Complementary user entity controls (CUECs) are essential to any SOC 2 compliance project report. These controls help to confirm the service provider’s system is secure by outlining responsibilities that the client (that is, the user) must undertake as well. 

Developing strategies to identify, map, and monitor CUECs is crucial for organizations that rely on Software-as-a-Service (SaaS) providers as part of their vendor management process. You won’t be able to manage privacy risks without them.

Why Complementary User Entity Controls Are Important

For a service provider to achieve its control objectives and compliance goals, the client will likely need to implement one or more CUECs itself. Those CUECs are typically listed in the System and Organization Controls (SOC) report generated when the service provider undergoes a SOC 2 audit. To implement CUECs successfully requires coordinated effort between the service provider and user entities.

When vendors don’t implement the proper CUECs, or when they implement CUECs of the wrong design, the vendor’s own SOC 2 controls can be severely undermined. That leaves the vendor unable to meet stated goals for security, availability, processing integrity, confidentiality, and privacy. Failure to enact CUECs can leave holes in the end-user’s defenses that hackers can exploit despite the provider’s own strong security protections.

Upholding your CUEC responsibilities is important for effective cybersecurity. That means you (the end-user) must review the service provider’s SOC 2 report carefully, to understand exactly what your CUEC responsibilities are. Documenting and continuously monitoring CUECs should be central to your third-party risk program.

Where to Find Complementary User Entity Controls in a SOC Report

CUECs are typically found in two places in a SOC 2 (and SOC 3) report: the system description and control activities sections.

The system description will have a defined CUEC subsection that outlines the general nature of complementary controls clients will need to implement so that the provider can meet its specified SOC 2 control objectives.

Specific CUECs are embedded within the control activities section alongside the related control objectives they address. For example, multifactor authentication for user logins may be labeled as a CUEC for logical access security. The practical upshot: to understand your CUEC obligations, you must analyze the control activities section of the SOC 2 report carefully. 

Comb through the SOC report to understand all relevant CUECs. It’s wise to document and classify CUECs too, so that you understand the additional controls and procedures you’ll need to implement within your IT environment. 

Who Is Responsible for CUECs?

Both sides of the provider-user relationship have some responsibility for CUECs. The service provider is responsible for defining, implementing, and operating controls within its system boundary. The user is responsible for configuring assigned CUECs per SOC 2 guidelines.

For example, say multifactor authentication (MFA) for provisioning user access is identified as a CUEC security control. The client must then enforce MFA for its personnel accessing the provider’s system. Any failure to implement prescribed CUECs properly results in gaps that counteract the provider’s internal controls, cause compliance nonconformities, and increase cyber risk exposure despite the vendor’s protections being aligned with industry standards.

How to Determine Your CUECs

To identify your organization’s share of control responsibilities for outsourced services, your information security team should review provider SOC 2 reports at least annually to pinpoint all applicable CUEC guidelines.

This review entails:

  • Searching reports for “user entity,” “client control,” and “complementary controls” sections.
  • Highlighting client obligations related to logical access controls, data security, availability monitoring, change management, and other critical domains.
  • Documenting extracted CUECs in a central inventory or risk assessment repository for tracking.
  • Confirming that current internal controls satisfy CUEC needs, or identifying gaps requiring new controls per SOC 2 criteria.
  • Validating that user control considerations for access provisioning and system configurations are fulfilled per AICPA standards.
  • Verifying that procedures for user management, network security, and operations align with prescribed CUECs

Continuous analysis clarifies any safeguards and procedures that are necessary to uphold security and compliance. MS Word natively supports taking notes while you read. Consider opening SOC 2 reports in Word to annotate key CUECs for documentation. 

Strategies for Mapping CUECs to Governance Documents

Once you’ve extracted CUECs from provider reports, the next step is to map the CUECs to your information security management system (ISMS) for tracking. This means:

  • Associating the CUECs to relevant policies, standards, and guidelines in your documentation system.
  • Linking CUECs to existing security controls or creating new user-entity controls.
  • Adding CUEC enforcement procedures into applicable processes (user provisioning, access reviews).

A centralized platform such as ZenGRC can help automate and simplify this CUEC integration process through impact analysis and governance mapping.

The Importance of Continuous Monitoring of CUECs

Without ongoing oversight, CUECs can quickly become outdated and ineffective as vendor environments evolve. This creates security gaps, most likely without you knowing those gaps exist. Simply relying on annual SOC reports allows windows for threat exposure from one audit to the next.

A mature vendor risk program can impose continuous monitoring of prescribed CUECs, along with regular internal control assessments and independent audits of service providers. Routine CUEC reviews can assure that client obligations adapt as vendors update systems, data flows, configurations, and compliance needs.

If users fail to examine CUEC evolution across reporting periods or fail to confirm that current mitigating controls sufficiently address updated requirements, significant vulnerabilities can emerge despite strong service organization safeguards.

Comprehensive CUEC tracking establishes tighter shared responsibility for cybersecurity and vendor-risk management. It’s an important activity and users ignore it at their peril.

ZenGRC Has an Integrated Management Solution for CUECs

Managing CUECs across multiple vendors while updating internal security controls is complex without the right technology. ZenGRC centralizes SOC reporting and provides automated impact analysis of CUECs on your governance framework. 

Schedule a demo today to see how ZenGRC can optimize your CUEC and third-party risk management programs.