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Arizona Public Service. How We Did It: Preparing for a Successful CIP Audit. Mark Haughn Information Security & Compliance CIP Standard Owner. 06/16/2011. Agenda. APS Overview Culture of Compliance CIP Compliance Program Document Preparation People Preparation Questions. APS Overview.
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Arizona Public Service How We Did It: Preparing for a Successful CIP Audit Mark Haughn Information Security & Compliance CIP Standard Owner 06/16/2011
Agenda • APS Overview • Culture of Compliance • CIP Compliance Program • Document Preparation • People Preparation • Questions
APS Overview • Serve over 1,100,000 customers • 35,000 square-mile service territory (11 of 15 Arizona counties) • Serve approx 45% of Phoenix Valley customers • Approximately 6,700 employees • 53 Interconnections/Ties • SRP, WALC, TEP, PNM, CAISO, LADWP, IID, PACE, GRMA
Culture of Compliance – Internal Compliance Program • Documented Processes and Controls: APS maintains policies, standards, work procedures and guidelines that document clearly defined work practices, conduct, and quality standards that align and comply with federal and regional standards. • Performance and Conduct of Work: All work performed by APS employees, vendors, and contractors complies with all standards and requirements. APS has a commitment to compliance that values issue identification, correction, and continuous performance improvement. • Evidence of Compliance: APS creates and maintains evidence of compliance documentation that can be easily accessed to support quality assurance reviews, internal auditing, third-party data requests, and regulatory agency compliance activities.
Document Preparation • Organize your evidence • Understand what evidence is used for which requirement • Anticipate what the Auditors will want • Conduct practice Data Requests • Have people unfamiliar with the program ask you to prove compliance to them
People Prep • Know your resources • Who are your SME’s? • Who are their support people? • What do your SME’s know? • Pre-audit coaching sessions • Witness training