Term Paper: Planning an IT Infrastructure Audit for Compliance
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Chapter 5 Goals When you complete this chapter, you will be able to:
• Define the scope and frequency of an audit
• Identify the key requirements for an audit
• Understand the importance of risk management in assessing security controls
• Identify the information and resources needed for an IT audit
• Relate the IT security policy framework to the seven domains of IT infrastructure
• Understand why monitoring requirements help with an IT audit
• Identify security control points
• Differentiate between the project management tasks of an IT audit
Defining the Scope, Objectives, Goals, and Frequency of an Audit
The scope, objectives, goals, and frequency of audits are based on a risk assessment. Depending on the risk, the frequency of audits varies. Critical systems controls might need to be monitored more often than noncritical controls. In more high-risk situations, automated or continual audit tests might be considered.
Prior to performing an audit, the auditor should first define the audit scope. The scope includes the area or areas to be reviewed as well as the time period. Experienced auditors know it’s just as important to define what will be audited as it is to define what will not be audited. If scope is not clearly defined, scope creep occurs, likely increasing the auditor’s workload. Scope creep is a term common to projects where the plans or goals expand beyond what was originally intended.
The audit objective is the goal of the audit. Both scope and objective are closely related. For the audit to be effective, the scope must consider the objectives of the audit. Defining scope requires consideration of the personnel, systems, and records relevant to the objective. Time is another consideration dependent upon the objective. The depth and breadth of an audit usually determines the time frame required to meet the objectives.
An external audit of financial controls, for example, will likely have a more narrow scope than an internal audit of information technology (IT) controls. When defining
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the scope, the auditor should consider the controls and processes across the seven domains of IT infrastructure. This includes relevant resources such as the following:
• Data • Applications
• Technology
• Facilities • Personnel
It is important for auditors to ensure the scope is sufficient to achieve the stated objectives. Restrictions placed on the scope could seriously affect the ability to achieve the stated objective. Examples of restrictions that an organization may place on an auditor that could have such a negative impact include the following:
• Not providing enough resources • Limiting the time frame
• Preventing the discovery of audit evidence
• Restricting audit procedures
• Withholding relevant historical records or information about past incidents
Project Management
An audit is a project. As with any project, proper planning is necessary. Auditors should be familiar with the Project Management Institute (PMI), which has created a standard named A Guide to the Project Management Body of Knowledge (PMBOK). This guide provides a well-known and applied framework for managing successful projects.
A project, such as an audit, has three important characteristics. First, a project is temporary. This means it has an identified start and end date. Unlike operations or a program, a project lasts for a finite time period. Second, a project is unique and produces unique results. At the end of the project, a deliverable is produced. Although projects might be similar, the process, resources, constraints, and risks, for example, will differ. Finally, a project is progressively elaborated. Because each project is unique, the process is more dynamic. Projects will occur in separate steps. As the process continues, the next phase becomes clearer.
Projects require someone to manage them. This position is often given the title of project manager. Large projects and even audits might have a dedicated project manager. Other times, the person managing the project might be the project expert. Project management requires the management of three competing needs to achieve the project objectives. Known as the triple constraint, these include scope, cost, and time. Consider, for example, a project with a large scope, but with little time and cost. More than likely, quality will be compromised. A project manager must be aware of all three constraints at the start of and throughout the project.
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Planned audit activities also have a defined rate of occurrence, known as the audit frequency. There are two approaches to determine audit frequency. Audits can occur on an annual basis or every two or three years, depending on regulatory requirements and the determined risk. IT audits also are known for not following a predefined frequency, but instead using a continuous risk-assessment process. This is more appropriate given the fast-paced change in technology as well as the threats and vulnerabilities related to IT.
Identifying Critical Requirements for the Audit
The risk assessment will influence the critical requirements for an IT audit. Overall, there are various types of IT audits. In addition to infrastructure audits for compliance, other examples include audits specific to IT processes, such as governance and software development. Another example includes integrated audits, where financial controls are the focus.
Auditing IT infrastructure for compliance incorporates the evaluation of various types of controls. IT organizations today are concerned with controls relating to both security and privacy. Traditionally, privacy and information security activities are separate activities. The two, however, have become more interrelated, and coordination between the two has become a priority for many organizations. Two major factors contributing to this are regulatory issues and the rapid growth and widespread use of the Web. As a result, both privacy and information security are converging, specifically around compliance issues.
Implementing Security Controls
Before an evaluation of controls can begin, the auditor must first identify the critical controls. To do so, the auditor must consider the audit scope and objective along with the risk assessment. Documentation and any preliminary interviews also help to identify the requirements.
Controls can be classified into different groups to aid in understanding how they fit into the overall security of a system. Figure 5-1 illustrates the different dimensions of control classifications. Understanding the classifications provides auditors with a foundation to identify and assess critical controls.
A high-level classification of controls for IT systems includes general and application controls. General controls are also known as infrastructure controls. These types of controls apply broadly to all system components across an organization. Application controls apply to individual application systems. Types of application controls include various transaction controls, such as input, processing, and output controls.
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FIGURE 5-1 Control classifications.
Three IT security controls covered by the National Institute of Standards and Technology (NIST) include management, operational, and technical controls. The following list provides a description and examples of each of these:
• Management controls—These include controls typically governed by management as part of the overall security program. Examples include the following: • Security policy
• Security program management
• Risk management
• Security and planning in the system development life cycle • Assurance
• Operational controls—These include controls that are implemented by people rather than systems. These controls are often interrelated with both management and technical controls. Examples include the following:
• Personnel and user issues
• Contingency and disaster planning • Incident response and handling
• Awareness, training, and education
• Computer support and operations
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• Physical and environmental security
• Technical controls—These include controls that are performed by the IT systems. Examples include the following: • Identification and authorization
• Logical access control
• Audit trails
• Cryptography
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Controls are further classified as being preventive, detective, or corrective. Preventive controls stop a particular threat in the first place. A door lock on a home is a simple example of a preventive control. A detective control identifies that a threat is present. A home alarm system, for example, is a common detective control. (Some people even advertise they have an alarm system by putting a notice on the door or a sign in the yard. In this case, this also serves as a preventive control.) Finally, a reactive or corrective control can lessen the effects of a threat. A home alarm system that also notifies the police department is an example of a reactive control.
NOTE
Antivirus software is a common control that spans all three controls. It can prevent a system from getting a virus in the first place. It can detect if a virus is on the system. Finally, it can react and correct the situation by removing or quarantining the virus.
Protecting Privacy Data
Audits of IT infrastructure relating to security are common. However, due to recent legislation regarding the need to protect personally identifiable information, audits specific to privacy are more commonplace than before. ISACA defines privacy within the context of information systems as “adherence to trust and obligation in relation to any information relating to an identified or identifiable individual (data subject). Management is responsible to comply with privacy in accordance with its privacy policy or applicable privacy laws and regulations.”
Privacy audits go beyond traditional IT audits in that the entire information lifecycle process needs to be considered. This includes not just the controls relating to how it was gathered and secured, but also how it is collected, used, and retained. Specifically, privacy audits address the following three concerns:
• What type of personal information is processed and stored?
• Where is it stored?
• How is it managed?
Table 5-1 outlines guidance for privacy audits established by the American Institute of Certified Public Accountants (AICPA) and the Canadian Institute of Chartered Accountants (CICA). This guidance is named Generally Accepted Privacy Principles (GAPP).
A privacy audit should consider what privacy laws apply to the organization. Auditors should consider who has responsibility for privacy within the organization. This includes the roles of legal counsel and whether a chief privacy officer (CPO) role is established. (The CPO is a senior-level position responsible for the overall management of an organization’s privacy program.) Finally, the policies and procedures specific to privacy should be examined.
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TABLE 5-1 The Generally Accepted Privacy Principles.
PRINCIPLE DESCRIPTION
Management The entity defines, documents, communicates, and assigns accountability for its privacy policies and procedures.
Notice The entity provides notice about its privacy policies and procedures and identifies the purposes for which personal information is collected, used, retained, and disclosed.
Choice of consent
The entity describes the choices available to the individual and obtains implicit or explicit consent with respect to the collection, use, and disclosure of personal information.
Collection The entity collects personal information only for the purposes identified in the notice.
Use and retention
The entity limits the use of personal information to the purposes identified in the notice and for which the individual has provided implicit or explicit consent. The entity retains personal information for only as long as is necessary to fulfill the stated purposes.
Access The entity provides individuals with access to their personal information for review and update.
Disclosure to third parties
The entity discloses personal information to third parties only for the purposes identified in the notice and with the implicit or explicit consent of the individual.
Security for privacy
The entity protects personal information against unauthorized access.
Quality The entity maintains accurate, complete, and relevant personal information for the purposes identified in the notice.
Monitoring and enforcement
The entity monitors compliance with its privacy policies and procedures and has procedures to address privacy-related complaints and disputes.
Assessing IT Security
Examining IT security is a key component of auditing IT infrastructure for compliance. An audit can help identify fraud, ineffective IT practices, improper use of resources, and inadequate security. Assessing IT security is largely about ensuring that adequate controls are in place. Controls cost money, however. The selection and implementation of controls must be a result of a consideration of risk.
Suppose you want to build a fence to protect a cow. Building the fence will cost money. Exactly how much money it will cost might depend upon the quality and size of the fence.
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How much might you be willing to spend? Of course, you should first understand why you want to protect the cow. How valuable is this cow to you? What are you protecting the cow from? Let’s assume the cow has some type of value to you— otherwise, there would be little reason to spend money on protecting the cow. Is a fence the only solution? Could you tie the cow to a tree instead? If you decide to build the fence, is it strong enough? Is it high enough? Now suppose you decide to have the security of your fence assessed. What you don’t need is for the auditor to come by and tell you what you already know— that you have a fence in place. Rather, what would be useful is a determination of the lack of controls, the ineffectiveness of controls, or even the use of unnecessary controls. If your cow turns out to be a bull, for example, perhaps that fence won’t be so effective. Is the fence effective against someone determined to steal the cow? To understand these issues, consider the following:
• Is a control even required? • How much effort or money should be spent on a control?
• Is the control effective?
Understanding the answers to these questions requires thought about risk. This is why risk management needs to be a key part of organizations and any audit.
Risk Management
Managing and understanding risk is a key operating component of any organization. Risk is about uncertainty. Yet, there will always be uncertainties across organizations. Uncertainty presents both challenges and opportunities for companies. Risk management provides a method for dealing with the uncertainty. This includes identifying which ones to accept and which ones to control. The Committee of Sponsoring Organizations (COSO) of the Treadway Commission, which provides a framework for enterprise risk management (ERM), identifies the following key components of ERM:
• Aligning risk appetite and strategy—This helps the organization to manage the uncertainty with consideration of the goals of the organization.
• Enhancing risk response decisions—This improves the organization’s ability to make decisions about how to better manage risk.
• Reducing operational surprises and losses—This enhances the organization’s ability to identify potential events or threats and react appropriately.
• Identifying and managing multiple and cross-enterprise risks—This helps the organization to consider related risks from across the organization and provides a unified response across the varying risks.
• Seizing opportunities—This helps the organization to recognize events from which new opportunities can be pursued. • Improving deployment of capital—This improves how organizations divide their financial resources to enhance
performance and profitability.
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An example of an IT risk framework compatible with ERM is ISACA’s Risk IT. The Risk IT framework is completely covered with the Control Objectives for Information and Related Technology (COBIT) framework. Risk IT provides a comprehensive framework not just for assessing risk, but also for governance and response. Combined with Risk IT and another framework, Val IT, COBIT 5 provides a framework of controls to minimize as well as manage risk. Another example of an information security risk management framework is ISO standard ISO/IEC 27005. In addition to providing guidelines for information security risk management, this ISO standard also supports the concepts within ISO/IEC 27001.
The key component of risk management includes a risk assessment. Planning an audit of IT infrastructure depends on this assessment. The audit plan should be prepared only after a risk assessment is complete. The key reason for this is that the audit will focus on those areas with the highest risk.
There are several methodologies for assessing risk specific to IT environments. NIST 800-30, “Risk Management Guide for Information Technology Systems,” is one such example. This guide provides a practical nine-step process, as follows:
• System characterization—Identify and understand the systems and their operating environment. • Threat identification—Identify potential methods or situations that could exploit a weakness. • Vulnerability identification—Identify flaws or weaknesses that can be triggered or exploited, which might result in a
breach.
• Control analysis—Analyze controls to reduce the likelihood of a threat successfully exploiting a vulnerability. • Likelihood determination—Determine the likelihood of an attack by considering the motivation and capability of the
threat source along with the nature of the vulnerability in relation to the current controls. • Impact analysis—Determine the impact of a successful attack on a vulnerability by a threat. Consider the mission of a
system, data criticality, and data sensitivity.
• Risk determination—Consider the likelihood, magnitude of impact, and adequacy of controls as an equation of risk. • Control recommendations—Consider controls to reduce the level of risk to an acceptable level. • Results documentation—Document for management the observations on threats and vulnerabilities as well as risks
overall and recommended controls.
Evaluating risk requires looking at the different parts of the risk equation. Effective risk management starts with identifying the IT assets and their value. Next, organizations need to identify the threats and vulnerabilities to these assets. A threat is any activity that represents a possible danger. A vulnerability is a weakness. An analysis or assessment of both threats and vulnerabilities is a key part of the risk-management process. Next,
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organizations need to identify the likelihood each threat will exploit a vulnerability. Finally, organizations need to consider the impact of the risk. Risks should then be prioritized. This enables organizations to give attention to the most severe. Different methodologies are available, which provide clear frameworks for evaluating risk.
NOTE
Threats don’t pertain to all organizations equally. This is part of what makes threat identification a difficult task. A simple example is the threat of a hurricane. Although a hurricane is a threat that can cause a loss, you wouldn’t consider a hurricane a threat to a data center based in Iowa, for example.
Threat Analysis
Part of the risk-assessment process requires an examination of those activities that represent danger. Threats to IT are numerous and can affect the loss of confidentiality, integrity, and availability in a number of ways. Analyzing the potential threats requires the identification of all possible threats first. This is called threat identification.
Threats can be grouped as a combination of the following:
• Adversarial • Accidental
• Structural
• Environmental
Information about threats such as natural disasters is readily available and easily obtained through private and governmental resources. The threats that are more difficult to identify are those that pertain specifically to the organization. Table 5-2 provides examples of various adversarial threat sources. The table includes a list of threats, motivations, and methods that might be used to carry out an attack. The methods are also known as threat actions.
All the threats in Table 5-2 represent varying degrees of potential risks if they are accompanied by vulnerabilities. Each organization will identify its unique threats. Even businesses with multiple locations will have threats specific to that location. To really understand threats, think about your own personal situation. What threats are common to you and where you live? Do these threats change as you travel? What threats exist based on your lifestyle and goals?
You need to consider likelihood when examining threats. Using the example of a hurricane earlier in this section, it is safe to say that the threat of a hurricane affecting the state of Iowa does not exist. The threat of a tornado, however, does exist. As a result, organizations should develop a threat classification mechanism. A simple example may include a classification of low, medium, and high:
• Low—No previous history of the threat, and the threat is not likely to occur • Medium—Some history of the threat, and the threat might occur • High—Substantial history of the threat, and the threat is likely to occur
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TABLE 5-2 Examples of threats, motivations, and threat actions.
THREAT MOTIVATION THREAT ACTION
Cracker Criminal Challenge Ego Social engineering System intrusion
Monetary gain Destruction of information
Computer crime Fraudulent act
Information bribery
Terrorist Destruction Exploitation Revenge
Bomb System penetration
System tampering
Espionage Competitive advantage Economic espionage
Economic exploitation Information theft
Social engineering
Insiders Curiosity Ego
Revenge Unintentional errors
System bugs System sabotage
Unauthorized access Computer abuse
Vulnerability Analysis
After performing a threat analysis, you need to identify weaknesses or flaws. Specifically, you need to identify vulnerabilities that can be exploited by the previously identified threats. This is known as vulnerability analysis. There are many ways to identify vulnerabilities. Examples include the following:
• Vulnerability lists and databases published by industry organizations
• Security advisories
• Software and security analysis using automated tools
TIP
The MITRE Corporation catalogs vulnerabilities in the Common Vulnerabilities and Exposures (CVE), which includes tens of thousands of items.
It is important to consider threats relative to vulnerabilities. Think about operating system patches issued by Microsoft or Apple. Typically, these fix potential vulnerabilities, which were previously unknown and have since been discovered. In most cases, these vulnerabilities affect a particular piece of the system. Say, for example, Microsoft issues a patch to fix a vulnerability for a particular service of the operating system. However, what if you don’t use this service or the service is turned off? In this case, the vulnerability is not really vulnerable. What if the particular system you use does not and will never be connected to the Internet? In this case, the threat in question does not exist. This is why
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it is important to pair threats with vulnerabilities. Threats are matched with existing vulnerabilities to further understand the risk. Finally, likelihood and impact must be considered. What is the likelihood that a particular threat can exploit a specific vulnerability? If that occurs, what would be the impact?
Consideration of all these elements involves tradeoffs. For example, you can do many things to remove or reduce specific threats and vulnerabilities in your personal life, but you might choose not to. You might even choose not to apply specific controls that can reduce the risks. Many of these decisions are based on your goals and personal tradeoffs. As you consider these concepts, think about the following:
• Why do some people live in areas with higher crime rates?
• Why doesn’t everyone wear a bulletproof vest?
• Why do you ride in or drive vehicles when there are approximately 40,000 vehicle deaths per year in the United States? • Why do some people spend more money on home security systems than others?
Risk Assessment Analysis: Defining an Acceptable Security Baseline Definition
Given the previous inputs, the final step is to determine the level of risk. When pairing threats and vulnerabilities, risk is determined primarily by three functions:
• The likelihood of a threat to exploit a given vulnerability
• The impact on the organization if that threat against the vulnerability is achieved
• The sufficiency of controls to either eliminate or reduce the risk
At this point, matrixes and other mechanisms are useful for qualitatively understanding risk. Such matrixes typically categorize the impact and likelihood of threats as low, medium, or high. The product of this results in a risk being low, medium, or high.
An alternative approach is to analyze impact and likelihood quantitatively. Such matrixes might use percentage values or a numerical count instead of defining what is high versus medium. Quantitative risk analysis, while more accurate and objective, can also be more time-consuming and expensive.
Applying controls to a system helps eliminate or reduce the risks. In many cases, the goal is not to eliminate the risk. Rather, what’s important is to reduce the risk to an acceptable level. Applying controls is a direct result of the risk-assessment process combined with an analysis of the tradeoffs. Several examples of the tradeoffs include the following:
• Cost—Are the costs of a control justified by the reduction of risk? • Operational impact—Does the control have an adverse effect on system performance? • Feasibility—Is the control technically feasible? Will the control be feasible fors end users?
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An effective risk-assessment process helps establish known good baselines for IT systems. A baseline is the system in a known good state, with the applied minimum controls relative to the accepted risk. Baselines provide a solid and simple method from which to audit a system. Comparing a system against a baseline can help identify nonexistent controls that should be applied as well as controls that have been removed or disabled. Additionally, a baseline audit can help identify a system that has been compromised or otherwise altered.
NOTE
The best security is layered. This means the information system is composed of multiple controls operating at different layers. This is similar to a castle and its location high on a hill surrounded by a moat, a series of walls, and then locks and guards.
An information system may have security controls at different layers in the system. For example, an operating system or network component typically provides an identification and authentication capability. An application may also provide its own identification and authentication capability, rendering an additional level of protection for the overall information system. As organizations select and specify security controls, they should consider components at all layers in the information system to provide effective security architecture and privacy.
In addition to the results of the risk assessment, numerous best-practice baselines exist to help organizations select appropriate security controls. These include the many documented standards from NIST. Several of these are introduced later in this chapter.
Obtaining Information, Documentation, and Resources
The COBIT framework provides a good starting point for auditors to assess IT controls. Before beginning an audit, however, the auditor needs to first gather information from people and relevant documentation as well as identify required resources. The information the auditor needs before performing an audit includes the following:
• An understanding of the organization and what its business requirements and goals are
• Knowledge of how the security program is currently in place
• Industry best practices for the type of organization and systems
Documentation related to business structure, configuration, and even previous audits should be gathered and reviewed. In many cases, auditors will need to request further documentation during the course of the audit. At any point, if the auditor is not given adequate documentation, the auditor should notify the responsible personnel.
In addition to understanding the regulatory and industry requirements to which the organization must adhere, auditors should have a much larger understanding of the business. General knowledge about the business can be gained by gathering information on business and reporting cycles, key business processes, and key personnel to interview. Strategic objectives of an organization reveal details about the organization in the future
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and how this will affect its information systems. In addition, information about the operational objectives for internal control provides relevant information with regard to the current state of the organization.
An organization’s written policies are among the most important documents for an auditor. They provide a guideline from which to check the environment for gaps. More specifically, the auditor can determine whether the organization is stating it is doing something that it is not.
There are many other types of documentation that should be gathered depending upon the scope of the audit across the seven domains of IT infrastructure. Examples include the following:
NOTE
Documentation is a good sign that an organization has a sound security program in place. Other documents should include standards, procedures, previous audit reports, risk assessments, and network diagrams.
• Administrative documentation
• System documentation • Procedural documentation
• Network architecture diagrams
• Vendor support access documents and agreements
Existing IT Security Policy Framework Definition
The results of an audit will reflect how well an organization is adhering to its security policy. However, risk management must be considered. How well an organization adheres to its own policy when combined with an assessment risk helps to identify any gaps. For example, are there control objectives not defined in the policy that should be?
Frameworks exist to help with risk-management programs, security programs, and policy creation. ISO/IEC 27002, for example, provides a structured way for organizations to determine their IT security policy. Accounting and audit firms traditionally had their own interpretations of security standards. They, however, have been increasing the use of existing frameworks for benchmarks. It is important for the auditor to know upon what framework an organization has based its policy. This allows better alignment between the organization’s policy and the audit. Most internal audits, to ensure compliance across the IT infrastructure, will align with the comparable framework.
Many organizations now have taken steps to implement a security policy framework. However, there are still many instances in which the policy is not actually being enforced. Additionally, information security policies are living documents. Business environments change. Technologies change. Risks change. As a result, companies with existing policy frameworks might discover that their policies are outdated. The IT security policy must be managed as an ongoing program to evolve with changing requirements and ensure adherence.
NOTE
An IT audit doesn’t just assess adherence to the security policy; it also uncovers situations in which the policy needs to be refined.
TIP
It is a good practice to have executive management approve and sign each high-level policy and provide a statement about the importance of the policy and how it helps support the objectives and goals of the organization.
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Finally, policies are fundamental to the organization’s actions. The policies drive the behavior of the people within an organization and even the technologies acquired. One of executive management’s responsibilities is to set goals. Management further supports these goals with a set of objectives. These objectives are communicated throughout the organization by policies. This applies not just to IT security policies but also to policies across the organization. The policies set the standards, which help drive the business to achieve its goals. An organization’s policies are quite important if they are expected to drive actions and behaviors from the top down. Therefore, high-level policies should be approved and signed by executive management.
Configuration Documentation for IT Infrastructure
The auditor will gather documents related to the configuration of the systems being audited. Although a single system component is possibly made up of thousands of configuration elements, the following are examples of items the auditor should gather from documentation:
• Host name
• Internet Protocol (IP) addresses
• Operating system • Patch level
• Hardware specifications
• Installed software
• Protocols • Service configuration
• User accounts
• Password settings
• Audit log settings
Applications that reside on the computer systems might also have their own configuration documents. These should be gathered as well. Finally, network documentation is required for the network segments pertaining to the applications and systems being audited.
Many organizations will have standard configuration documents for role-specific systems. Examples include the configurations for the following:
• Firewalls
• Web servers
• Mail servers
• Domain Name System (DNS) servers • File Transfer Protocol (FTP) servers
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Interviews with Key IT Support and Management Personnel: Identifying and Planning
Interviews play an important role in both the information-gathering process and during the audit. Interviews with IT management, for example, can reveal expectations about the organization to the auditor. Interviewing IT support personnel can reveal pertinent information that might not otherwise be discovered. These interviews can also provide greater focus in areas that need it. For example, those personnel doing the daily work can help identify weak controls and broken processes.
Properly conducted interviews might even reveal more serious violations such as fraud. Effective interviews often result in employees offering information about fraud and other serious activities, even when hotlines and other reporting processes exist. These conversations should be an interview, however, and not an interrogation. A friendly and nonthreatening environment fosters openness and honesty with those being questioned. The Institute of Internal Auditors (IIA) defines the audit interview as “a specialized form of communication used to gain information and assist in evaluation.”
Although interviews play a key role throughout the audit, they help to further define the scope during the planning phase. Individual interviews alone might be reason enough to expand the scope. Interviews looked at collectively can provide the auditor with more information. Taken together, these interviews might reveal patterns. Interviews can aggregate enough data to reveal new information. Reasons to expand the scope from the initial interviews can vary, but common examples include the following:
• Lack of controls
• Override of controls • Fraudulent activity
Some of the most valuable information for audits will be a result of the interview. Therefore, the interview and how well it is performed can make a difference in the outcome of the audit. A simple framework for conducting effective interviews is composed of the following six steps:
• Preparing • Scheduling
• Opening
• Conducting
• Closing • Recording
Preparing for the interview is essential. It is important to be cognizant of others’ time and of the job functions they must continue to accomplish even during an ongoing audit. The auditor should prepare a list of questions or at least go into the meeting knowing exactly what it is he or she hopes to achieve or learn. Additionally, an auditor should think like a psychologist. Be aware of the positions and the personalities of those being
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interviewed. Preparation and scheduling can happen in parallel. It is important, however, to ensure that enough time is given for preparation. When scheduling, the auditor should try to remain as flexible as possible.
The next two steps constitute the actual interview. The opening sets the tone for the remainder of the interview. Opening with a positive tone and clear expectations, combined with thorough preparation, makes conducting the interview much easier. This leads us into the next step, which is asking the questions. At this point, however, it is not enough to have well- thought-out questions. The auditor must be adept at listening as well. The auditor should understand the reporting hierarchy and how management might influence the interviewee’s responses. Closing the interview occurs after the auditor has asked all the required questions or when time is up. The interview should ideally end politely and on an upbeat note. The auditor should thank the interviewee for his or her time and suggest an agreed-upon protocol should the auditor require anything else. This leads into the final step of recording. Taking notes is certainly acceptable during the interview process, but it can be disruptive to the interview flow. Even if notes are taken, after the interview, the auditor should immediately review the notes and organize them as needed.
NIST Standards and Methodologies
NIST 800-53 and NIST 800-53A are two important and widely used standards from NIST. They provide a catalog of security controls and a framework to assess the controls, respectively. As with the ISO/IEC frameworks, many organizations base their policies on NIST. NIST provides many more standards, including low-level documentation that has proven useful for internal auditing and assessments.
The Computer Security Division (CSD) of NIST provides several popular publications. All of their publications reflect their research on IT security issues. The publications they provide include the following:
• Special Publications—The 800 series publications, sometimes called Special Publications, provide general-interest documents for the IT security community. NIST also publishes the 500 series of Special Publications, which covers IT.
• NIST Internal Reports (NISTIR)—The NIST Internal Reports (NISTIR) are publications that describe niche technical research.
• Information Technology Laboratory (ITL) Bulletins—The Information Technology Laboratory (ITL) Bulletins publications provide an in-depth look at timely topics of importance.
• Federal Information Processing Standards (FIPS)—The Federal Information Processing Standards (FIPS) are standards documents published by NIST and approved by the secretary of commerce.
Of these four different document types, the Special Publications from NIST are more likely to be used for audits and assessments. The publications are known for their depth
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and prescriptive stance. In addition to the two standards listed at the beginning of this section, the following are examples of other NIST Special Publications:
• SP 800-50, “Building an Information Technology Security Awareness and Training Program” • SP 800-57, “Recommendation for Key Management”
• SP 800-58, “Security Considerations for Voice Over IP Systems”
• SP 800-61, “Computer Security Incident Handling Guide” • SP 800-68, “Guide to Securing Microsoft Windows XP Systems for IT Professionals”
• SP 800-70, “National Checklist Program for IT Products—Guidelines for Checklist Users and Developers”
• SP 800-95, “Guide to Secure Web Services”
• SP 800-115, “Technical Guide to Information Security Testing and Assessment” • SP 800-123, “Guide to General Server Security”
The preceding list provides several examples of the many different publications from NIST. SP 800-70 defines the National Checklist Program (NCP). The NCP is a government repository of available security checklists or baseline configurations for operating systems and applications.
Mapping the IT Security Policy Framework Definitions to the Seven Domains of a Typical IT Infrastructure
The IT security policy framework includes policies, standards, and guidelines. Each of these includes technology, processes, and personnel. The seven domains of a typical IT infrastructure need to be mapped into the framework. The seven domains of a typical IT infrastructure are as follows:
• User Domain • Workstation Domain
• LAN Domain
• LAN-to-WAN Domain
• WAN Domain • Remote Access Domain
• System/Application Domain
In some cases, policies might be very specific to only a single domain. For example, the User Domain maps specifically to human resources security. This encompasses controls relating to items such as pre-employment background checks and information security awareness and training. The seven domains also map across various high-level areas. Examples include access control and operations management.
technical TIP
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It is helpful to map the infrastructure against the control objectives for the audit. This can provide a clear scope and ensure that every necessary element is addressed against the control objectives. A challenge for auditors is considering the components or pieces of the IT infrastructure that relate to a key issue. Consider the common example of financial reporting. It is not just the application controls that need to be assessed. Even a single financial reporting system may rely on many supporting technologies across the various domains of IT infrastructure. As a result, it is important when developing an audit plan to have a complete picture of all processes and technology across the infrastructure. A security policy framework can help with scope planning by defining boundaries. It also ensures the consideration of all relevant pieces such as interconnected systems to achieve the audit objective. Mapping the security policy framework to the seven domains of IT infrastructure helps define appropriate boundaries for the audit.
Standards further help align the seven domains to the security policy. This includes, for example, access control requirements for networks, users, applications, and operating systems. Just as IT infrastructure needs to be organized within a policy framework, the infrastructure needs to be considered within the framework used for an audit.
The IT universe includes all the auditable resources or components within an organization. Naturally, the seven domains of typical IT infrastructure are a large part of this IT universe. The IT universe may be defined as one or more domains of IT infrastructure or even a portion of a single domain. In addition, the IT universe may describe specific entities, locations, functions, or processes within the organization.
Identifying and Testing Monitoring Requirements
Perhaps one of the most important and beneficial elements of an IT security program for auditors is monitoring. All frameworks include a control objective for regularly assessing and monitoring IT systems and controls. For example, COBIT places a heavy emphasis on monitoring, as defined by the key areas within the framework. COBIT states that continuous monitoring and evaluation of a the control environment helps provide answers to the following questions:
• Is IT performance measured to detect problems before it is too late?
• Does management ensure that internal controls are effective and efficient?
• Can IT performance be linked back to business goals? • Are adequate confidentiality, integrity, and availability controls in place for information security?
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Auditors are trying to answer the same questions. Therefore, auditors should identify the tools already put in place by organizations that they can leverage to help answer these questions. Of course, one of the objectives of most audits, regardless of the IT domain being audited, is to identify and test monitoring requirements. Although organizations might have monitoring solutions in place, it doesn’t necessarily mean that they are monitoring the right things.
In addition, many companies might be monitoring the right things, but might not have a process in place to make the data actionable. Computer logs provide a perfect example. Are logs being generated? Is the correct information being captured? Is that information being maintained correctly? Are system analysts examining the log data? After analysts examine the data, are any actions taken to deal with identified problems? Depending upon the maturity of the organization, there are many systems that manage these events and information and even provide ways to correlate and make this data more manageable and actionable.
Identifying and testing whether an organization has implemented a sound program for monitoring provides a lot of the information required by an auditor. Consider the following control objectives suggested by COBIT:
• Monitor, evaluate, and assess performance and conformance • Monitor, evaluate, and assess the system of internal control
• Evaluate and assess compliance with external requirements
The outputs provided from these objectives are a valuable resource to auditors. Except in situations where these controls are nonexistent, auditors can derive usable data regardless of maturity.
Identifying Critical Security Control Points That Must Be Verified Throughout the IT Infrastructure
Adequate controls should be in place to meet high-level defined control objectives. The organizational risk assessment plays an important role in identifying the high-risk areas. Areas identified as being the most risky should be assessed as often as possible. Levels of risk across the IT infrastructure vary across organizations. This is a result of differing objectives and risk appetites. Regardless, most organizations do share common critical controls.
A great example is the Consensus Audit Guidelines (CAG) published by SANS in 2009. These guidelines are now formally known as the Critical Security Controls for Effective Cyber Defense. They include 20 technical control areas deemed critical. These 20 controls, although not prioritized in any order, do establish an overall prioritized baseline of security measures and controls that should be in place at most organizations. This provides not only a baseline from which to identify security controls, but also a way to verify them efficiently and continuously.
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NIST Special Publication 800-53, unlike the Critical Security Controls, provides a comprehensive library of security controls. The Critical Security Controls, on the other hand, only provide a subset, but are focused more on what’s believed to be the most important controls. Keep in mind that this is only a generalization. After the critical controls are addressed, further controls can be considered from the NIST document, for example.
TIP
The Critical Security Controls for Effective Cyber Defense provide an appendix that maps the top 20 critical security controls to specific controls in NIST SP 800-53.
Building a Project Plan
Having the appropriate people assigned to perform an audit is critical. This affects the effectiveness and efficiency of the audit. Consider that IT professionals could not possibly be experts across all seven domains of the IT infrastructure. Thus, it is not feasible to expect an auditor to be able to perform an adequate audit across all areas. Depending on the scope of an audit, appropriate resources must be obtained to perform the audit.
Other helpful resources include tools to support the IT auditing process. Various tools are available to assist in developing and managing the project plan and associated elements, such as tasks, deliverables, and timelines. The IIA lists several types of tools that can facilitate an audit. These include the following:
• Electronic work papers—This provides a document management system to help centralize and provide workflow management of the audit process.
• Project management software—This includes mechanisms for managing any project, including auditing projects. These software packages help track progress to established milestones. Project management software is helpful in defining the timeline of the plan and for reporting the status.
• Flowcharting software—This provides a way to visually document processes. • Open issue tracking software—This allows for easy tracking of audit deficiencies and areas that still need to be
addressed. In many cases, this function can be integrated or included with a document management system. • Audit department Web site—Internal auditing departments typically have an intranet-based solution that provides
for collaboration and communication. Even external auditors benefit from maintaining secure Internet-based portals that provide the same functions.
NOTE
Although resources and budgets can be tight, organizations need to ensure adequate auditing resources. The Public Company Accounting Oversight Board (PCAOB) Auditing Standard No. 2 states that “an ineffective control environment was a significant deficiency and a strong indicator that a material weakness exists.”
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The previous list of tools is useful for the overall management of the audit. During the course of an audit, however, auditors will likely use additional tools to aid in the efficiency and effectiveness of carrying out the audit. Various programs and utilities can help automate tests during the course of the audit. From a planning perspective, it’s important to understand that identification of such tools should be included as part of the planning process.
CHAPTER SUMMARY
Developing an audit plan is a necessary step before conducting the actual audit and reporting findings. Identifying and prioritizing risks is a key component of the audit plan. This provides the necessary information to make informed decisions about the scope and objectives of an audit and what resources will be required. Performing key tasks such as aligning the scope with the objectives and gathering all pertinent information beforehand makes the process of testing controls much easier. The auditor’s ability to conduct the audit and report on the results will be a direct reflection on the approved plan.
KEY CONCEPTS AND TERMS
Audit frequency
Audit objective
Audit scope
Baseline
Chief privacy officer (CPO)
Consensus Audit Guidelines (CAG)
Enterprise risk management (ERM)
Federal Information Processing Standards (FIPS)
Generally Accepted Privacy Principles (GAPP)
Information Technology Laboratory (ITL) Bulletins
ISO/IEC 27005
IT universe
National Checklist Program (NCP)
NIST 800-30
NIST Internal Reports (NISTIR)
Scope creep
Special Publications
Threat
Threat actions
Threat identification
Vulnerability
Vulnerability analysis
CHAPTER 5 ASSESSMENT
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