IS
Audit Basics: The Core of IT Auditing
就電腦稽核領域的專業證照而言,我想大多人直覺聯想到是CISA(國際電腦稽核師)、CISSP(國際資訊安全管理師),但是這兩項證照主要領域為資訊系統稽核(IS Auditing)、資訊科技治理(IT Governance)或是資訊科技安全(IT Security)。對於電腦稽核的另一重要應用領域:電腦輔助查核技術(CAATS: Computer-Assisted Audit Techniques),涉入的並不多。
Tommie Singleton, CISA, CGEIT, CPA
ISACA Journal Volume 6, 2014
With the advent of the latest wave of
information technologies such as big
data, social media, technologies as a service and the cloud in general, it is
worth taking the time to revisit the basics of IT audit. Usually, when such new
technologies arise, the issues are the same as something in the past, and the
way to address the emerging technology is to do what IT auditors always
do when faced with challenges of new technologies. We go back to the core of IT auditing and what IT
auditing is all about. It is about identifying
risk and the appropriate controls to
mitigate risk to an acceptable level.
Three
Things an IT Audit Is Not
But first, especially for those new to the profession and for those outside our profession, it should be
noted what IT auditing is not. It is
not about ordinary accounting
controls or traditional financial auditing. That knowledge and skill set served
the audit profession well from the beginning of auditing in the middle ages (with exchequers and other forms of
auditing) until the introduction of
computing systems in the 1950s. In fact, before 1954, it was possible for an auditor to use a
very similar audit program from day one of his/her career until he/she retired.
To put it simply, the use of computers
in accounting systems
introduced a new source of risk
associated with accounting processes and information (i.e., data). And, it
introduced the need for those who
understand this new “thing” to identify
and mitigate the risk.
IT auditing is also not compliance testing. Some believe IT auditors are about making
sure people conform to some set of
rules—implicit or explicit—and that what we do is report on exceptions to the
rules. Actually, that is management’s job. It is not the compliance with rules that is of interest to IT
auditors. IT auditors are examining whether the entity’s relevant systems or business processes
for achieving and monitoring compliance are effective. IT auditors also assess the design
effectiveness of the rules—whether they are suitably designed or
sufficient in scope to properly mitigate the target risk or meet the intended
objective.
Compliance failures are important to IT auditors, but for reasons beyond the keeping of rules. A compliance failure can be,
and often is, the symptom
of a bigger problem
related to some risk factor and/or control, such as a defective system or business process,
that can or does adversely affect the entity. Thus, to the IT auditor,
compliance failures are much more about risk (ultimately) than the rules
themselves.
【關注systems or
business processes】
It is also passé to automatically or
casually consider IT considerations
of an audit to be out of scope because it is not explicitly related to some stated requirement, or to consider
an audit to be a waste of time. The fact is IT can and does adversely affect business processes or financial data
in ways of which management may not be adequately aware.
ISACA
thanks Tommie for his years of service to the Journal and the association. Your
words have influenced many professionals and will continue to do so. Wishing
you the very best as you end this chapter and begin the next!
Unique
Inherent Risk
IT presents risk factors (風險因子) that are unique to accounting, auditing and systems. That is, IT itself brings risk to the entity regarding its systems, business processes and
financial/accounting processing. That risk is unique to IT and without IT being present, that risk would not exist—at
least not to the same level. It takes a professional, such as an IT auditor, to identify and assess the
inherent risk associated with IT.
Those risk factors include systems-related
issues, such as systems development, change management (變更管理) and vulnerabilities, and other technology-specific factors.
Apart from the IT professional, such risk can go unnoticed, to the detriment of
the entity. For example, a university had the following experience related to its financial aid systems.
The university’s IT department wrote its own code for financial aid. The
university had a great deal of financial aid available as a private institution, leading to the
majority of students receiving some form of aid. The experienced IT auditor, seeing these
facts, identified certain inherent
risk associated with financial aid including the accuracy of the code, the possibility of a bug in the code, and the possibility of fraudulent code that needed to be addressed, examined and
mitigated. However, management of the university
did not recognize any risk and
assumed the IT department had done its due diligence and everything about the
financial aid code was acceptable. A few years later, the university accidentally
discovered a bug in the code that
was causing calculations of financial aid to be overstated. Millions of dollars
of financial aid had been awarded over those years in error, and the
institution had some financial problems causing it to abandon some of its
programs. This case is offered to illustrate the need to identify and assess
the inherent risk associated with IT to the entity.
Given that almost all entities employ some
level of IT, the day has come when these entities truly need an IT auditor to evaluate
their inherent risk of IT. IT auditors are particularly trained and skilled at
doing that task. IT auditors are capable of identifying the nature and risk of
IT technologies and systems.
Back to the emerging technologies issues,
the place to start with them is to properly assess the nature, specificity and assessed level of
risk. Once this process is thought
through diligently, the IT auditor and others can begin to put together adequate controls to
satisfactorily mitigate risk.
The
Role of Controls
One of the main reasons for a control is to
mitigate some identified risk. The way to deal with an inherent risk that is at a level higher than what is acceptable is
to implement an effectual
control to mitigate that risk
to an acceptable level.
That being said雖然如此, there are some points to remember about controls and the role they
play in IT auditing, or auditing in general. First, IT auditors need to
be wary of false security by a
control that is effective enough to mitigate the risk to an acceptable level.
While experienced IT
auditors are generally good at this exercise, management and others may not be as adept at
understanding the reality of a control.
On the other hand, IT auditors should remember and keep in mind
that controls introduce a cost and a
benefit. The cost is almost always in real dollars—cost of identifying, designing, implementing
and managing the control. The cost can also be an impact cost of inconvenience or operational
efficiency in slowing down a process. Some of the latter is not so much a
concrete observation as it is an understanding of, and taking into account, the
impact of a control. A key for IT auditors has been seeking a balance between these costs
(real/concrete and impact) and benefits. Benefits can also be real and concrete—understanding
the relative difference in having the control operate effectively and doing
without it. That balance is easier to describe than to discern effectually.
For instance, an organization wants to implement an effective password policy for the length
of life for passwords. The common wisdom is that the life should be
inversely correlated with the amount of risk associated with unauthorized
access (未授權存取). That
is, if there is a high risk
associated with unauthorized access, the life should be short (e.g., 90 days
for an online bank account). However, once that policy is implemented, there
could be an unintended cost
associated with forgotten passwords due to the frequency of changes in them.
The result could be users frequently forgetting passwords and having to use
entity resources for assistance in obtaining access—a cost that includes delays
and frustration, among other results. Thus, the key is due diligence in
assessing the real net benefit of a control.
Another consideration is that an entity has
a business or purpose for which it is in operation. That purpose needs to be
part of the consideration. It is easy to lose sight of the unintended impact on operations.
Generally speaking, the higher the inherent
risk, the higher the interest should be in a
control to mitigate that risk. IT auditors need to, therefore, consider the
level of inherent and residual risk when
conveying recommendations for controls.
Last, controls are often embedded in technologies or systems.
That fact alone suggests that IT auditors need to be involved in assisting with the design
where independence allows it. It also suggests a high importance for using IT
auditors to assess the effectiveness
of the internal control system. How can the control embedded in IT be properly
assessed without an IT
subject-matter expert providing assistance in understanding how effectively the
control operates?
Understanding
the Real Residual Risk (剩餘風險)
One of the issues with analyzing risk is
that it is usually relative
and subject to judgment.
All constituents want controls to be “good enough” so that things will be
“okay.” But, what is “good enough” and what is “okay”? Risk is not usually
subject to an absolute measurement.
Bad
managers have a tendency to misjudge or misapply
controls and risk. Concerned with surviving and making a profit, they sometimes
do not see the reality of residual risk and rush ahead only to encounter a bad
result. Or, they get paranoid and avoid a perfectly acceptable risk and take no
action to their detriment. Good
managers, however, understand the reality of residual risk, and usually make
the right decisions and often have a contingency
plan (應變計畫) should the risk come to the forefront. One of the challenges for IT
auditors is to help managers be good or great managers by understanding the real residual risk and
taking the appropriate action related to it.
One challenge in understanding the reality of residual risk is to properly assess
risk and controls holistically. First, some controls are not IT and there is a
tendency by some to overlook a manual
control that has the potential to mitigate an IT-related risk. For
instance, review and
reconciliation by a controller may adequately reduce/mitigate the risk
of unauthorized access to data and databases. That is, if someone were able to
compromise the access controls, or lack thereof, and compromise data in a
financial/accounting database, any error or fraud created would be caught
promptly and corrected. Thus, the residual risk may be relatively low
considering the manual control.
Second, a residual risk that exists in one
area may be addressed by an effective control in another area. For instance, it
may be that a firewall
has inadequate protection against an outsider coming through the perimeter and
hacking into the system. It would be easy to jump to conclusions about the
high-level residual risk related to financial data and financial reporting, for
example; however, if the entity has strong access controls at the network layer (網路層) (e.g., a strong Active Directory control matrix and logical segregation of duties),
at the application layer (應用層), and over the operating system and database access, what are
intruders going to do once they gain access through the perimeter? Therefore,
it is crucial to do a mental walk-through of how the perceived residual risk
will play out if it becomes reality, to determine if it is a real residual
risk. This example assumes the audit objective was related to financial
reporting. Obviously, if this situation were one where the audit objectives
were related to systems in general (internal audit) or the firewall in
particular, the residual risk would be real and need attention. Either way, the
firewall is broken and probably needs to be fixed.
Scoping the residual risk means the IT
auditor also needs to have a mental
map of all the broken things in the IT space and which ones are
real/relevant and which ones are broken; but out of scope. (The truth is, all
IT audits will likely unveil several things, but they may not all be in scope.)
It is also crucial that the IT auditor
develop a rational argument for why something found in the IT audit needs to be
addressed and remediated, and ensure that it makes sense from a business perspective.
The tendency of IT auditors is to find broken things and want them all fixed because
they are broken. However, IT auditors need to examine from a business
perspective what really needs to be fixed. The rationale should be a
reasonable, realistic, business-oriented scenario of a relatively high risk
that would come to fruition.
These issues illustrate the need for IT
auditors to be effective communicators.
Conclusion
What IT auditors do is usually contained in
risk and control
arenas. Therefore, it is critical that IT auditors be adept at understanding,
analyzing and communicating results related to risk and controls and what we
do.