How To Do A General IT Contr
How To Do A General IT Contr
How To Do A General IT Contr
Information Technology
General Controls Review
June 3, 2015
Speakers
Sharon Gallo, Manager, CISA - sgallo@sunera.com
More than 7 years of work experience providing audit and advisory services to
large multinational and smaller Fortune 1000 clients in various industries.
Expertise: Information Technology General Controls (ITGC) testing and
remediation, SSAE 16 reports, application control testing, entity level testing,
vendor assessments, and Software Development Lifecycle (SDLC) projects.
Prior to Sunera, she was a Senior within Ernst & Youngs Information Technology
Risk & Assurance practice.
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Agenda
Introductions
Speakers
What is Sunera?
Background
Overview of standard ITGCs
Audit Frameworks
How to perform an ITGC standard review
Practice Exercises
Access to Programs and Data
Program Development and Change Management
Computer Operations
Questions
What is Sunera?
Sunera is a business and technology risk management consulting firm
dedicated to reducing technology risk, designing cost-saving solutions, and
protecting our clients customers and reputations.
Core Services
Data Privacy | Internal Audit | Information Security
IT Audit | Enterprise Risk Management | Data Analytics
Technology Training | SOX Compliance | PCI
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National Reach
Los Angeles
Atlanta
Miami
Boston
New York
Calgary
Phoenix
Charlotte
Raleigh
Chicago
San Francisco
Dallas
Tampa
Denver
Toronto
Houston
Vancouver
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Background
Information Technology
General Controls (ITGCs)
Why are ITGCs important?
Information Technology General Controls (ITGCs) can be defined as internal
controls that assure the secure, stable, and reliable performance of computer
hardware, software and IT personnel connected to financial systems.
ITGCs affect the ability to rely on application controls and IT dependent manual
controls.
ITGCs are an integral part of many different operational and regulatory (federal and
state) audits, including:
o IT operational reviews
o HIPAA assessments
o SSAE16 assessments
o PCI reviews/audits
o SOX assessments
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ITGC Areas of Focus
The following areas are typically addressed as part of ITGC:
Access to Programs and Data
o Controls that prevent inappropriate and unauthorized use of the system across all layers of systems,
operating system, database and application.
- Security Policy, Password, Unique IDs, Authorized Administrators, Users Access Provisioning,
Users Access Reviews, Physical Security, Firewall, Monitoring (i.e. invalid logins, audit trails)
Program Changes
o Controls may involve required authorization of change requests, review of the changes, approvals,
documentation, testing and assessment of changes on other IT components and implementation protocols.
- Change Management Process for Regular and Emergency Changes (i.e. infrastructure and
software changes for all layers: O/S, database, application)
Program Development
o Controls over development methodology, including system design and implementation, that outline specific
phases, documentation requirements, change management, approvals and checkpoints to control the
development or maintenance of the project.
o Controls over the effective acquisition, implementation and maintenance of system software, database
management, telecommunications software, security software, and utilities.
- Software Development Life Cycle (SDLC)
Computer Operations
o Controls over the effective job configuration and scheduling, data center operations, data backup and data
recovery procedures.
- Backups, Restorations, Job Scheduling
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ITGC Approach Across all Layers
ITGCs should be applied across all layers of
the identified in-scope systems, including:
Application System
o Typically the system used by front-end users
to perform specific tasks (i.e., PeopleSoft).
Database
o Collects and stores data supporting the
application. Typically restricted to back-end
users.
Operating System
o Supports the entire organization and serves as
a back-bone to all systems (i.e., Windows).
Network
o A group of two or more computer systems
linked together that allows the exchange of
data.
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Key Terms
SOX Sarbanes-Oxley Act of 2002. U.S. federal legislation that establishes new or
enhanced requirements for financial reporting for all U.S. public company boards,
management, and public accounting firms.
PCAOB Public Company Accounting Oversight Board. A private-sector, non-profit
corporation created by the Sarbanes-Oxley Act, to oversee the auditors of public
companies.
COBIT Control Objectives for Information and Related Technology. A comprehensive
framework for management of the governance of risk and control of IT, comprising 5
domains, 37 IT processes and 210 control objectives. COBIT includes controls that address
all aspects of IT governance, but only those significant to financial reporting have been used
to develop this document.
COSO Committee of Sponsoring Organizations of the Treadway Commission. A
private-sector initiative, formed in 1985 to identify the factors that cause fraudulent financial
reporting and to make recommendations to reduce its incidence. COSO has established a
common definition of internal controls, standards, and criteria against which companies and
organizations can assess their control systems.
ISACA Information Systems Audit and Control Association. International professional
organization for information governance, control, security and audit professionals. Its
auditing and control standards are followed by practitioners worldwide.
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COSO vs. COBIT
The most common framework used to evaluate ITGCs is the COBIT framework
COSO vs. COBIT
Established to provide a generic Established by ISACA to be used for the
framework for evaluating internal controls. IT component of documenting and testing
SECs suggested Internal Controls internal controls.
Framework for Sarbanes Oxley.
Addresses application controls and Comprehensive framework for managing
general IT controls at a high level. risk and control for IT.
Does not dictate requirements for control More detailed and IT specific.
objectives and related controls activity.
Not a comprehensive Internal Controls
framework.
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COBIT 4.1 Mapped to COSO
The Control Objectives for Information and related
Technology (COBIT) defines an IT governance
framework. COBIT
4.1
Control Environment The control environment
sets the tone of an organization, influencing the
control consciousness of its people.
Risk Assessment Every entity faces a variety of
risks from external and internal sources that must
be identified and analyzed at both the entity and
the activity level.
Control Activities These policies and
procedures help ensure management directives
are carried out (e.g., preventive, detective, and
mitigating controls).
Information and Communication Pertinent
information must be identified, captured, and
communicated in a manner and timeframe that
supports all other control components.
Monitoring The monitoring process assesses
the quality of the systems performance over time
by reviewing the output generated by control
activities and conducting special evaluations.
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ITGC Framework
COBIT 5 Overview
COBIT 5
The focus of COBIT 5 is on processes, that are
split into governance and management areas.
These two areas contain a total of 5 domains:
Governance of Enterprise IT
o Evaluate, Direct and Monitor (EDM) Provides
direction to information security and monitoring the
outcome
Management of Enterprise IT
o Align, Plan and Organize (APO) Provides direction
to solution delivery (BAI) and service delivery (DSS),
o Build, Acquire and Implement (BAI) Provides the
solutions and passes them to be turned into services,
o Deliver, Service and Support (DSS) Receives the
solutions and makes them usable for end users, and
o Monitor, Evaluate and Assess (MEA) Monitors all
processes to ensure that the direction provided is Across these 5 domains, COBIT has
followed. identified 37 IT processes that are
generally used by an organization as well
as specific practices.
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Mapping PCAOB AS 5 to COBIT 5
Processes to Identify Relevant ITGC controls
COBIT 5 processes mapped
to PCAOB Auditing Standard
No. 5
Identifies ITGCs that have a
direct impact on the audit of
the effectiveness of internal
controls over financial
reporting (SOX section 404)
which can be used as a
baseline for non-public
organizations.
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How to Perform an ITGC
Standard Review
Phase 1 Phase 2 Phase 3
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Phase 1 Phase 2 Phase 3
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Phase 1 Phase 2 Phase 3
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Phase 1 Phase 2 Phase 3
Request Type Control Ref# Key Control Activity System Requested Items
1. Download and save "Script 4" from the link listed to the right
(i.e. cell F17) to the desktop of the production server where the
Population A standard password policy Windows Active domain controller is installed.
has been defined and critical Directory
2. Extract the Windows Server - Domain Policies Script" to the
applications and supporting desktop.
DSS 05.02b
platforms are configured 3. Double click the Windows Server - Domain Policies Script
according to the corporate file.
standard. 4. Wait for the DOS command prompt windows to close.
5. Provide a copy of the output files (i.e. WinDomainPolicies.vbs)
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Phase 1 Phase 2 Phase 3
Sample Selection
Samples are selected based on:
Frequency of Control: Determined by the assumed population of control
occurrences per year and risk level.
Population Size Sample Size
Frequency
(typical) (typical)
Annual 1 1
Quarterly 4 2
Monthly 12 2 to 5
Weekly 52 5 to 10
Daily 250 20 to 40
Multiple Times per Day 250+ 25 to 45
Inherent Risk: The measure of auditor's assessment that the control will
not operate as intended (control failure).
o High
o Medium
o Low
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Phase 1 Phase 2 Phase 3
Non-Statistical Sample Section The auditor may employ some bias when selecting
the sample.
Haphazard The auditor selects a sample from a population without following a structured
technique, however avoiding any conscious bias or predictability.
Judgmental The auditor intentionally places a bias on the sample (e.g., all sampling units over a
certain value, all for a specific type of exception, all negatives, all new users, etc.) selected from a
population
Note: Population - the entire set of data from which a sample is selected and about which the IT
Auditor wishes to draw conclusions.
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Phase 1 Phase 2 Phase 3
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Phase 1 Phase 2 Phase 3
Testing Methods
Methods for testing ITGCs:
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Phase 1 Phase 2 Phase 3
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Phase 1 Phase 2 Phase 3
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Phase 1 Phase 2 Phase 3
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Phase 1 Phase 2 Phase 3
Note: Corroboration is useful only if the other party does not have prior
knowledge of the question being asked.
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Phase 1 Phase 2 Phase 3
Notes:
Observation - During observation, evidence must be retained that support the control
being observed. Observation is a weaker form of assurance than the other procedures
and should be performed in conjunction with other procedures where possible.
Re-Performance - Not typically performed as part of ITGC testing.
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Phase 1 Phase 2 Phase 3
Example
Control Description: DSS 05.04a Unique identities are required for system access. Group
or shared logins are disabled. Users are uniquely authenticated to the system to support the
validity of transactions and system administrators do not use generic standard system
accounts (e.g., root, sa) to login to critical systems. Vendor supplied default and generic
passwords are removed or changed.
Test Procedures:
1. Inquire of IT Management to gain understanding of how users are uniquely authenticated to systems
and whether vendor supplied default and generic passwords are removed or changed.
2. Obtain a complete list of user IDs from the manager of each key application and platform and inspect
the entire population of user IDs to determine that unique IDs are used.
3. For system components that utilize vendor supplied default and generic accounts, obtain evidence to
verify that default accounts and passwords have been changed.
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Phase 1 Phase 2 Phase 3
Example
Control Description: DSS 04.07a Procedures are in place to ensure that systems are
backed up according to the backup operating procedures.
Test Results:
1. Inquired with the Disaster Recovery Manager, Lucy Lu, on March 1, 2015, and noted that for
Windows AD servers, daily differential backups are performed Monday through Thursday, and a full
backup is performed on Friday. It is noted that the weekly rotational backup tapes are stored at the
companys co-located site (Iron Mountain) for a period of 5 weeks. The only IT staff members with
keys to the safe are the IT Operations Manager, Janice Houston, and the Manager of Business
Systems & Development, Roger Wallace.
2. Obtained and inspected the Backup and Restore policy from the Disaster Recovery Manager, Lucy
Lu, on March 2, 2015, and noted the following:
o Differential Backups are performed for all Windows AD Servers on a daily basis. No
exception noted.
o Weekly rotational backup tapes are stored in the backup tape drive at the companys co-
located site (Iron Mountain) for a period of 5 weeks. No exception noted.
3. Inspected the Backup and Restore policy on March 2, 2015, and noted that the CTO, Bill Johnson,
reviewed and updated the policy on January 20, 2015. No exception noted.
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Phase 1 Phase 2 Phase 3
Test Workpapers
Example
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Practice Exercise #1
Access to Programs and Data
Practice Exercise #1
Access to Programs and Data
Control Description:
Only authorized individuals have Administrator access to PeopleSoft on the
application level.
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Practice Exercise #1
Access to Programs and Data
Control Description : Only authorized individuals have Administrator access to
Peoplesoft on the application level.
Sample Size: The sample size for a system access control is the entire population of user
accounts.
Testing Steps:
1. Inquire with IT to gain an understanding of how the security is configured in the
PeopleSoft application.
2. Observe IT generate a system query to obtain the list of PeopleSoft users.
3. Compare the list of administrators to the IT organization chart or active employee listing
to determine if user access is in line with job responsibilities.
4. Inquire with IT Management to determine if the individuals with administrator access are
appropriate.
Supporting Evidence:
1. User Access List.
2. If available, a copy of the IT organization chart and/or HR reports (active employees,
new hires, terminations from beginning of audit period to present).
o If available, system documentation.
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Practice Exercise #1
Access to Programs and Data
Documenting the Test Results:
1. Internal Audit (IA) inquired with the IT Application Implementation and Support Manager, Janet
Jackson, on March 2, 2015, and noted that only users with the Super User role had
administrator access within the PeopleSoft application.
2. IA observed Janet Jackson execute a system query to generate the list of the PeopleSoft
users on March 2, 2015. IA filtered the user list in Microsoft Excel by the Super User role.
3. IA obtained the job titles for the users with administrator access from the Director of Human
Resources, Johnny Depp, on March 3, 2015, to determine if the users access were in line
with job responsibilities, and noted the results in the table below. Further, no developers had
been granted administrator level access. No exception noted.
4. Inquired with Janet Jackson, on March 4, 2015 and corroborated the inquiry with Ellie
Goldberg, Director of IT Applications and noted that all users with administrator access were
appropriate. No exception noted.
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Practice Exercise #2
Program Development & Change
Management
Practice Exercise #2
Program Development & Change Management
Control Description:
Requests for normal changes to application systems, data structures, or any
other information systems software or devices running in the production
environment, are documented in a change management request form and
authorized by the designated approver, where applicable, either through a work
order or change request form.
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Practice Exercise #2
Program Development & Change Management
Control Description : Requests for normal changes to application systems, data
structures, or any other information systems software or devices running in the
production environment, are documented in a change management request form
and authorized by the designated approver, where applicable, either through a work
order or change request form.
Sample Size: The sample size for a program development/change control is based on the entire
population of changes, frequency and level of risk.
Testing Steps:
1. Inquire with IT to gain an understanding of the Change Management process and how
changes are approved. Obtain the formal Change Management policy/procedure, if
available.
2. Observe IT execute a system query to obtain a listing of changes promoted to the production
environment at all layers.
3. Select a sample of changes and obtain supporting documentation.
4. Inspect the forms for appropriate approval.
Supporting Evidence:
1. Change Management policy/procedure, if available.
2. Change Approval Matrix.
3. Computer-generated listing of OS, application, database changes.
4. Sample support documentation (i.e., work order, change request form, approvals).
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Practice Exercise #2
Program Development & Change Management
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Practice Exercise #3
Computer Operations
Practice Exercise #3
Computer Operations
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Practice Exercise #3
Computer Operations
Control Description: Automated data retention tools have been implemented to manage
the backup and retention data plan and schedule. Backup logs are reviewed daily and
documented in the Backup Log check sheet.
Sample Size: The sample size for computer operations control is based on the
entire population of changes, frequency and level of risk.
Testing Steps:
1. Obtain backup schedule (for in-scope applications) from the automated tool from
the backup administrator.
2. Randomly select a sample of days.
3. From sample, obtain history file and determine that jobs were run according to
policy.
4. Obtain backup log check sheet and determine that jobs were run according to
backup schedule.
5. If jobs were not run according to policy, determine that they were investigated and
resolved.
Supporting Evidence:
1. Computer Operations policy/procedure, if available.
2. Backup schedule from backup tool for in-scope servers.
3. History files for backup jobs.
4. Backup log check sheet.
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Practice Exercise #3
Computer Operations
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Pop Quiz!
1. Which of the following would not be in scope in a general computer control
review?
a. Change Management
b. Operating System Security
c. The Financial Statement Close Process
d. Physical Security
2. Access to systems and data should be assigned on a need-to-know basis True
or False?
3. Inquiry alone is a suitable way to test a control True or False?
4. The appropriate sample size required to test a general computer control is
always:
a. 1
b. 30
c. The entire population
d. None of the above
5. The programmer who developed a new piece of code is the most appropriate
individual to migrate that new code into the production environment True or
False?
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Pop Quiz! (Answers)
1. Which of the following would not be in scope in a general computer control
review?
a. Change Management
b. Operating System Security
c. The Financial Statement Close Process
d. Physical Security
2. Access to systems and data should be assigned on a need-to-know basis
True or False?
3. Inquiry alone is a suitable way to test a control True or False?
4. The appropriate sample size required to test a general computer control is
always:
a. 1
b. 30
c. The entire population
d. None of the above
5. The programmer who developed a new piece of code is the most appropriate
individual to migrate that new code into the production environment True or
False?
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Questions
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