CPCSC Level 2 Control

Last updated June 25, 2026

03.01.20Access control

CPCSC Level 2 03.01.20: Use of External Systems

Apply use of external systems to control who can access in-scope systems, how information flows, and which access paths are allowed for CPCSC Level 2 readiness. This guide separates the official ITSP.10.171 control language from practical implementation, evidence, auditor questions, and related controls.

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Formal Control Language

Official ITSP.10.171 wording for 03.01.20. Use the Cyber Centre publication and contract requirements as the source of truth for certification, assessment, or procurement submissions.

  • Prohibit the use of external systems unless they are specifically authorized
  • Establish the following terms, conditions, and security requirements to be satisfied on external systems prior to allowing use of or access to those systems by authorized individuals: [Assignment: organization-defined security requirements]
  • Permit authorized individuals to use an external system to access the organization's system or to process, store, or transmit specified information only after: verifying that the security requirements on the external system as specified in the organization's system security and privacy plans have been satisfied
  • retaining approved system connection or processing agreements with the organizational entities hosting the external systems
  • Restrict the use of organization-controlled portable storage devices by authorized individuals on external systems

Contains information sourced from Government of Canada material used under the Open Government Licence - Canada.

What This Means In Plain English

Use of External Systems is part of the CPCSC Level 2 Access control family. This is about making access decisions enforceable. The organization needs to know who can reach specified information, which systems can exchange it, and which access paths are approved.

For a founder, CISO, engineer, or compliance owner, the practical question is whether use of external systems is visible in real operating evidence: a setting, workflow, ticket, log, approval, review, or exception record that can survive an external assessment.

Level 2 is different from Level 1 because the evidence has to survive an external assessment. A policy statement helps, but the stronger answer is a record that shows who did the work, when it ran, what system setting or workflow enforced it, and how exceptions were handled.

How To Implement It

1

Define the in-scope systems, owners, users, vendors, and data flows affected by use of external systems.

2

Use identity groups, network rules, conditional access, remote-access approvals, data-flow boundaries, and exception records to make the access rule real in systems.

3

Translate the formal requirement into one or two operating procedures: who performs it, how often, where it is recorded, and who approves exceptions.

4

Configure the relevant systems so the control is enforced by identity, endpoint, cloud, network, ticketing, monitoring, vendor, or documentation workflows rather than memory.

5

Keep evidence in a consistent folder, GRC system, ticket queue, or audit workspace so an assessor can trace the control from requirement to implementation to review.

Evidence Normally Gathered

Use of External Systems: access policy and role matrix.

Use of External Systems: identity provider groups.

Use of External Systems: access review records.

Use of External Systems: remote access configuration.

Use of External Systems: data-flow or boundary diagram.

Use of External Systems: exception approvals.

Use of External Systems: owner assignment and review cadence.

Use of External Systems: exception, remediation, or POA&M records when the control is not fully implemented.

Common Auditor Questions

Where is use of external systems implemented in the in-scope environment?

Who owns use of external systems, and how do they know it is operating?

Show the evidence that proves use of external systems ran during the assessment period.

What happens when use of external systems fails, is bypassed, or has an exception?

How does this control connect to the system security plan, risk register, POA&M, and related CPCSC controls?

Sources

Source and attribution.

Formal control language is sourced from the Canadian Centre for Cyber Security ITSP.10.171 publication. CPCSC Level 2 assessment context references the Government of Canada CPCSC program overview and ITSP.10.171-01 assessment guidance.

CPCSC Program OverviewITSP.10.171ITSP.10.171-01Open Government Licence - Canada