Do all of these run continuously during the Type II observation window?
Yes — Type II observes operating effectiveness over 6–12 months. The auditor will sample evidence from random months, so any cadence you skip can become an exception.
Can we tool this with Drata / Vanta / Secureframe?
Yes for evidence collection (access reviews, MFA enforcement, scan reports). No tool replaces the manager-signed access review, the tabletop, or the management review — the human signoff is the control.
What's the difference between Type I and Type II for ongoing cadence?
Type I attests controls exist on a single date. Type II attests they operated over time — meaning every recurring item in this calendar must be evidenced through the observation window.
Do we need quarterly access reviews if we have automated provisioning?
Yes. Automated provisioning addresses joiner/mover/leaver risk, but auditors still expect manager-attested certification of who currently holds privileged access — automation alone fails CC6.2.