Define your CMMC Audit Scope
Overview
Define your CMMC Audit Scope to set the boundaries of the audit and identify the object in focus.
The object can include the people, data, system, or product in review. The scope definition allows the auditors to focus on an aspect of the organization rather than the whole. This is why it is important to clearly define the scope of review for your given audit.
Determining your CMMC audit scope requires your organization to specify the product, the data, the systems, and the vendors in scope.
Read below for guidance on how to determine each scope item. A table listing each item is provided below to use as a template for this exercise.
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Product(s) in scope
For a Software as a Service (SaaS) provider, the scope is typically the software application(s) offered to clients. Some organizations have multiple products, and it is important to define for your CMMC what product is in focus and what product isn’t.
Data in scope
In order to identify the data in scope, the ideal step is to focus on the type of data and people that flow through the product or service identified. For a SaaS provider, it’s typically all the data held in it (i.e., customer data, etc.) and the people that support it, such as vendors and employees.
Systems in scope
To identify all your systems in scope, take an inventory of all the various systems and internal controls that are critical to delivering your service or product in scope. This could include email and Slack. The key is to focus on the systems and tools that are essential to delivering your service / product. Production systems have a direct impact on your product or service in lieu of non-production systems.
For HR systems, focus on systems that manage employee onboarding and training processes. Everything else, such as time off requests and benefits, is out of scope since they are not critical to delivering a service or product.
For a SaaS provider, it’s typically all the infrastructure that hosts it and the procedures that support it, such as AWS, Github, JIRA, etc.
Vendors in scope
IIn order to identify the vendors in scope, focus on the critical vendors, such as cloud hosting and production-related organizations used to support the product or service in scope.
Scoping guidance template
| Scoping guidance |
| Provide a detailed description of your organization’s products or services. Focus on the product or service under review |
| Provide the type of data and people that flow through the product or service under review |
| Please provide a list of systems / tools that flow through or support the product or service under review |
| Please provide the list of critical vendors being used to support the product or service under review |
