Episode 80: Reviewing Risk and Control Analysis for Gaps Assessment

Welcome to The Bare Metal Cyber CRISC Prepcast. This series helps you prepare for the exam with focused explanations and practical context.
A gaps assessment in the risk and control environment is the structured process of identifying what is missing, misaligned, or ineffective in the organization’s ability to manage its risks. It involves analyzing whether the risks in the register are adequately addressed by existing controls, and whether those controls are operating as designed. A gaps assessment does not just verify presence—it evaluates sufficiency, alignment, and integration across systems, processes, and responsibilities. CRISC professionals perform these assessments to uncover vulnerabilities in the current risk posture and to guide remediation efforts that strengthen governance. Conducted thoroughly, this process supports compliance readiness, audit transparency, and strategic decision-making. On the exam, questions involving control failure, undetected incidents, or ineffective mitigation often point back to gaps that were not previously recognized. The right answers reflect attention to detail, traceability, and corrective action planning.
There are several common types of gaps that can undermine the effectiveness of risk management. Control gaps occur when there is no control in place to address a known risk, or when an existing control does not adequately reduce exposure. These gaps represent direct openings for threats to materialize into incidents. Process gaps involve missing or inconsistent procedures—steps that are bypassed, poorly documented, or overly reliant on manual execution. Ownership gaps are another frequent issue, arising when roles are unclear or unassigned, leaving key activities unmanaged. Monitoring gaps occur when there is no performance tracking, when thresholds go untested, or when detection occurs too late to prevent damage. CRISC professionals are trained to recognize that all of these categories represent exposure points. On the exam, phrases like “no control listed,” “approval unassigned,” or “no follow-up detected” are often clues to the presence of a gap that needs immediate attention.
A thorough gaps assessment depends on pulling the right data from the right sources. This starts with the organization’s risk register and control library, which together should show the connections between risks and the controls intended to mitigate them. Test results from control evaluations, audit findings, and exception logs all provide evidence of where things have failed in the past or where oversight has weakened. Incident reports help surface patterns and recurring issues that signal control or process failure. Regulatory compliance checklists and industry frameworks add structure by showing what is expected for your type of business or operating environment. Stakeholder interviews, process walkthroughs, and technical reviews provide ground-level insight into what is actually happening—not just what is written in a document. On the exam, weak assessments often reflect missing inputs. The best answers involve comprehensive, multi-source data gathering to fully illuminate the current state of the environment.
Identifying gaps requires structured techniques that allow CRISC professionals to detect disconnects between risks and controls. Control coverage mapping is one of the most commonly used tools. It involves listing every risk and showing which controls are in place to mitigate it, helping reveal any that have no supporting safeguards. Risk-to-control heatmaps provide a visual representation of where controls are strong, weak, or absent. Process mining uses logs and data flows to trace how processes actually run—often revealing steps that are skipped or handled inconsistently. Comparative reviews against frameworks like ISO 27001, NIST CSF, or COBIT allow teams to spot where the organization’s controls fall short of best practice expectations. CRISC professionals choose the method based on the complexity and maturity of the organization. On the exam, answers that rely on visual tools, control mapping, and structured analysis tend to reflect more robust identification practices.
There are also clear red flags that can indicate the presence of gaps before a formal assessment is even complete. One warning sign is the recurrence of incidents even when controls appear to be in place—this suggests those controls are ineffective or bypassed. Another is when a control is documented but not directly linked to a risk in the register. Gaps may also be suspected when no performance metrics are tracked, no test results are logged, or when treatment plans stall due to lack of assignment. If a critical risk is marked as “treated” but no controls are listed in the system, that is a significant red flag. CRISC professionals treat these clues as signs that a deeper review is required. On the exam, look for scenario language that suggests disconnect, delay, or silence in expected governance activity. These are usually strong indicators that a gap is present and must be addressed.
Once gaps have been identified, they must be prioritized for remediation. Not every gap poses the same level of risk. The highest priority goes to risks with no controls at all—these represent unmanaged exposure. Next are risks with weak or ineffective controls, especially when those risks have high impact potential, involve sensitive data, or could trigger regulatory penalties. Risks that could affect business-critical operations or derail strategic objectives must also rise to the top of the list. CRISC professionals evaluate gaps not only by risk scoring but by alignment with business needs and stakeholder expectations. Centralized tracking—through an issue log or GRC platform—helps ensure nothing is lost and that progress is visible to governance teams. On the exam, expect questions that ask which gap should be addressed first. The best answers will involve unmanaged, high-impact risk areas or gaps that reflect complete absence of treatment.
Every identified gap must be documented in a consistent and auditable way. This can be done through a standalone “gaps register” or integrated into the organization’s broader issue or action management process. The documentation should include a clear description of the gap, the source or evidence that revealed it, the associated risk or control, the recommended action, and the assigned owner with a resolution timeline. Governance teams must review this register regularly to track progress, approve resource allocations, and escalate unresolved or high-risk issues. CRISC professionals ensure that documentation supports transparency, accountability, and audit readiness. On the exam, scenarios involving missed remediation often stem from gaps that were informally tracked or never logged at all. The strongest answers reflect structured documentation that supports follow-through and monitoring.
Communicating identified gaps is a critical step in turning findings into corrective action. Executive summaries are used for high-priority or high-impact gaps, providing senior leaders with the information they need to make timely decisions. Dashboards and scorecards are helpful tools for visualizing gap distribution, trends, and status. Communication must reach all relevant audiences, including risk owners, IT teams, compliance officers, and process owners. Escalation paths must be defined in advance so that urgent or unresolved issues are brought to the right forums without delay. CRISC professionals ensure that gap communication supports governance—not just awareness. On the exam, if a scenario describes persistent failure or silence around known issues, the root cause may be in communication breakdown. The correct answer will involve raising visibility, structuring reporting, and ensuring that communication is built into remediation oversight.
Identifying a gap is only the beginning. CRISC professionals must also ensure that the loop is closed after remediation actions are completed. This means retesting the control, re-evaluating the risk, and updating treatment plans and register entries. Once changes have been implemented, scoring may need to be adjusted to reflect reduced exposure. Governance thresholds, such as risk appetite or tolerance, must also be re-validated to confirm that the new state falls within acceptable limits. Lessons learned from the remediation process should be shared with relevant teams and incorporated into future assessments to prevent similar issues from recurring. On the exam, the concept of “closing the loop” is often implied in scenario questions. Correct responses will involve validation, documentation, scoring updates, and governance review—not just problem identification.
CRISC exam questions on gaps assessment test your ability to think through the risk lifecycle and trace how problems can be identified, communicated, and resolved. You may be asked why a risk materialized, and the correct answer may be a missing control, poor ownership, or a stalled treatment plan. You may be asked what is missing from a treatment plan, and the answer may be test results, a control mapping, or a governance review step. Some questions will ask how to detect gaps, and the strongest answers will include coverage mapping, audit review, and structured process tracing. If a control fails, you may be asked what happens next, and the best response will involve reassessing risk, documenting the gap, and launching a formal remediation plan. The most effective exam answers reflect structure, traceability, and governance integration—three core traits of a mature, gap-aware risk program.
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Episode 80: Reviewing Risk and Control Analysis for Gaps Assessment
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