When do we…
When do we share a report, certificate or policy with a customer, and on what terms?
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The short answer
- Recommendation
- Share a document only when it is in your evidence index, in date, and released by the person its sharing tier names. Public items can go to any customer or live prospect. Under NDA items go only when an agreement covers the recipient and the document that day, and a Summary only item goes as its approved summary.
- Reasoning
- Evidence supports answers you are held to, and some of it must never leave the organisation. The index gives each item an owner, a scope, dates and one sharing tier, so the decision is made once and not for each request. A document shows only its own scope and period, so it is described by its title, scope, issuer and dates and no further. A supplier's document belongs to the supplier, whose terms decide whether it may be shared.
- Considerations
- Check expiry on the day you send. An expired or withdrawn item is not sent, and one sent by mistake is a wrong answer that goes through the correction route.
- An agreement with a customer's lawyers does not by itself cover its security team. Ask Legal to confirm cover for the recipient and the document.
- A recipient with no agreement in force is offered the Public items and a summary whose own tier is Public. The request for an agreement goes to Legal.
- Say the organisation is certified or compliant only when a current indexed document says so for that scope and Legal has confirmed the wording.
The decision, step by step
Select any step for the reasoning behind it and where the pack covers it.
- Start
- Step
- Decision
- Outcome
- Loop back
Keyboard: Tab to a step, arrow keys move along the flow, Enter pins its explanation, + and − zoom, 0 fits the diagram, Esc closes. The text version below has the same content.
Where a step quotes a number, it is the default in the CISO Times pack. Your own standard may set a different one.
Read as text
The same flow written out: each step, its reasoning and where the pack covers it. 22 steps.
Start
A customer asks for a report, certificate or policy
Treat every such request as a request for evidence, whoever receives it. Evidence supports answers the organisation is held to, and some of it must never leave. The rule is the same for a short email, a call or a line in a questionnaire: nothing goes out until the evidence index and the release rules have been applied.
In the pack
- P26-A02 Questionnaire Response Governance MethodSharing evidence (rule QG-13)
- P26-A05 Evidence & Attestation Library IndexRelease Check
Decision
Is the sender a customer, or a prospect in a live sale?
Only customers and prospects in a live sales opportunity are answered. Anyone else is declined and the reason recorded. Sales may still send the Public overview and Public evidence to them. If it is not clear who the sender is, treat the answer as no until the account owner confirms.
- Yes: Is the item in the evidence index?
- No, or not known: Decline, send only Public items, record why
In the pack
- P26-A03 Questionnaire Intake, Drafting & Approval ProcedureWhat triage finds, and what follows (rule IN-04)
- P26-A03 Questionnaire Intake, Drafting & Approval ProcedureStep 2: Triage
Outcome
Decline, send only Public items, record why
Reply politely and send nothing beyond the Public overview and Public evidence. Record the decline and the reason in your request log. Sales may send the Public overview and Public evidence, and nothing else goes.
In the pack
- P26-A03 Questionnaire Intake, Drafting & Approval ProcedureWhat triage finds, and what follows (rule IN-04)
- P26-A03 Questionnaire Intake, Drafting & Approval ProcedureStep 2: Triage (rule IN-09)
Decision
Is the item in the evidence index?
The index lists what the organisation may send, with each item's scope, issuer, owner, dates and sharing tier. A document found on a shared drive but missing from the index has no tier and no owner, so nobody has decided who may see it. If you are unsure, answer no.
- Yes: Has it expired or been withdrawn, or is that unknown?
- No, or not known: Do not send; ask the response lead to place it first
In the pack
- P26-A05 Evidence & Attestation Library IndexEvidence Index (rule EV-08)
- P26-A05 Evidence & Attestation Library IndexTypes and Rules
Outcome
Do not send; ask the response lead to place it first
Judgement call: the pack gives every item a tier and an owner but does not say how to treat a document that is not indexed. This flow takes the cautious route. The response lead and the Head of Information Security decide whether it joins the index and in which tier. Meanwhile tell the customer what is available now, from the Public items.
In the pack
- P26-A02 Questionnaire Response Governance MethodSharing evidence (rule QG-13)
- P26-A05 Evidence & Attestation Library IndexEvidence Index (rule EV-08)
Decision
Has it expired or been withdrawn, or is that unknown?
Check the expiry date on the day you send, not on the day the item was indexed. An item past its expiry date, or withdrawn, is not sent. The answers that cite it are held until its owner renews it or changes them.
- Yes, or not known: Do not send; the owner renews it or replaces it
- No: Is it a supplier's document, not the organisation's own?
In the pack
- P26-A05 Evidence & Attestation Library IndexTypes and Rules (rule EV-10)
- P26-A03 Questionnaire Intake, Drafting & Approval ProcedureStep 8: Release evidence and submit (rule QG-13)
Outcome
Do not send; the owner renews it or replaces it
Tell the customer only what the owner has confirmed about renewal, and give no date the owner has not confirmed. Sending an expired certificate or report is a wrong answer, and the correction route applies if it has already gone. Do not hide it.
In the pack
- P26-A05 Evidence & Attestation Library IndexTypes and Rules (rule EV-10)
- P26-A05 Evidence & Attestation Library IndexTypes and Rules (rule QG-19)
Decision
Is it a supplier's document, not the organisation's own?
A hosting provider's certificate or report belongs to the provider, which holds the control and the attestation. Its scope of claim is the supplier's service, not ours. It is shared only as the supplier's terms allow, and never shown as the organisation's own.
- Yes, or not known: Do the supplier's terms allow you to share it?
- No: Which sharing tier is the item in?
In the pack
- P26-A02 Questionnaire Response Governance MethodThe library and the evidence (rule QG-14)
- P26-A05 Evidence & Attestation Library IndexTypes and Rules (rule EV-11)
Decision
Do the supplier's terms allow you to share it?
Read the terms the index records for that supplier. If they are not recorded or not clear, answer no and ask the owner to check with the supplier.
- Yes: Label it as the supplier's, with its scope
- No, or not known: Do not send; point the customer to the supplier
In the pack
- P26-A05 Evidence & Attestation Library IndexTypes and Rules (rules EV-08, EV-11)
- P26-A02 Questionnaire Response Governance MethodThe library and the evidence (rule QG-14)
Outcome
Do not send; point the customer to the supplier
Tell the customer whose document it is and that the supplier controls its release. Offer what the organisation can say on its own account instead, within its own scope. Do not describe the supplier's controls as the organisation's.
In the pack
- P26-A05 Evidence & Attestation Library IndexTypes and Rules (rule EV-11)
- P26-A02 Questionnaire Response Governance MethodThe library and the evidence (rule QG-14)
Step
Label it as the supplier's, with its scope
State the supplier's name and the scope on the document, for example the hosting service and not the organisation's systems. The customer must not be able to read it as the organisation's own certificate.
In the pack
- P26-A05 Evidence & Attestation Library IndexTypes and Rules (rule EV-11)
- P26-A08 Customer-Facing Security Overview DocumentAssurance and evidence we can share
Decision
Which sharing tier is the item in?
Every indexed item has exactly one tier. The tier decides who releases it and whether it may go at all. Public needs no further agreement. Under NDA needs an agreement in force. Summary only is never sent as it stands. Never shared is not sent.
- Public: Will you say the organisation is certified or compliant?
- Under NDA: Does an NDA cover the recipient and this document today?
- Summary only: Send the approved summary named in the index instead
- Never shared, or not known: Do not send; offer the overview and Public items
In the pack
- P26-A05 Evidence & Attestation Library IndexTypes and Rules (rule Sharing tiers)
- P26-A02 Questionnaire Response Governance MethodSharing evidence
Outcome
Do not send; offer the overview and Public items
Internal workpapers such as internal control test results never leave the organisation. Only the Head of Information Security and Legal together can change a tier. A customer who insists is told what is available instead, and the request is logged.
In the pack
- P26-A02 Questionnaire Response Governance MethodSharing evidence (rule QG-13)
- P26-A05 Evidence & Attestation Library IndexRelease Check
Step
Send the approved summary named in the index instead
An item such as a full penetration test report holds detail an attacker could use, so the item stays inside. Its approved summary goes in its place, released by the Head of Information Security. The summary has its own sharing tier, so this flow checks the summary again from the start: a recipient with no agreement in force gets it only where the summary's own tier is Public (EV-13).
- Then: Has it expired or been withdrawn, or is that unknown? (back to an earlier step)
In the pack
- P26-A02 Questionnaire Response Governance MethodSharing evidence (rule QG-13)
- P26-A05 Evidence & Attestation Library IndexRelease Check (rule EV-13)
Decision
Does an NDA cover the recipient and this document today?
The agreement must be in force on the day of sending and cover the recipient and the document. An agreement with a customer's lawyers does not by itself cover its security team: ask Legal. If cover is unclear or has lapsed, answer no.
- Yes: Will you say the organisation is certified or compliant?
- No, or not known: Offer Public items and summaries; Legal requests an NDA
In the pack
- P26-A02 Questionnaire Response Governance MethodSharing evidence (rule QG-13)
- P26-A05 Evidence & Attestation Library IndexRelease Check (rule EV-13)
Outcome
Offer Public items and summaries; Legal requests an NDA
Send the Public items, and a summary only where the summary's own tier is Public, and ask Legal to put an agreement in place. Send the Under NDA item once Legal confirms it covers the recipient. Tell the customer what is waiting on the agreement.
In the pack
- P26-A05 Evidence & Attestation Library IndexTypes and Rules (rule EV-13)
- P26-A05 Evidence & Attestation Library IndexRelease Check
Decision
Will you say the organisation is certified or compliant?
Describe the item by its title, scope, issuer and dates, as the document states them, and no further. A statement that the organisation is certified, compliant or aligned is a legal claim about a scope. It is made only when a current document in the index says it for that scope and Legal has confirmed the wording. If unsure, answer yes.
- Yes, or not known: Hold the wording; Legal confirms it first
- No: Does it expire within 60 days?
In the pack
- P26-A05 Evidence & Attestation Library IndexTypes and Rules (rules EV-14, QG-10)
- P26-A02 Questionnaire Response Governance MethodApproval, promises and claims (rule QG-10)
Outcome
Hold the wording; Legal confirms it first
Remove the claim or have it confirmed. Name the document and say whose it is, but leave out any statement that the organisation holds a certificate or is compliant unless the index and Legal support it. The distributor in the pack's example holds no certificate of its own and says so.
In the pack
- P26-A02 Questionnaire Response Governance MethodApproval, promises and claims (rule QG-10)
- P26-A08 Customer-Facing Security Overview DocumentAssurance and evidence we can share
Decision
Does it expire within 60 days?
The pack's default warning window is 60 days. Say in the response when an item expires within it, and state the date. Say that it is being renewed only if the item's owner has confirmed that.
- Yes, or not known: Put the expiry date in the response
- No: Add the covering statement and send through the customer's channel
In the pack
- P26-A05 Evidence & Attestation Library IndexTypes and Rules (rule EV-09)
- P26-A03 Questionnaire Intake, Drafting & Approval ProcedureStep 8: Release evidence and submit
- P26-A08 Customer-Facing Security Overview DocumentAssurance and evidence we can share
Step
Put the expiry date in the response
Write the date plainly. Do not word it as a promise, such as 'we will renew by', which turns a description into a commitment the customer can hold you to. Mention renewal only if the item's owner has confirmed it.
In the pack
- P26-A03 Questionnaire Intake, Drafting & Approval ProcedureStep 8: Release evidence and submit
- P26-A05 Evidence & Attestation Library IndexTypes and Rules (rule EV-09)
Step
Add the covering statement and send through the customer's channel
The covering statement says the response describes the organisation as at a date, for the stated scope, and that any commitment is made only in the agreement. The account owner sends only what the response lead released, by the customer's channel or an encrypted route. Releasing needs the person the tier names.
In the pack
- P26-A03 Questionnaire Intake, Drafting & Approval ProcedureThe covering statement
- P26-A03 Questionnaire Intake, Drafting & Approval ProcedureStep 8: Release evidence and submit (rule QG-13)
Outcome
Record the item, recipient and date, then close
Record the item, the recipient and the day in your request log, and keep an exact copy of what was sent with the item versions. If the item or its date later proves wrong, the log shows who received it.
In the pack
- P26-A05 Evidence & Attestation Library IndexTypes and Rules (rule EV-12)
- P26-A03 Questionnaire Intake, Drafting & Approval ProcedureStep 9: Follow up and close
Practical checklist
- Confirm the sender is a customer or a prospect in a live sale, or decline and record why.
- Find the item in the evidence index, and send nothing that is not indexed.
- Check its expiry date on the day of sending, and hold it if it has expired or been withdrawn.
- For a supplier's document, check the supplier's terms allow sharing, and label it as theirs with its scope.
- Apply the sharing tier: send Public items, send the approved summary of a Summary only item, and never send a Never shared item.
- Send an Under NDA item only once Legal confirms an agreement covers the recipient and the document that day.
- Describe each item by title, scope, issuer and dates, state any expiry within 60 days, and mention renewal only if its owner has confirmed it.
- Add the covering statement, send through the customer's channel or an encrypted route, and record the item, the recipient and the day.
Evidence to have ready
- The evidence index entry for each item sent: type, scope, issuer, owner, dates, sharing tier and any supplier's terms.
- The release record in your request log: the item, the recipient, the day and who released it.
- The non-disclosure agreement in force on the day, and Legal's confirmation that it covers the recipient and the document.
- The exact copy of the response as sent, with the item versions and the covering statement.
- Legal's written confirmation of any certification or compliance wording.
Assumptions
- The organisation keeps an evidence index with a sharing tier, owner and expiry date for each item. Without one, build it before the next request.
- A named response lead handles requests, and the Head of Information Security (or whoever holds that role) releases Under NDA items. The tiers and the 60-day warning are the pack's defaults, which your own standard may change.
- Legal can confirm whether a non-disclosure agreement covers a given recipient and document.
Not covered here
- Whether to answer a questionnaire in full, point to the documents or decline. That is “How do we decide whether to answer a questionnaire in full, point to a certificate, or decline?”.
- Who approves the answers in the questionnaire itself. That is “How do we decide who approves our answers to a customer's security questionnaire before we send them?”.
- How a customer's request to audit, visit or enter your systems is handled. That goes to Legal, with report-based assurance as the default offer.
- Which certificate a regulated customer needs from a supplier. That depends on the customer and its own rules, and this flow does not say what meets any of them.
Related questions
- How do we decide whether to answer a questionnaire in full, point to a certificate, or decline?
- How do we decide who approves our answers to a customer's security questionnaire before we send them?
- How do we write a customer-facing security overview that answers most questionnaires before they arrive?
- How do we build and keep a library of security answers we can reuse?
- How do we answer a customer's 300-question security questionnaire consistently?