SOC 2 CC1.5: COSO Principle 5: Holds Individuals Accountable for Internal Control Responsibilities

Map internal control responsibilities to specific roles and individuals. Each control should have a clearly identified owner responsible for its operation and effectiveness. Document these assignments in a control ownership matrix or RACI chart. Bake internal control responsibilities into job descriptions and employment agreements. Employees should formally acknowledge their security and compliance obligations during onboarding, with periodic renewals when responsibilities change. Integrate security and compliance metrics into performance evaluations. For security and IT staff, include specific KPIs like patch compliance rates, incident response times, policy adherence, and training completion. For all employees, include criteria around security awareness, policy compliance, and data handling practices. Set up a formal disciplinary process for security policy violations and control failures. Make it documented, consistently applied, and proportional to the severity of the violation. Communicate it to all employees and document any disciplinary actions taken. Implement regular monitoring and reporting of control effectiveness. Control owners should provide periodic status reports to management, flagging issues, exceptions, or failures. Management should review these reports, address gaps, and follow up on corrective actions. Create incentive structures that reward good security behaviour. Recognition programmes, bonuses tied to security metrics, or including security excellence in promotion criteria all work. Positive reinforcement matters as much as disciplinary consequences when you're building an accountability culture.