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	<title>Comments on: Subservice Organizations and the Carve-out or Inclusive Method</title>
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	<link>http://linfordco.com/2010/03/subservice-organizations-and-the-carve-out-or-inclusive-method/</link>
	<description>SSAE 16/SOC 1 (f. SAS 70), SOC 2, and Royalty Audit Specialist CPAs</description>
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		<title>By: Newel Linford</title>
		<link>http://linfordco.com/2010/03/subservice-organizations-and-the-carve-out-or-inclusive-method/comment-page-1/#comment-6</link>
		<dc:creator>Newel Linford</dc:creator>
		<pubDate>Fri, 02 Apr 2010 16:20:42 +0000</pubDate>
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		<description>1 - Correct.  The service organization is not relieved of their responsibilities for monitoring the sub-service organizations.  Especially sub-service organizations that perform moderate to extensive functions for the service organization.  Monitoring in this scenario usually takes the form of monitoring service-level agreements or other relevant metrics and following up on deviations.</description>
		<content:encoded><![CDATA[<p>1 &#8211; Correct.  The service organization is not relieved of their responsibilities for monitoring the sub-service organizations.  Especially sub-service organizations that perform moderate to extensive functions for the service organization.  Monitoring in this scenario usually takes the form of monitoring service-level agreements or other relevant metrics and following up on deviations.</p>
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		<title>By: Kimberley Laris</title>
		<link>http://linfordco.com/2010/03/subservice-organizations-and-the-carve-out-or-inclusive-method/comment-page-1/#comment-5</link>
		<dc:creator>Kimberley Laris</dc:creator>
		<pubDate>Fri, 02 Apr 2010 00:53:14 +0000</pubDate>
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		<description>The #1 question is - does the services provider evaluate the adequacy of controls at sub-services providers? If that is not happening in any way, shape, or form, there are big monitoring concerns to address in the provider&#039;s SAS 70. The client should not turn their SAS 70 auditor into their monitoring control; the auditor should not be the first to find out that there is a problem at a sub-services provider. Sub-services providers need to be monitored by the provider purchasing services when they sub-source services. It is the sub-services provider&#039;s job to provide evidence of adequate controls - just like the services provider does for their customers by obtaining a SAS 70 for them.</description>
		<content:encoded><![CDATA[<p>The #1 question is &#8211; does the services provider evaluate the adequacy of controls at sub-services providers? If that is not happening in any way, shape, or form, there are big monitoring concerns to address in the provider&#8217;s SAS 70. The client should not turn their SAS 70 auditor into their monitoring control; the auditor should not be the first to find out that there is a problem at a sub-services provider. Sub-services providers need to be monitored by the provider purchasing services when they sub-source services. It is the sub-services provider&#8217;s job to provide evidence of adequate controls &#8211; just like the services provider does for their customers by obtaining a SAS 70 for them.</p>
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