The vendor must host data in a specific geographic location to ensure that the data is protected by the applicable data protection laws of the EU or the country where the data originates. This is especially important for SaaS customers who transfer personal data from the EU to third countries, as they need to comply with the GDPR and the new Standard Contractual Clauses (SCCs) that regulate such transfers. The vendor must also provide adequate security measures and guarantees to protect the data from unauthorized access, disclosure, or loss. References = Risk and Information Systems Control Study Manual, Chapter 5: IT Risk Mitigation, Section 5.3: IT Risk Mitigation Strategies and Approaches, Page 253; Data Protection - New EU Standard Contractual Clauses - Bodle Law.

When an organization has a policy prohibiting ransom payments in the event of a ransomware attack, the most effective control to support this policy is creating immutable backups. Here's why:
* Immutable Backups:
* Definition: Immutable backups are backups that cannot be altered, deleted, or modified in any way once they are created. This ensures that a clean, untampered copy of data is always available.
* Protection Against Ransomware: Ransomware attacks typically encrypt data and demand a ransom to decrypt it. With immutable backups, the organization can restore the affected systems using the backup without paying the ransom, thereby adhering to their policy.
* Effectiveness:
* Restoration Capability: Immutable backups provide a reliable means to restore data to its state before the ransomware attack. This restoration capability negates the need to consider paying the ransom to regain access to encrypted data.
* Compliance with Policy: By having a secure and untouchable backup, the organization ensures compliance with its no-ransom policy as it can recover operations without engaging with the attackers.
* Comparison with Other Options:
* Vulnerability Scanning: While important, this primarily helps in identifying vulnerabilities and does not directly help in data recovery post-ransomware attack.
* Patching: Regular patching reduces the risk of ransomware infection but does not aid in recovery if an attack occurs.
* Intrusion Detection: Continuous monitoring can detect ransomware activities but does not provide a solution for restoring data after an attack.
* References:
* The CRISC Review Manual emphasizes the importance of data backups and specifically highlights the advantages of immutable backups in maintaining data integrity and availability in the face of attacks .

Key control indicators measure the operational effectiveness of specific controls, such as those contributing to defense-in-depth strategies. Monitoring these indicators ensures controls are functioning as intended, aligning with Control Effectiveness Monitoring.

First-hand direct observation of the controls in operation is the best way to confirm the existence and operating effectiveness of information systems controls because it provides the auditor with the most reliable and persuasive evidence. Direct observation involves inspecting the physical and logical aspects of the controls, such as the hardware, software, network, data, procedures, and personnel involved in the information systems. Direct observation also allows the auditor to verify that the controls are functioning as intended, and to identify any deviations or weaknesses that may affect the reliability of the information systems. Direct observation can be performed by using various techniques, such as walkthroughs, inquiries, inspections, reperformance, and analytical procedures1. References = Auditing Standard No. 13, The Auditor's Responses to the Risks of Material Misstatement, PCAOB, 20101

The risk owner should be assigned accountability for monitoring risk levels, as they have the authority and responsibility to manage the risk and its associated controls, and to report on the risk status and performance.
The risk practitioner, the business manager, and the control owner are not the best choices, as they have different roles and responsibilities related to risk identification, assessment, response, and reporting, but they are not accountable for the risk and its monitoring. References = CRISC Review Manual, 7th Edition, page
101.