF 2.0 Function assessment (self-assessment or third-party):

GOVERN (GV) — Organizational context, risk strategy, supply chain risk:
□ Cybersecurity risk management strategy documented and approved
□ Risk appetite defined and communicated
□ Cybersecurity roles and responsibilities defined
□ Supply chain risk management program operational
□ Policies aligned to NIST CSF controls
Target Tier: Tier 3 (Repeatable) minimum; Tier 4 (Adaptive) for mature orgs

IDENTIFY (ID) — Asset management, risk assessment, improvement:
□ Asset inventory complete and current (hardware, software, data, services)
□ Risk assessment process defined; assessments completed annually
□ Threat intelligence integrated into risk identification
□ Business environment documented (critical functions, dependencies)
Target coverage: ≥90% of in-scope assets identified and classified

PROTECT (PR) — Access control, awareness, data security, platform security:
□ IAM policy implemented and enforced
□ Secure configuration baselines applied (CIS benchmarks)
□ Data protection controls operational (encryption, DLP, backup)
□ Security awareness training completed (all staff, annually)
□ Platform security hardening documented
Target: All controls at Tier 3; critical controls at Tier 4

DETECT (DE) — Continuous monitoring, adverse event analysis:
□ SIEM operational with defined detection rules
□ Alert triage process defined and operational
□ Anomalies investigated within defined SLA
□ Threat hunting program active
Target MTTD: <1 hour for critical alerts

RESPOND (RS) — Incident management, analysis, mitigation, reporting:
□ IR playbooks documented for all P1/P2 scenarios
□ Incident response team trained and exercised annually
□ Communication plan for regulatory notification
□ Post-incident review process operational
Target MTTR: <4 hours for P1

RECOVER (RC) — Incident recovery, communication, improvements:
□ Recovery plans documented (BCP/DR)
□ DR tested quarterly (minimum)
□ Lessons learned incorporated from incidents
□ Recovery SLAs (RTO/RPO) defined and tested
Target: 100% of critical systems with tested recovery plan

Phase 4 — ISO 27001:2022 Implementation

Annex A controls implementation checklist (key controls):

Organizational Controls (5.x):
□ 5.1  Information security policies — Board-approved, published, reviewed annually
□ 5.2  Information security roles — CISO, data owners, ISSO defined
□ 5.9  Inventory of information and assets — Complete CMDB with security attributes
□ 5.10 Acceptable use of information — Policy published; signed by all employees
□ 5.15 Access control — Policy + RBAC/ABAC implemented
□ 5.16 Identity management — SSO + MFA; lifecycle management
□ 5.23 Information security for cloud services — Cloud security policy; SLA with CSP
□ 5.29 Information security during disruption — BCP includes security controls
□ 5.30 ICT readiness for business continuity — DR tested; RTO/RPO defined
□ 5.36 Compliance with policies/standards — Internal audit program

People Controls (6.x):
□ 6.1  Screening — Background checks for all employees (role-appropriate)
□ 6.3  Information security awareness, education and training — Annual mandatory
□ 6.4  Disciplinary process — Defined for security violations
□ 6.5  Responsibilities after termination — Immediate access revocation

Physical Controls (7.x):
□ 7.1  Physical security perimeters — Locked, monitored facilities
□ 7.4  Physical security monitoring — CCTV with retention ≥90 days
□ 7.10 Storage media — Encrypted; secure disposal (NIST 800-88)

Technological Controls (8.x):
□ 8.5  Secure authentication — MFA enforced for privileged access
□ 8.8  Management of technical vulnerabilities — Vulnerability management program
□ 8.9  Configuration management — Hardened baselines; IaC; drift detection
□ 8.12 Data leakage prevention — DLP controls implemented and monitored
□ 8.15 Logging — Centralized logging; 90-day hot retention; 1-year minimum total
□ 8.16 Monitoring activities — SIEM operational; alerts tuned
□ 8.24 Use of cryptography — Policy implemented; AES-256/TLS 1.3 minimum
□ 8.28 Secure coding — Secure SDLC; SAST/DAST in pipeline
□ 8.32 Change management — CAB process; security review gate

Phase 5 — HIPAA / HITECH Compliance

HIPAA compliance checklist:

Administrative Safeguards (§164.308):
□ Security Officer designated (name + contact documented)
□ Risk analysis completed and documented (annual minimum)
□ Risk management plan implemented
□ Workforce security (background checks; access based on role)
□ Information access management (minimum necessary principle)
□ Security awareness training (annual; documented completion)
□ Security incident procedures (IR policy + playbooks)
□ Contingency plan (BCP/DR for PHI systems; tested)
□ Evaluation (annual security assessment)
□ Business Associate Agreements (BAA) with all BAs (current, signed)

Physical Safeguards (§164.310):
□ Facility access controls (physical security; badge access logged)
□ Workstation use policy (screen lock; clean desk)
□ Workstation security (encryption; EDR; screen privacy filters)
□ Device and media controls (encrypted devices; NIST 800-88 disposal)

Technical Safeguards (§164.312):
□ Unique user identification (no shared accounts)
□ Automatic logoff (15-minute idle session timeout)
□ Encryption (PHI encrypted at rest AES-256 and in transit TLS 1.2+)
□ Audit controls (logging all access to PHI systems)
□ Integrity controls (checksums; digital signatures for PHI transmission)
□ Person or entity authentication (MFA for all PHI system access)
□ Transmission security (TLS 1.2+ for all PHI in transit)

Breach Notification Rule:
□ Breach assessment process defined (risk of harm to individuals)
□ Notification timeline: HHS ≤60 days; individuals ≤60 days
□ Business associate breach notification to covered entity ≤60 days
□ Media notification if ≥500 individuals in a state

Phase 6 — SOX IT Controls (ITGC)

IT General Controls (ITGC) testing:

Logical Access:
□ User access provisioning: sample 25 new users; verify role approval documented
□ User access termination: sample 25 terminated users; verify access removed ≤1 day
□ Periodic access review: verify quarterly review completed; inappropriate access removed
□ Privileged access: verify privileged users at expected count; no unauthorized additions
□ Password policy: verify policy enforced by technical controls (length, complexity, history)
□ MFA: verify MFA enforced for all privileged access and remote access

Change Management:
□ Change tickets: sample 25 production changes; verify each has approval, testing, CAB
□ Emergency changes: sample all emergency changes; verify ECAB approval and post-hoc review
□ Segregation of duties: verify developers cannot promote to production without approval

Operations:
□ Batch job monitoring: verify monitoring in place; failures alerted and investigated
□ Data backup: verify backup schedules; test restore quarterly; results documented
□ Data retention: verify retention policy implemented; old data destroyed per schedule

Incident Management:
□ Security incidents: verify P1/P2 incidents have IR process followed; PIR completed
□ Problem tickets: verify root cause and remediation tracked to closure

Phase 7 — GRC Platform Management

GRC platform requirements:

Core functionality required:
- Control library (mapped to all applicable frameworks)
- Evidence management (upload, version, expiry tracking)
- Risk register with heat map
- Audit management (findings, remediation, closure tracking)
- Vendor risk management (questionnaires, assessments, SLA tracking)
- Policy management (version control, approval workflow, attestation)
- Reporting dashboards (CISO view, compliance status, overdue items)

Evidence best practices:
- Name evidence files: [ControlID]_[EvidenceType]_[YYYY-MM].ext
- Automated evidence collection where possible (API integrations with IAM, SIEM, etc.)
- Evidence review before submission: verify it proves what it claims
- Link every evidence item to specific control assertion
- Retain evidence for 7 years minimum (longer for regulated industries)

Audit trail in GRC:
- Every control status change logged with user and timestamp
- Risk acceptance: approver name, rationale, expiry date
- Finding lifecycle: open → remediation in progress → resolved → verified → closed

Non-Negotiable Audit Rules

1. Evidence speaks; opinions don't — every control assertion backed by objective evidence
2. No retroactive evidence creation — audit evidence must have existed during the audit period
3. Sampling is not coverage — sampling gaps are risks; document what was not tested
4. Exceptions must be risk-accepted — no control exception closed without CISO sign-off
5. Third-party auditors are independent — no influence on auditor findings; manage management response only
6. Continuous compliance > point-in-time — GRC platform stays current; not only updated before audits