Skip to content

Control 3.12: Evidence Collection and Audit Attestation — Troubleshooting

Common issues and resolution steps for evidence collection and audit attestation procedures.

Common Issues

Issue 1: Evidence Pack Missing Critical Control Documentation

  • Symptoms: Regulatory examiners identify gaps in the evidence pack during examination preparation.
  • Root Cause: Evidence collection scripts may not cover all controls, or control owners have not uploaded evidence to Compliance Manager.
  • Resolution:
  • Run the evidence completeness check against the full control inventory.
  • Identify missing controls and contact assigned owners for immediate evidence submission.
  • Update automation scripts to cover the missing control areas.
  • Implement a mandatory pre-examination review checklist.

Issue 2: Stale Evidence Not Updated Before Examination

  • Symptoms: Evidence freshness audit reveals items exceeding their maximum age at the time of examination.
  • Root Cause: Evidence refresh schedule not adhered to, or responsible parties not notified of upcoming refresh deadlines.
  • Resolution:
  • Run the evidence freshness audit immediately and identify stale items.
  • Regenerate stale evidence using automation scripts.
  • Implement automated reminders for evidence refresh deadlines.
  • Assign backup owners for each evidence category to prevent single-point-of-failure.

Issue 3: Attestation Approver Unavailable

  • Symptoms: Attestation workflows are stuck pending approval because the designated approver is unavailable.
  • Root Cause: No backup approver is configured, or the approval workflow does not support delegation.
  • Resolution:
  • Configure backup approvers for all attestation workflows.
  • Implement an escalation path that automatically redirects to backup after 48 hours.
  • Ensure at least two people are assigned to each attestation approval role.
  • Document the delegation of authority for attestation sign-offs.

Issue 4: Compliance Manager Automated Assessments Showing Incorrect Status

  • Symptoms: Compliance Manager shows a control as "Not implemented" when it has been configured correctly.
  • Root Cause: Automated assessment may not detect all configuration methods (e.g., PowerShell-configured settings vs. portal settings).
  • Resolution:
  • Review the automated assessment criteria for the specific control.
  • If the configuration was done via PowerShell, manually override the assessment status in Compliance Manager.
  • Upload manual evidence (PowerShell output, screenshots) to support the override.
  • Document the discrepancy for future reference.

Diagnostic Steps

  1. Run evidence completeness check: Review the evidence pack against the full control inventory.
  2. Check freshness audit: Run Script 4 from PowerShell Setup to identify stale items.
  3. Verify attestation status: Check Compliance Manager for pending or overdue attestations.
  4. Test evidence retrieval: Simulate an examiner request and measure response time.

Escalation

Severity Condition Escalation Path
Critical Examination underway with evidence gaps Chief Compliance Officer + Legal
High Multiple controls lacking evidence Compliance team + Control owners
Medium Evidence freshness issues Assigned evidence owners
Low Minor attestation workflow delays IT support for workflow configuration