The appropriate controls provide assurance that data is changed only in accordance with management’s criteria. In March 2017, the New York State Department of Financial Services (DFS) issued 23 NYCRR 500, Cybersecurity Requirements for Financial Services Companies. IT risks and controls must be evaluated from the top down. In today’s interconnected global hypercompetitive business environment, the use of technology is expanding and the pace of the introduction of ever more complex technology is increasing. This framework serves as a tool for both management and CPAs in preparing for and conducting a SOC-C engagement. This issue of The Bulletin addresses these and other questions relating to technology risks and controls. The following are common types of IT risk. These assertions provide a context for assessing IT risks. To help organisations implement risk driven security controls, security standards have been developed to control cyber risks. These rules require that companies 1) maintain comprehensive policies and procedures related to cybersecurity risks and incidents; 2) establish and maintain appropriate and effective disclosure controls and procedures that enable them to make accurate and timely disclosures of material events, including those related to cybersecurity; and 3) have policies and procedures in place to thwart insider trading during the period between when a material cybersecurity incident is discovered and is publicly disclosed. They can be positioned at either the source of the risk (preventive) or downstream from the risk source within a process (detective). Federal and state regulators have not ignored the importance of companies protecting their electronic assets. An important aspect of managing a company’s overall business risk, including its continuation as a going concern, is its ability to effectively address business continuity and disaster recovery. For example, the AICPA’s Trust Services’ control criteria are security, availability, processing integrity, confidentiality, and privacy. An information technology audit, or information systems audit, is an examination of the management controls within an Information technology (IT) infrastructure. Application and data owners are the business groups interfacing with business-process owners, and are responsible for business and accounting information that is generated by the applications. Our Technology Risk group has deep experience and skills to help our clients better comprehend and manage technology, cyber and information risks. The goal of this GTAG is to help internal auditors become more comfortable with general IT controls so they can talk with their Board and exchange risk and control ideas with the chief information officer (CIO) and IT management. SOC-C’s process is similar to evaluating and reporting on the design and effectiveness of ICFR (required for publicly traded companies by PCAOB Auditing Standard 2201, An Audit of Internal Control over Financial Reporting) in that it gives management the responsibility to design and implement a cybersecurity risk management program (CRMP) and to evaluate whether program controls are effective to achieve management’s objectives. They also include so-called “programmed controls” within the applications that perform specific control-related activities, such as computerized edit checks of input data, numerical sequence checks, validation of key fields, and exception reporting and related follow up on exceptions. Businesses urgently need to recognise this new risk profle and rethink their approach to the risks and controls relating to this technology in a structured way. AdButler.ads.push({handler: function(opt){ AdButler.register(165519, 461033, [300,600], 'placement_461033_'+opt.place, opt); }, opt: { place: plc461033++, keywords: abkw, domain: 'servedbyadbutler.com', click:'CLICK_MACRO_PLACEHOLDER' }}); Frameworks designed to address information technology risks have been developed by the Information Systems Audit and Control Association (ISACA) and the International Organization for Standardization (ISO) [Control Objectives for Information and Related Technologies (COBIT) and ISO 27001 Information Security Management, respectively]. In 2017, the average cost of a data breach in the United States was $7.35 million, or approximately $225 for each lost or stolen electronic record. })(); if (!window.AdButler){(function(){var s = document.createElement("script"); s.async = true; s.type = "text/javascript";s.src = 'https://servedbyadbutler.com/app.js';var n = document.getElementsByTagName("script")[0]; n.parentNode.insertBefore(s, n);}());} var AdButler = AdButler || {}; AdButler.ads = AdButler.ads || []; Business Risk Respond to governance requirements Account for and protect all IT assets. The program, which takes 15.5 hours to complete, is described as for “practitioners who are interested in providing cybersecurity advisory services and want to build their competencies in and understanding of these types of services.” It also cautions, “Participants must have either IT expertise or access to IT professionals who possess the skills to perform this work.” Given the pace of change in cybersecurity risk, CPAs who want to build a practice in SOC-C should consider hiring individuals with specialized IT and cybersecurity skills. The costs include identifying the breach, notifying the affected parties, downtime, recovery, repairs, lawsuits, and customer losses (2018 Cost of a Data Breach Study, IBM, https://ibm.co/2WJ475C). Risk Management Projects/Programs. Better controls and insights result in better information. Risk control is the set of methods by which firms evaluate potential losses and take action to reduce or eliminate such threats. This evaluation must be directed to (1) processes and applications that the company operates, and (2) processes and applications that the company outsources to external service providers. With respect to IT controls, analyzing and closing gaps could take an extended period of time to remedy. While many companies are counting on information technology to curb fraud, it also increases some risks. Management also should have oversight processes in place to ensure effective control of the specific processes that directly impact the integrity of applications and data. There are general controls and there are application controls. SOC for Cybersecurity Description Criteria. If the entity is sophisticated in identifying and responding to cybersecurity risks, the description and control criteria will help identify gaps in its CRMP. document.write('<'+'div id="placement_456219_'+plc456219+'">'); The service auditor’s report must meet certain criteria to be acceptable to the company’s auditors. Risk Analysis. In a SOC-C consulting engagement, CPAs provide guidance to an entity developing a CRMP, helping to identify control deficiencies and making recommendations for improvement using the AICPA’s cybersecurity risk framework. This innovation comes with a heightened level of risk. Neither the programmed controls nor the application around the programmed controls are changed, resulting in the controls no longer performing as or when intended by management. It is safe to say that the independent auditor will have ITrelated risks and controls strongly in mind when evaluating the basis for management’s assertions in the internal control report. None of these risks are great enough to dissuade companies from expansive use of technology, but they are things that should be planned for and protected against. These might include the CFO, CISO, IT staff, and internal auditors. The objective of the risk management program is to reduce risk and obtain and maintain DAA approval. The data suggest that the cost of a breach isolated to payroll records of a business with only five employees, bimonthly pay periods, and operating for 10 years could be nearly $300,000. As high-profile corporate data breaches continue to occupy headline space, businesses are grappling with how to confront a serious risk that changes on an almost daily basis. These assertions provide a context for assessing IT risks. These controls can be used to mitigate risk for the better protection of mission-critical information and the IT systems that process, store, and carry this information.The third step in the process is continual evaluation and assessment. Information Technology General Controls • IT risk assessment • Organization-wide or IT Specific • Security policy and IT policies and procedures • Acceptable Use Policy • Network and financial application administrators • Shared accounts limited • Network and financial application password parameters • UC/lc and Alphanumeric This comparison process is similar to when the COSO internal control framework was updated in 2013 to include a heightened focus on fraud, IT, and outsourcing risks, and many entities found control gaps in these areas. While this does not mean that strong controls cannot exist within the company’s processes, it does mean that upper management has not communicated clearly the need for such controls, nor is there consistent monitoring of the environment. Even some manual controls are dependent on technology, e.g., comparing a computer-generated report to something, making sure the general ledger and sub-ledgers agree, using performance metrics to monitor certain activities, etc. By David W. Dodd; 04/01/13; Enterprise risk management (ERM) is a continuing responsibility that requires monitoring the environment for changes in the nature and severity of risks, and responding accordingly. The evaluation of all control systems must be continuous, not one-and-done. If management chooses to omit evaluation of the privacy criteria, the SOC-C report would be silent with respect to the design adequacy and operating effectiveness of privacy program controls, possibly creating an expectations gap regarding CPAs’ responsibilities. Organizations or individuals able to implement security for assets by using this model must first identify and categorize the organization’s IT assets that need to be protected in the security process. The IT general controls constitute the IT processes that could have a direct impact on the integrity of applications and data. Through this service, we gain a better understanding of technology risks and assess the related controls to help management implement better controls. The controls that mitigate these risks are important because of their pervasive effect on the reliability, integrity and availability of processing and relevant data. ©2020 Protiviti Inc. All Rights Reserved. Other states and state agencies have, or are in process of developing, cybersecurity-related rules and regulations (e.g., Massachusetts, Colorado, Vermont). Management cannot outsource the application and data-owner roles, as those individuals are responsible for the application-specific controls and how they are used in the business process. Information systems (IS) are important assets to business organizations and are ubiquitous in our daily lives. The National Institute of Standards and Technology (NIST) describes a continuous improvement process framework designed to specifically assist companies in developing a robust process to identify and address cybersecurity risks. In a weak entity-level control environment, overall policies and guidance setting forth expectations for developing and maintaining strong process-level controls often are nonexistent or lacking. The company’s ability to meet its obligations to file timely, complete and accurate reports with the SEC could be impacted if it is not prepared to deal with unexpected events through comprehensive, up-to-date business-continuity and disaster-recovery plans. Organizations use risk assessment, the first step in the risk management methodology, to determine the extent of the potential threat, vulnerabilities, and the risk associated with an information technology (IT) system. However, given the volume and complexity of transactions, compensating controls may not be possible. A material weakness determination will result in an assertion that internal control over financial reporting is ineffective. In order to minimize losses, it is necessary to involve risk management and risk assessment in the areas of information technology and operational risks. Credentials like the Certified Information Systems Auditor (CISA) and Certified Information Systems Security Professional (CISSP) can help deepen relevant skills. Why is IT important? AdButler.ads.push({handler: function(opt){ AdButler.register(165519, 461032, [300,250], 'placement_461032_'+opt.place, opt); }, opt: { place: plc461032++, keywords: abkw, domain: 'servedbyadbutler.com', click:'CLICK_MACRO_PLACEHOLDER' }}); Information Technology Risks and Controls . They also include processes for monitoring performance of controls, including monitoring exception reports (e.g., security breaches). All rights reserved. These control considerations arise around critical process flow points at which the application makes calculations, performs data validation and edit checks, interfaces electronically with other systems, limits access to transactions and data, and sorts, summarizes and reports critical financial information that is relied upon as complete and accurate by management. var abkw = window.abkw || ''; In addition, this guide provides information on the selection of cost-effective security controls. Business Risk and Controls Advisor Senior- Technology/Information Security/Risk Management USAA Phoenix, AZ Just now Be among the first 25 applicants There are a number of different ways that information technology risks can have an extensive impact on a business. Disclosure and internal controls seem to be commanding the headlines these days, with particular emphasis on complying with Sections 302 and 404 of the Sarbanes-Oxley (SOA) legislation. Developing an understanding of the context, impactand probabilityof each identified … Application controls are more specific to individual business processes. If automated and manual controls are not evaluated on an integrated basis, gaps in controls or unjustified reliance on undocumented controls may result. Start studying Chapter 7 Information Technology Risks and Controls. By closely understanding our clients’ issues and strategies, we can design methods to manage their risks which also further their business objectives. A SOC-C examination may even reduce an entity’s cyber-security insurance premiums. Information technology risk is the potential for technology shortfalls to result in losses. 14.3.4 Design of Security Management IT risks are the events that depict “what can go wrong” to cause failure to meet or achieve the fundamental assertions. The CPA Journal 14 Wall St. 19th Floor New York, NY 10005 [email protected]. AdButler.ads.push({handler: function(opt){ AdButler.register(165519, 456219, [300,600], 'placement_456219_'+opt.place, opt); }, opt: { place: plc456219++, keywords: abkw, domain: 'servedbyadbutler.com', click:'CLICK_MACRO_PLACEHOLDER' }}); var AdButler = AdButler || {}; AdButler.ads = AdButler.ads || []; Information Technology General Controls • IT risk assessment • Organization-wide or IT Specific • Security policy and IT policies and procedures • Acceptable Use Policy • Network and financial application administrators • Shared accounts limited • Network and financial application password parameters • UC/lc and Alphanumeric This information technology risk assessment template can be used to perform routine maintenance tasks and ensure the continuous and optimum performance of servers. None of these risks are great enough to dissuade companies from expansive use of technology, but they are things that should be planned for and protected against. The individual billings are summarized and the corresponding revenue is recorded in the general ledger. In 2011, the SEC issued CF Disclosure Guidance: Topic 2—Cybersecurity, and in February 2018, it issued additional interpretive guidance about companies’ cybersecurity risk and incident disclosures. Create mechanisms and metrics (such as higher-than-normal volumes) to enable the monitoring of risk levels and control effectiveness, in real time wherever possible. Learning Module 6: Information Technology Risks and Controls Outline Definition of internal control Control Frameworks o COBIT o COSO o Control Activities Control Activities Risk Identification and Management Introduction Organisations need control systems so they are not exposed to excessive risks that: o Could harm their reputation for honesty and integrity. Top Information Technology Risks 2013. The use of information technology can lead to unauthorized access to important company data and information. Information technology (IT) plays a critical role in many businesses. Reputational and out-of-pocket cybersecurity costs create significant pressure on entities to ensure that information shared with customers, vendors, employees, and investors is safe and to comply with regulations. For example, Amazon Web Services provides SOC reports to clients who purchase website hosting services. Management may select any description or control criterion as the basis for its assertion about the entity’s CRMP and program controls, so long as the criterion selected is relevant, objective, measurable, and does not omit factors that could reasonably be expected to impact users’ decisions. Arguably, the greatest benefit of SOC-C is derived from its requirement that management identify, document, and evaluate its CRMP. var plc456219 = window.plc456219 || 0; If there are weak entity-level controls, the likelihood of consistently strong IT general controls is greatly reduced. Information Technology General Controls (ITGCs) 101 ... Validate existing controls to assess control operating effectiveness . The information technology and internal control processes an organization has in place to protect computers, networks, programs, and data from unauthorized access is often referred to as cybersecurity. In a SOC-C examination, the CPA forms a conclusion about the design of an entity’s CRMP and the operating effectiveness of its program controls based on an independent evaluation and testing. IT controls provide for assurance related to the reliability of information and information services. document.write('<'+'div id="placement_289809_'+plc289809+'">'); There are three broad areas of so-called process-level controls. The impact of IT must be considered carefully during an evaluation of internal control over financial reporting. Internal controls, pervasive and specific, are either preventive or detective. var plc289809 = window.plc289809 || 0; Just as importantly, CPAs should evaluate engagement risk before agreeing to undertake SOC-C services. Learn faster with spaced repetition. For this reason, Section 404 compliance teams should assess the IT control environment, including the general IT controls, as early as possible in the process to determine whether any gaps exist. Each option has advantages but also challenges—automation can introduce technology risk while operational controls can make systems unwieldy. IT and other control issues exist regardless of whether transaction processing takes place internally or externally. For example, in a complex environment with significant transaction volumes, reliance on detective and monitoring controls may not be effective or feasible. var plc461033 = window.plc461033 || 0; The general ledger for the operating unit is consolidated with the results of other business units by the consolidation system, which then produces the consolidated revenue amounts reported in the financial statements. IT controls help mitigate the risks associated with an organization’s use of technology. Guide to the Sarbanes-Oxley Act: IT Risks and Controls(Second Edition) provides guidance to Section 404 compli- ance project teams on the consideration of information technology (IT) risks and controls at both the entity and activity levels within an organization. Learn about the different risks to your business's information technology (IT) systems and data, including natural disasters. (function(){ These detective and monitoring controls would need to be highly detail-oriented and extensive in nature and scope. In large entities, there could be multiple IT entities requiring review. The way in which controls are designed and implemented within the company, so as to address identified risks. Overall entity-level controls relevant to IT often would include the control environment, including the assignment of authority and responsibility encompassing IT operations and application management, consistent policies and procedures, and entity-wide programs such as codes of conduct and fraud prevention that apply to all locations and business units. Phnom Penh - Information Technology Risks & Controls Management. Risks provide a context for evaluating IT and manual controls. Information security risk management, or ISRM, is the process of managing risks associated with the use of information technology. Managers and auditors use COSO’s Internal Control—Integrated Framework to evaluate the design and operating effectiveness of systems of internal control over financial reporting (ICFR). CPAs may then independently provide positive assurance about whether controls are designed and operating effectively. Cybersecurity threats are ubiquitous; they affect all businesses across all industries. Organizations use risk assessment, the first step in the risk management methodology, to determine the extent of the potential threat, vulnerabilities, and the risk associated with an information technology (IT) system. The Many Types of Technology Risk Before determining how to manage technology risk, you must understand the many types of technology risks that organizations and their supply chains face. This is essential for two main reasons: 1 AI will allow systems and businesses to become much more complex (to the point Programmed controls assure the complete, accurate, timely and consistent processing and reporting of transactions by financial reporting applications. Applications-based controls often require more time to design and build. This would give rise, at a minimum, to a significant deficiency and possibly even a material weakness in internal control. As transaction volumes and the velocity and complexity of risk increase, applications-based controls are often more reliable than people-based controls. What controls exist to mitigate risks unique to the IT environment? As an example, Ernst & Young (EY) certified certain IT security controls of Equifax using ISO Standard 27001 prior to Equifax’s 2017 security breach (Francine McKenna, “Unit of Equifax’s Auditor EY Certified the Information Security That Was Later Breached,” MarketWatch, Dec. 20, 2018, https://on.mktw.net/2VzURUU). In order of their relative importance, these processes include: Although there are related functions carried out in the IT organization(s) for each of the above activities, there is also a need for the business-process owners to have processes in place to ensure applications supporting business functions and controls are properly designed, maintained and managed in accordance with their requirements. Process owners should obtain an understanding of the application’s programmed controls when they evaluate the manual controls. Without an effective technology risk management strategy, your organization’s profitability and your reputation could be impacted. 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