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Qestions:
1) a) Using the IT audit report for the Cancer Prevention and Research Institute of Texas (in the
Readings tab), find examples of the items that are supposed to be in IT audit report according to
Standard 1401. Indicate item and page number.
b) Comment on additional items you find in the audit report that are not part of the 1401 standard
for Audit Reporting. Explain what the benefits are of including it.
Information Technology
Internal Audit Report
Report #2013-03
August 9, 2013
Cancer Prevention and Research Institute of Texas (CPRIT)
Information Technology Internal Audit Report – FINAL Page 2
Table of Contents
Page
Executive
Summary............................................................................................................................................
.......3
Background
Information........................................................................................................................................
..4
Background
...........................................................................................................................................................
.4
Audit
Objectives..........................................................................................................................................
..........4
Scope
...........................................................................................................................................................
............5
Testing
Approach............................................................................................................................................
......5
Statement of Auditing Standards
........................................................................................................................6
Findings, Observations, and Recommendations
..................................................................................................6
IT Policies and Procedures
..................................................................................................................................7
IT Risk
Assessment.........................................................................................................................................
......8
Disaster Recovery Plan & Business Continuity
Plan.......................................................................................9
Security Access
Reviews.....................................................................................................................................11
Self-Assessment
Review.....................................................................................................................................12
Additional Recommendations
...............................................................................................................................13
Appendix A – Texas Administrative Code, Subchapter B, Rule
§202.22.......................................................15
Appendix B – Texas Administrative Code, Subchapter B, Rule §202.25 – IT Policies
...............................16
Cancer Prevention and Research Institute of Texas (CPRIT)
Information Technology Internal Audit Report – FINAL Page 3
Executive Summary
In support of the FY2013 Internal Audit Plan, a review of the information technology (IT)
process was
conducted in August 2013. The IT department is responsible for setting up and supporting IT
operations at
the Agency. The CPRIT offices are located in Austin, TX; however, the Chief Scientific Officer
has an
office in downtown Houston, which is also serviced and maintained by the CPRIT IT
department. The
department is also responsible for the Agency’s various websites, cloud services operations,
video
conference system, data closet, and typical back-office IT operations.
This was the third annual IT audit for the Agency. An internal audit of the IT processes was
performed
previously in June 2012 and May 2011. As a result of those audits, Internal Audit provided
CPRIT findings
and recommendations to improve overall efficiency and effectiveness within their IT operations.
Although
some steps have been made to remediate these findings, CPRIT needs to place importance on
establishing a
strong IT governance structure.
CPRIT continues to work towards establishing leading practices within the IT operations.
However, during
the FY 2013 IT internal audit, the following improvement opportunities were noted, in
descending priority:
· Outdated IT Policies and Procedures – In efforts to remediate the findings in the FY 2012 IT
internal audit, the CPRIT IT department recently began reviewing and creating IT policies
required
by Texas Administrative Code, Chapter 202, Subchapter B – Security Standards for State
Agencies.
However, many of the developed policies have not yet been reviewed and approved by
management.
· Incomplete IT Risk Assessment – As recommended as part of the FY 2012 IT internal audit
remediation plan, a detailed risk assessment of the IT environment has not been performed.
· Insufficient Disaster Recovery Plan and Business Continuity Plan – As recommended as part
of the FY 2012 IT internal audit remediation plan, a disaster recovery plan and business
continuity
plan has not been developed, implemented, or tested.
· Inadequate Review or Evidence of Third-Party Control Environment – the third party grants
management provider, SRA, has not provided adequate evidence of their internal control
environment to provide assurance that CPRIT’s information is secure and recorded accurately
within the application.
Cancer Prevention and Research Institute of Texas (CPRIT)
Information Technology Internal Audit Report – FINAL Page 4
Background Information
Background
Texas voters approved a constitutional amendment in 2007 establishing the Cancer Prevention
and
Research Institute of Texas (CPRIT) and authorized the state to issue $3 billion in bonds to fund
groundbreaking cancer research and prevention programs and services in Texas. To date, CPRIT
has
funded almost 500 grants totaling $835,820,450.1
CPRIT’s goals are to:
· Create and expedite innovation in the area of cancer research, thereby enhancing the potential
for a
medical or scientific breakthrough in the prevention of cancer and cures for cancer;
· Attract, create, or expand research capabilities of public or private institutions of higher
education
and other public or private entities that will promote a substantial increase in cancer research
and in
the creation of high-quality new jobs in this State; and
· Continue to develop and implement the Texas Cancer Plan by promoting the development and
coordination of effective and efficient statewide public and private policies, programs, and
services
related to cancer and by encouraging cooperative, comprehensive, and complementary planning
among the public, private, and volunteer sectors involved in cancer prevention, detection,
treatment, and research.
Audit Objectives
The main objective of the audit was to verify that the IT infrastructure is appropriately
safeguarded and that
data reliability and accuracy are maintained within the environment.
The specific audit objectives were:
· Verify that prior year audit findings had been addressed and corrected
· Validate that the Agency’s IT environment is compliant with the requirements identified in the
Texas Administrative Code, Chapter 202, Subchapter B – Security Standards for State Agencies
· Assess the overall IT function to determine whether sufficient resources and skill sets have
been
appropriated to support the technology requirements
· Evaluate whether appropriate access has been granted to the network and selected applications
· Validate whether databases are sufficiently backed-up and whether back-ups are restorable
· Confirm that the Agency follows IT general computer controls
1 Figures provided by the CPRIT website. http://www.cprit.state.tx.us/
Cancer Prevention and Research Institute of Texas (CPRIT)
Information Technology Internal Audit Report – FINAL Page 5
In order to assess the IT department, Internal Audit reviewed the following:
· Compliance with Texas Administrative Code requirements
· Internal policies and procedures
Scope
Although current legislation may potentially change procedural and reporting requirements for
CPRIT, the
audit performed was designed to evaluate and test compliance with established policies and
procedures as of
July 2013. Internal Audit interviewed staff and completed field work in August 2013.
Our procedures included discussions with the following CPRIT personnel:
Name Title
Heidi McConnell Chief Operating Officer
Alfonso Royal Finance Manager
Lisa Nelson Operations Manager
Therry Simien Information Technology Officer
Testing Approach
During the IT audit, Internal Audit performed procedures that included: inquiry, observation,
inspection
and re-performance. See the matrix below for a description listing of each type of test
performed.
Type Description
Inquiry Inquired of appropriate personnel. Inquiries seeking relevant information or
representation from CPRIT personnel were performed to obtain among other things:
· Knowledge and additional information regarding the policy or procedure
· Corroborating evidence of the policy or procedure
In conducting this internal audit, we interviewed:
· Therry Simien, Information Technology Officer
· Alfonso Royal, Finance Manager
· Lisa Nelson, Operations Manager
Observation Observed the application or existence of specific controls as represented.
Inspection Inspected documents and records indicating performance of the controls, including:
· Examination of documents or records for evidence of performance, such as
existence of required documentation and approvals.
· Inspection of CPRIT systems documentation, such as policies and procedures,
network diagrams, flowcharts and job descriptions.
Re-performance Re-performed the control activity performed by CPRIT to gain additional
evidence
regarding the effective operation of the control activity.
Cancer Prevention and Research Institute of Texas (CPRIT)
Information Technology Internal Audit Report – FINAL Page 6
Statement of Auditing Standards
This internal audit was conducted in accordance with generally accepted government auditing
standards
(GAGAS). The internal audit also follows the guidelines set forth by the Institute of Internal
Auditors (IIA)
and conforms to the Standards for the Professional Practice of Internal Auditing, the code of
ethics
contained in the Professional Practices Framework as promulgated by the IIA.
Although due professional care in the performance of this audit was exercised, this should not
be construed
to imply that unreported irregularities do not exist. The deterrence of fraud is the responsibility
of
management. Audit procedures alone, even when executed with professional care, do not
guarantee that
fraud will be detected. Specific areas for improvement are addressed later in this report.
Cancer Prevention and Research Institute of Texas (CPRIT)
Information Technology Internal Audit Report – FINAL Page 7
Findings, Observations, and Recommendations
Summary of Findings and Related Recommendations
The section below provides details regarding the audit findings and corresponding reference to
the Texas
Administrative Code rule.
Statement on FY 2012 Information Technology Audit Remediation
Following the fiscal year 2012 internal audit, the remediation of IT findings was significantly
delayed. IT
staff priorities were shifted to support the agency’s 2012 annual conference logistics, electronic
conference
registration system and electronic scientific abstract collection system; to assist legal counsel
with highpriority
data requests related to investigations; to relocate the remote office IT infrastructure from Dallas
to
Houston; and to support communication projects. As a result, longer-term, non-user related
projects (e.g.,
documentation updates) were effectively placed on hold. Management has made completion of
all
outstanding IT infrastructure and operational compliance projects a high priority during the
current year
within staffing constraints.
IT Policies and Procedures
Rule §202.25 lists suggested policies that should be created and implemented by the information
security
officer. Per the results of the FY 2012 IT audit, policies and procedures were scheduled to be
completed
and/or up-to-date by March 2013. As of July 2013, all policies and procedures have not been
finalized.
CPRIT has 11 out of 26 recommended IT policies documented. While some policies have been
developed,
none of them have been approved by management. Please see Appendix B for details around
testing of IT
recommended policies.
Recommendation: To ensure CPRIT has established proper IT governance and protocols,
CPRIT needs
to finalize its IT security policies and procedures as recommended by Texas Administrative
Code §202.25.
The agency should update all existing policies to reflect the actual processes taking place. The
policies
should also be approved by the state agency head or another designated representative.
Management’s Response:
During this audit cycle, significant progress has been made in the review, updating and creation
of IT
policies. As shown in Appendix B of the report, nearly half of the recommended policies have
been
submitted to agency senior management for final approval. IT staff is now in the process of
revising those
policies to incorporate management’s recommendations with the expectation to have this
process
completed within the next 30 days. The remaining policies and procedures will continue to be
updated
and/or created over the next several months.
Cancer Prevention and Research Institute of Texas (CPRIT)
Information Technology Internal Audit Report – FINAL Page 8
Person Responsible: Heidi McConnell / Therry Simien / Lisa Nelson
Revised Target Date for Implementation: May 31, 2014
Prior Year (FY 2012) Audit Management’s Response:
CPRIT’s policies and procedures are still being updated to reflect the many changes to agency
infrastructure, systems and additional deployed services that have occurred since the new base
IT
infrastructure was deployed. Over the next several months, CPRIT will continue to document
currently
deployed critical agency infrastructure systems and services as well as systems and services that
will be
deployed over this same time span. CPRIT will also develop or update any relevant agency
policy or
procedure.
Person Responsible: Heidi McConnell / Therry Simien / Lisa Nelson
Revised Target Date for Implementation: March 31, 2012
IT Risk Assessment
Rule §202.22 states that a “risk assessment of information resources shall be performed and
documented”
that ranks the risks as high, medium, or low. Per the results of the FY 2012 audit, an IT risk
assessment was
scheduled to be performed by December 2012. As of July 2013, a formal IT risk assessment has
not yet
been performed.
Recommendation: Based on the guidelines set forth in Rule §202.22, it was determined that
CPRIT
appears to be classified as “low-risk” and therefore should consider completing a biennial
assessment. By
completing a risk assessment periodically, CPRIT will be able to reassess changes that affect the
IT
environment. Please see Appendix A, for more detail around the risk classification levels in
Texas
Administrative Code, Subchapter B, Rule §202.22.
Management’s Response:
The tool CPRIT previously used to perform its initial risk assessment (Information Security
Awareness,
Assessment, and Compliance) ISAAC program was discontinued on August 1, 2013. After a
new Chief
Compliance Officer is on staff, that person will help define and implement new formal
assessment
guidelines. Once these guidelines have been established, CPRIT IT will work to implement
them as quickly
as possible.
CPRIT has contracted with the Department of Information Resources (DIR) to provide quarterly
controlled penetration testing of infrastructure systems and services. After each testing cycle, a
report will
be created detailing vulnerabilities found and remediation recommendations. Once DIR has
received
confirmation that remediation processes have been established, a new cycle will be implemented
to test
again. An initial penetration test occurred at the end of September 2013. No exploits were found
in the IT
systems but some system vulnerabilities were noted. IT staff is addressing those items. The
remediation of
those items will be tested during the next penetration test DIR conducts.
Cancer Prevention and Research Institute of Texas (CPRIT)
Information Technology Internal Audit Report – FINAL Page 9
Person Responsible: Heidi McConnell / Therry Simien / Lisa Nelson / Chief Compliance Officer
Revised Target Date for Implementation: May 31, 2014
Prior Year (FY 2012) Management’s Response:
While the initial risk assessment was not completed by the time the internal audit field work was
being
conducted as originally anticipated due to resource needs for other IT projects, it was performed
in June
2012 utilizing the ISAAC (Information, Security Awareness, Assessment, and Compliance) tool
created and
maintained by Texas A&M University (TAMU) and licensed by DIR for state agencies. Based
on the results
of the initial assessment, a timeline of required actions to address deficient areas has been
incorporated into
the current IT plan. Assessment results combined with existing agency policies and TAC §202 is
planned to
be used to develop a controls matrix for the necessary testing of procedural processes and
scheduling of
identified compliance activities.
CPRIT will ensure newly implemented technical controls comply with existing agency policies
and amend
agency policies to comply with TAC §202. Once compliance in key areas has been addressed, a
follow-up
assessment will be performed in six months and reviewed. Risk assessments will be scheduled
to occur
annually.
Person Responsible: Heidi McConnell / Therry Simien / Lisa Nelson
Revised Target Date for Implementation: December 31, 2012
Disaster Recovery Plan & Business Continuity Plan
Rule §202.24 states "agencies shall maintain written Business Continuity Plans that address
information
resources so that the effects of a disaster will be minimized, and the state agency will be able
either to
maintain or quickly resume mission-critical functions. The state agency head or his or her
designated
representative(s) shall approve the plan."
Per the results of the FY 2012 audit, a Disaster Recovery Plan and Business Continuity Plan
were scheduled
to be updated by December 2013. Additionally, an electronic records retention schedule was
scheduled to
be written and implemented by December 2013. As of July 2013, neither of these documents
had been
finalized.
In response to the FY 2012 internal audit, the DuPont FM 200 fire suppression system in its
server room is
now fully active. The system will alert specified personnel as well as the authorities in the
instance of smoke,
fire, or drastic change in room temperature. These alerts include a phone call and text and email
alerts.
In an effort to decrease the risk of system unavailability and data recovery, the CPRIT IT group
is looking
into cloud services to store all public facing data and limiting data stored on servers to
confidential data.
This transition will protect data in the instance of a disaster as well as increase the available
capacity on
CPRIT servers.
Cancer Prevention and Research Institute of Texas (CPRIT)
Information Technology Internal Audit Report – FINAL Page 10
Recommendation: Since IT systems are critical to CPRIT’s operations, Management should
update their
disaster recovery plan to ensure the continued operation of the IT systems, or rapid recovery of
the systems
in case of a natural disaster.
Likewise, CPRIT should also ensure that a business continuity plan is kept updated to guarantee
that all
aspects of a business remain functioning in the midst of a disruptive event. These plans should
include a
business impact analysis, a risk assessment, and evidence of implementation, testing, and
maintenance.
Management’s Response:
CPRIT has worked to reduce overall business impact on agency operations of the most common
disasters
by implementing a server room environmental monitoring and alert system and performing the
relocation
of several agency public facing resources to cloud provider systems that are geographically
separated from
the agency. This work continues and will focus on internal services that can be relocated off-site
for
redundancy or efficiency purposes.
CPRIT will update the agency’s existing business continuity plan to reflect these infrastructure
changes and
will design and implement an effective routine testing schedule.
Person Responsible: Heidi McConnell / Therry Simien / Lisa Nelson
Revised Target Date for Implementation: December 31, 2014
Prior Year (FY2012) Management’s Response:
Assessments have been completed for all key agency public facing resources, such as CPRIT’s
primary
website, to determine if they could be co-located or relocated to off-site service providers. The
implementation of relocating and co-locating these resources off-site is currently underway.
CPRIT is continuing to develop an electronic records retention schedule to be used for planning
and testing
to ensure that access to critical electronic information can be maintained in the event of a
primary site
disaster.
CPRIT will update the agency’s existing business continuity plan, establishing current controls-
based testing
protocols for that plan and the scheduling of routine testing.
Person Responsible: Heidi McConnell / Therry Simien / Lisa Nelson / Laurie Baker
Revised Target Date for Implementation: December 31, 2013
Cancer Prevention and Research Institute of Texas (CPRIT)
Information Technology Internal Audit Report – FINAL Page 11
Security Access Reviews
Rule §202.21 states that the agency should "review access lists based on documented risk
management
decisions." Per the results of the FY 2012 audit, CPRIT was scheduled to perform quarterly
reviews of
systems and network access lists, badge access lists, 3rd party agency sponsored system access
(e.g. USAS,
GMS), and user accounts. As of July 2013, a quarterly review has not been performed.
Recommendation: To prevent unauthorized use of proprietary information or programmatic
information
that could result in undesirable financial, reputational, regulatory, or operational impacts, CPRIT
should
consider conducting a semi-annual review of all network users, all badge access holders, and all
users with
access to USAS. Any exceptions should be noted and remediated immediately.
Management’s Response:
While informal security audits have been performed when staffing changes occurred, security
access reviews
have not been performed regularly. CPRIT will complete a second, formal review of user
accounts, thirdparty
agency sponsored accounts and physical access system lists. Final assessment report guidelines
will be
defined and documented, and quarterly reviews will be scheduled.
Person Responsible: Therry Simien / Lisa Nelson
Target Date for Implementation: March 31, 2014
Prior Year (FY2012) Management’s Response:
CPRIT completed a review of systems and network access lists in June 2012 after the internal
audit
fieldwork was completed. CPRIT audited system user accounts, including third-party agency
sponsored
accounts (e.g. USAS, GMS), network access, facility system access keys, and badge access lists.
A formal
assessment report will be created and quarterly reviews will be implemented.
Person Responsible: Therry Simien / Lisa Nelson
Target Date for Implementation: June 30, 2012
Cancer Prevention and Research Institute of Texas (CPRIT)
Information Technology Internal Audit Report – FINAL Page 12
Self-Assessment Review
The State Auditor’s Office website provides a self-assessment document to help state agencies
determine
their compliance with TAC §202. Per the results of the FY 2012 audit, a TAC 202 self-
assessment was
scheduled to be completed by June 2013. As of July 2013, CPRIT has not yet performed a TAC
202 selfassessment.
Recommendation: CPRIT management should complete the self-assessment for state agencies
annually.
By performing the self-assessment, the IT department can help ensure compliance with TAC
202.
Management’s Response:
CPRIT is continuing to address areas of noncompliance with requirements in TAC §202 and
working to
establish an annual self-assessment review schedule.
Person Responsible: Heidi McConnell / Therry Simien / Lisa Nelson
Target Date for Implementation: December 31, 2013
Prior Year (FY2012) Management’s Response:
Management agrees that a regular self-assessment be performed. While the self-assessment was
not
completed as originally anticipated due to resource needs for other IT, CPRIT performed an
initial selfassessment
in June 2012 to determine compliance with TAC §202. CPRIT is addressing areas of
noncompliance specified in TAC §202 and will establish an annual assessment schedule.
Person Responsible: Heidi McConnell / Therry Simien / Lisa Nelson
Target Date for Implementation: June 30, 2013
Cancer Prevention and Research Institute of Texas (CPRIT)
Information Technology Internal Audit Report – FINAL Page 13
Additional Recommendations
The following was noted in 2011 and 2012 to improve IT operations and to align with leading
practices.
Grants Management System Third Party Provider Review
The grants management application is hosted by a third party service provider, SRA
International, Inc.
CPRIT does not currently require SRA to provide any evidence of review of SRA processes or
control
environment.
Recommendation: Because safeguarding the information contained within the grants
management
application is crucial to CPRIT's reputation, CPRIT should ensure that the information
contained in the
SRA application is appropriately safeguarded from unauthorized external users. If SRA has had
a third-party
perform an independent controls attestation report for the current period, CPRIT should obtain a
copy the
report and review the report to ensure that SRA's controls are operating effectively. One of the
common
reports obtained by service providers is the SOC 2 (Service Organization Controls) Report.
A SOC 2 Report is a report on controls at a service organization relevant to security,
availability, processing
integrity, confidentiality or privacy. This type of report is applicable when an entity outsources a
business
task or function to another entity (usually one that specializes in that task or function). One way
a user
auditor may obtain evidence about the quality and accuracy of the data provided to a user entity
by a service
organization is to obtain a service auditor’s report on controls at the service organization that
affect data
provided to the user entities. The rationale for this approach is that controls are designed to
prevent, or
detect and correct, errors or misstatements. If controls at a service organization are operating
effectively,
errors in data provided to the user entities will be prevented, or detected and corrected, and
misstatements
in the user entities’ financial statements will be avoided.
Management’s Response:
SRA has been providing the annual and quarterly SSAE 16 reports, also called Service
Organization
Controls (SOC) 1 Reports for assurance of the suitability of design and operating effectiveness
of controls.
CPRIT will work with SRA to obtain a SOC 2 Report to provide the assurances of security,
availability,
processing integrity, confidentiality and privacy at the service organization.
Person Responsible: Heidi McConnell / Therry Simien / Lisa Nelson
Target Date for Implementation: June 30, 2014
Cancer Prevention and Research Institute of Texas (CPRIT)
Information Technology Internal Audit Report – FINAL Page 14
Prior Year (FY2012) Management’s Response:
Management agrees with the recommendation that CPRIT complete a formal written assessment
of the
SSAE 16 annual and quarterly reports to verify that CPRIT understands the management
controls over
logical controls, physical controls, and change management in place at Savvis, where SRA-
managed systems
for CPRIT are housed. CPRIT will use these assessments to have SRA rectify any findings
identified in
these reports. The SSAE 16 annual report is available in December of each year, so the written
assessment
will be completed by the end of January and assessments of quarterly reports will be completed
within 30
days after they are received by CPRIT.
Person Responsible: Heidi McConnell / Therry Simien / Lisa Nelson
Target Date for Implementation: January 31, 2013
Cancer Prevention and Research Institute of Texas (CPRIT)
Information Technology Internal Audit Report – FINAL Page 15
Appendix A – Texas Administrative Code,
Subchapter B, Rule §202.22
(a) A risk assessment of information resources shall be performed and documented. The risk
assessment
shall be updated based on the inherent risk. The inherent risk and frequency of the risk
assessment will be
ranked, at a minimum, as either "High," "Medium," or "Low," based primarily on the
following criteria:
(1) High Risk-annual assessment--Information resources that:
(A) Involve large dollar amounts or significantly important transactions, such that business
or government processes would be hindered or an impact on public health or safety
would occur if the transactions were not processed timely and accurately, or
(B) Contain confidential or other data such that unauthorized disclosure would cause real
damage to the parties involved, or
(C) Impact a large number of people or interconnected systems.
(2) Medium Risk-biennial assessment--Information resources that:
(A) Transact or control a moderate or low dollar value, or
(B) Data items that could potentially embarrass or create problems for the parties involved
if released, or
(C) Impact a moderate proportion of the customer base.
(3) Low Risk-biennial assessment--Information resources that:
(A) Publish generally available public information, or
(B) Result in a relatively small impact on the population.
(b) A system change could cause the overall classification to move to another risk level.
Cancer Prevention and Research Institute of Texas (CPRIT)
Information Technology Internal Audit Report – FINAL Page 16
Appendix B – Texas Administrative Code,
Subchapter B, Rule §202.25 – IT Policies
The following IT policies have been created and/or updated at the Agency:
Rule §202.25 Recommended IT Policy Area Policy Created?
Acceptable Use
Account Management
Administrator/Special Access
Application Security
Backup/Recovery
Change or Configuration Management
Encryption
Firewall
Incident Management
Identification/Authentication
Internet/Intranet Use
Intrusion Detection
Network Access
Network Configuration
Physical Access
Portable Computing
Privacy
Security Monitoring
Security Awareness and Training
Platform Management
Authorized Software
System Development and Acquisition
Third Party Access
Malicious Code
Wireless Access
Vulnerability Assessment
Total 11 / 26
Solution
When planning an engagement, the IT auditor should consider:
Objectives should be developed for each engagement and the scope should be sufficient to
satisfy the objectives.
Types of recommendations
The IT auditor can make four types of recommendations:

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Qestions1) a) Using the IT audit report for the Cancer Prevention.pdf

  • 1. Qestions: 1) a) Using the IT audit report for the Cancer Prevention and Research Institute of Texas (in the Readings tab), find examples of the items that are supposed to be in IT audit report according to Standard 1401. Indicate item and page number. b) Comment on additional items you find in the audit report that are not part of the 1401 standard for Audit Reporting. Explain what the benefits are of including it. Information Technology Internal Audit Report Report #2013-03 August 9, 2013 Cancer Prevention and Research Institute of Texas (CPRIT) Information Technology Internal Audit Report – FINAL Page 2 Table of Contents Page Executive Summary............................................................................................................................................ .......3 Background Information........................................................................................................................................ ..4 Background ........................................................................................................................................................... .4 Audit Objectives.......................................................................................................................................... ..........4 Scope ........................................................................................................................................................... ............5 Testing Approach............................................................................................................................................ ......5 Statement of Auditing Standards ........................................................................................................................6 Findings, Observations, and Recommendations
  • 2. ..................................................................................................6 IT Policies and Procedures ..................................................................................................................................7 IT Risk Assessment......................................................................................................................................... ......8 Disaster Recovery Plan & Business Continuity Plan.......................................................................................9 Security Access Reviews.....................................................................................................................................11 Self-Assessment Review.....................................................................................................................................12 Additional Recommendations ...............................................................................................................................13 Appendix A – Texas Administrative Code, Subchapter B, Rule §202.22.......................................................15 Appendix B – Texas Administrative Code, Subchapter B, Rule §202.25 – IT Policies ...............................16 Cancer Prevention and Research Institute of Texas (CPRIT) Information Technology Internal Audit Report – FINAL Page 3 Executive Summary In support of the FY2013 Internal Audit Plan, a review of the information technology (IT) process was conducted in August 2013. The IT department is responsible for setting up and supporting IT operations at the Agency. The CPRIT offices are located in Austin, TX; however, the Chief Scientific Officer has an office in downtown Houston, which is also serviced and maintained by the CPRIT IT department. The department is also responsible for the Agency’s various websites, cloud services operations, video conference system, data closet, and typical back-office IT operations. This was the third annual IT audit for the Agency. An internal audit of the IT processes was performed previously in June 2012 and May 2011. As a result of those audits, Internal Audit provided CPRIT findings
  • 3. and recommendations to improve overall efficiency and effectiveness within their IT operations. Although some steps have been made to remediate these findings, CPRIT needs to place importance on establishing a strong IT governance structure. CPRIT continues to work towards establishing leading practices within the IT operations. However, during the FY 2013 IT internal audit, the following improvement opportunities were noted, in descending priority: · Outdated IT Policies and Procedures – In efforts to remediate the findings in the FY 2012 IT internal audit, the CPRIT IT department recently began reviewing and creating IT policies required by Texas Administrative Code, Chapter 202, Subchapter B – Security Standards for State Agencies. However, many of the developed policies have not yet been reviewed and approved by management. · Incomplete IT Risk Assessment – As recommended as part of the FY 2012 IT internal audit remediation plan, a detailed risk assessment of the IT environment has not been performed. · Insufficient Disaster Recovery Plan and Business Continuity Plan – As recommended as part of the FY 2012 IT internal audit remediation plan, a disaster recovery plan and business continuity plan has not been developed, implemented, or tested. · Inadequate Review or Evidence of Third-Party Control Environment – the third party grants management provider, SRA, has not provided adequate evidence of their internal control environment to provide assurance that CPRIT’s information is secure and recorded accurately within the application. Cancer Prevention and Research Institute of Texas (CPRIT) Information Technology Internal Audit Report – FINAL Page 4 Background Information Background Texas voters approved a constitutional amendment in 2007 establishing the Cancer Prevention and Research Institute of Texas (CPRIT) and authorized the state to issue $3 billion in bonds to fund groundbreaking cancer research and prevention programs and services in Texas. To date, CPRIT has funded almost 500 grants totaling $835,820,450.1
  • 4. CPRIT’s goals are to: · Create and expedite innovation in the area of cancer research, thereby enhancing the potential for a medical or scientific breakthrough in the prevention of cancer and cures for cancer; · Attract, create, or expand research capabilities of public or private institutions of higher education and other public or private entities that will promote a substantial increase in cancer research and in the creation of high-quality new jobs in this State; and · Continue to develop and implement the Texas Cancer Plan by promoting the development and coordination of effective and efficient statewide public and private policies, programs, and services related to cancer and by encouraging cooperative, comprehensive, and complementary planning among the public, private, and volunteer sectors involved in cancer prevention, detection, treatment, and research. Audit Objectives The main objective of the audit was to verify that the IT infrastructure is appropriately safeguarded and that data reliability and accuracy are maintained within the environment. The specific audit objectives were: · Verify that prior year audit findings had been addressed and corrected · Validate that the Agency’s IT environment is compliant with the requirements identified in the Texas Administrative Code, Chapter 202, Subchapter B – Security Standards for State Agencies · Assess the overall IT function to determine whether sufficient resources and skill sets have been appropriated to support the technology requirements · Evaluate whether appropriate access has been granted to the network and selected applications · Validate whether databases are sufficiently backed-up and whether back-ups are restorable · Confirm that the Agency follows IT general computer controls 1 Figures provided by the CPRIT website. http://www.cprit.state.tx.us/ Cancer Prevention and Research Institute of Texas (CPRIT) Information Technology Internal Audit Report – FINAL Page 5 In order to assess the IT department, Internal Audit reviewed the following: · Compliance with Texas Administrative Code requirements · Internal policies and procedures Scope
  • 5. Although current legislation may potentially change procedural and reporting requirements for CPRIT, the audit performed was designed to evaluate and test compliance with established policies and procedures as of July 2013. Internal Audit interviewed staff and completed field work in August 2013. Our procedures included discussions with the following CPRIT personnel: Name Title Heidi McConnell Chief Operating Officer Alfonso Royal Finance Manager Lisa Nelson Operations Manager Therry Simien Information Technology Officer Testing Approach During the IT audit, Internal Audit performed procedures that included: inquiry, observation, inspection and re-performance. See the matrix below for a description listing of each type of test performed. Type Description Inquiry Inquired of appropriate personnel. Inquiries seeking relevant information or representation from CPRIT personnel were performed to obtain among other things: · Knowledge and additional information regarding the policy or procedure · Corroborating evidence of the policy or procedure In conducting this internal audit, we interviewed: · Therry Simien, Information Technology Officer · Alfonso Royal, Finance Manager · Lisa Nelson, Operations Manager Observation Observed the application or existence of specific controls as represented. Inspection Inspected documents and records indicating performance of the controls, including: · Examination of documents or records for evidence of performance, such as existence of required documentation and approvals. · Inspection of CPRIT systems documentation, such as policies and procedures, network diagrams, flowcharts and job descriptions. Re-performance Re-performed the control activity performed by CPRIT to gain additional evidence regarding the effective operation of the control activity. Cancer Prevention and Research Institute of Texas (CPRIT) Information Technology Internal Audit Report – FINAL Page 6
  • 6. Statement of Auditing Standards This internal audit was conducted in accordance with generally accepted government auditing standards (GAGAS). The internal audit also follows the guidelines set forth by the Institute of Internal Auditors (IIA) and conforms to the Standards for the Professional Practice of Internal Auditing, the code of ethics contained in the Professional Practices Framework as promulgated by the IIA. Although due professional care in the performance of this audit was exercised, this should not be construed to imply that unreported irregularities do not exist. The deterrence of fraud is the responsibility of management. Audit procedures alone, even when executed with professional care, do not guarantee that fraud will be detected. Specific areas for improvement are addressed later in this report. Cancer Prevention and Research Institute of Texas (CPRIT) Information Technology Internal Audit Report – FINAL Page 7 Findings, Observations, and Recommendations Summary of Findings and Related Recommendations The section below provides details regarding the audit findings and corresponding reference to the Texas Administrative Code rule. Statement on FY 2012 Information Technology Audit Remediation Following the fiscal year 2012 internal audit, the remediation of IT findings was significantly delayed. IT staff priorities were shifted to support the agency’s 2012 annual conference logistics, electronic conference registration system and electronic scientific abstract collection system; to assist legal counsel with highpriority data requests related to investigations; to relocate the remote office IT infrastructure from Dallas to Houston; and to support communication projects. As a result, longer-term, non-user related projects (e.g., documentation updates) were effectively placed on hold. Management has made completion of all outstanding IT infrastructure and operational compliance projects a high priority during the
  • 7. current year within staffing constraints. IT Policies and Procedures Rule §202.25 lists suggested policies that should be created and implemented by the information security officer. Per the results of the FY 2012 IT audit, policies and procedures were scheduled to be completed and/or up-to-date by March 2013. As of July 2013, all policies and procedures have not been finalized. CPRIT has 11 out of 26 recommended IT policies documented. While some policies have been developed, none of them have been approved by management. Please see Appendix B for details around testing of IT recommended policies. Recommendation: To ensure CPRIT has established proper IT governance and protocols, CPRIT needs to finalize its IT security policies and procedures as recommended by Texas Administrative Code §202.25. The agency should update all existing policies to reflect the actual processes taking place. The policies should also be approved by the state agency head or another designated representative. Management’s Response: During this audit cycle, significant progress has been made in the review, updating and creation of IT policies. As shown in Appendix B of the report, nearly half of the recommended policies have been submitted to agency senior management for final approval. IT staff is now in the process of revising those policies to incorporate management’s recommendations with the expectation to have this process completed within the next 30 days. The remaining policies and procedures will continue to be updated and/or created over the next several months. Cancer Prevention and Research Institute of Texas (CPRIT) Information Technology Internal Audit Report – FINAL Page 8 Person Responsible: Heidi McConnell / Therry Simien / Lisa Nelson
  • 8. Revised Target Date for Implementation: May 31, 2014 Prior Year (FY 2012) Audit Management’s Response: CPRIT’s policies and procedures are still being updated to reflect the many changes to agency infrastructure, systems and additional deployed services that have occurred since the new base IT infrastructure was deployed. Over the next several months, CPRIT will continue to document currently deployed critical agency infrastructure systems and services as well as systems and services that will be deployed over this same time span. CPRIT will also develop or update any relevant agency policy or procedure. Person Responsible: Heidi McConnell / Therry Simien / Lisa Nelson Revised Target Date for Implementation: March 31, 2012 IT Risk Assessment Rule §202.22 states that a “risk assessment of information resources shall be performed and documented” that ranks the risks as high, medium, or low. Per the results of the FY 2012 audit, an IT risk assessment was scheduled to be performed by December 2012. As of July 2013, a formal IT risk assessment has not yet been performed. Recommendation: Based on the guidelines set forth in Rule §202.22, it was determined that CPRIT appears to be classified as “low-risk” and therefore should consider completing a biennial assessment. By completing a risk assessment periodically, CPRIT will be able to reassess changes that affect the IT environment. Please see Appendix A, for more detail around the risk classification levels in Texas Administrative Code, Subchapter B, Rule §202.22. Management’s Response: The tool CPRIT previously used to perform its initial risk assessment (Information Security Awareness, Assessment, and Compliance) ISAAC program was discontinued on August 1, 2013. After a new Chief
  • 9. Compliance Officer is on staff, that person will help define and implement new formal assessment guidelines. Once these guidelines have been established, CPRIT IT will work to implement them as quickly as possible. CPRIT has contracted with the Department of Information Resources (DIR) to provide quarterly controlled penetration testing of infrastructure systems and services. After each testing cycle, a report will be created detailing vulnerabilities found and remediation recommendations. Once DIR has received confirmation that remediation processes have been established, a new cycle will be implemented to test again. An initial penetration test occurred at the end of September 2013. No exploits were found in the IT systems but some system vulnerabilities were noted. IT staff is addressing those items. The remediation of those items will be tested during the next penetration test DIR conducts. Cancer Prevention and Research Institute of Texas (CPRIT) Information Technology Internal Audit Report – FINAL Page 9 Person Responsible: Heidi McConnell / Therry Simien / Lisa Nelson / Chief Compliance Officer Revised Target Date for Implementation: May 31, 2014 Prior Year (FY 2012) Management’s Response: While the initial risk assessment was not completed by the time the internal audit field work was being conducted as originally anticipated due to resource needs for other IT projects, it was performed in June 2012 utilizing the ISAAC (Information, Security Awareness, Assessment, and Compliance) tool created and maintained by Texas A&M University (TAMU) and licensed by DIR for state agencies. Based on the results of the initial assessment, a timeline of required actions to address deficient areas has been incorporated into the current IT plan. Assessment results combined with existing agency policies and TAC §202 is planned to be used to develop a controls matrix for the necessary testing of procedural processes and scheduling of
  • 10. identified compliance activities. CPRIT will ensure newly implemented technical controls comply with existing agency policies and amend agency policies to comply with TAC §202. Once compliance in key areas has been addressed, a follow-up assessment will be performed in six months and reviewed. Risk assessments will be scheduled to occur annually. Person Responsible: Heidi McConnell / Therry Simien / Lisa Nelson Revised Target Date for Implementation: December 31, 2012 Disaster Recovery Plan & Business Continuity Plan Rule §202.24 states "agencies shall maintain written Business Continuity Plans that address information resources so that the effects of a disaster will be minimized, and the state agency will be able either to maintain or quickly resume mission-critical functions. The state agency head or his or her designated representative(s) shall approve the plan." Per the results of the FY 2012 audit, a Disaster Recovery Plan and Business Continuity Plan were scheduled to be updated by December 2013. Additionally, an electronic records retention schedule was scheduled to be written and implemented by December 2013. As of July 2013, neither of these documents had been finalized. In response to the FY 2012 internal audit, the DuPont FM 200 fire suppression system in its server room is now fully active. The system will alert specified personnel as well as the authorities in the instance of smoke, fire, or drastic change in room temperature. These alerts include a phone call and text and email alerts. In an effort to decrease the risk of system unavailability and data recovery, the CPRIT IT group is looking into cloud services to store all public facing data and limiting data stored on servers to confidential data. This transition will protect data in the instance of a disaster as well as increase the available
  • 11. capacity on CPRIT servers. Cancer Prevention and Research Institute of Texas (CPRIT) Information Technology Internal Audit Report – FINAL Page 10 Recommendation: Since IT systems are critical to CPRIT’s operations, Management should update their disaster recovery plan to ensure the continued operation of the IT systems, or rapid recovery of the systems in case of a natural disaster. Likewise, CPRIT should also ensure that a business continuity plan is kept updated to guarantee that all aspects of a business remain functioning in the midst of a disruptive event. These plans should include a business impact analysis, a risk assessment, and evidence of implementation, testing, and maintenance. Management’s Response: CPRIT has worked to reduce overall business impact on agency operations of the most common disasters by implementing a server room environmental monitoring and alert system and performing the relocation of several agency public facing resources to cloud provider systems that are geographically separated from the agency. This work continues and will focus on internal services that can be relocated off-site for redundancy or efficiency purposes. CPRIT will update the agency’s existing business continuity plan to reflect these infrastructure changes and will design and implement an effective routine testing schedule. Person Responsible: Heidi McConnell / Therry Simien / Lisa Nelson Revised Target Date for Implementation: December 31, 2014 Prior Year (FY2012) Management’s Response: Assessments have been completed for all key agency public facing resources, such as CPRIT’s primary website, to determine if they could be co-located or relocated to off-site service providers. The implementation of relocating and co-locating these resources off-site is currently underway. CPRIT is continuing to develop an electronic records retention schedule to be used for planning
  • 12. and testing to ensure that access to critical electronic information can be maintained in the event of a primary site disaster. CPRIT will update the agency’s existing business continuity plan, establishing current controls- based testing protocols for that plan and the scheduling of routine testing. Person Responsible: Heidi McConnell / Therry Simien / Lisa Nelson / Laurie Baker Revised Target Date for Implementation: December 31, 2013 Cancer Prevention and Research Institute of Texas (CPRIT) Information Technology Internal Audit Report – FINAL Page 11 Security Access Reviews Rule §202.21 states that the agency should "review access lists based on documented risk management decisions." Per the results of the FY 2012 audit, CPRIT was scheduled to perform quarterly reviews of systems and network access lists, badge access lists, 3rd party agency sponsored system access (e.g. USAS, GMS), and user accounts. As of July 2013, a quarterly review has not been performed. Recommendation: To prevent unauthorized use of proprietary information or programmatic information that could result in undesirable financial, reputational, regulatory, or operational impacts, CPRIT should consider conducting a semi-annual review of all network users, all badge access holders, and all users with access to USAS. Any exceptions should be noted and remediated immediately. Management’s Response: While informal security audits have been performed when staffing changes occurred, security access reviews have not been performed regularly. CPRIT will complete a second, formal review of user accounts, thirdparty agency sponsored accounts and physical access system lists. Final assessment report guidelines will be defined and documented, and quarterly reviews will be scheduled. Person Responsible: Therry Simien / Lisa Nelson Target Date for Implementation: March 31, 2014
  • 13. Prior Year (FY2012) Management’s Response: CPRIT completed a review of systems and network access lists in June 2012 after the internal audit fieldwork was completed. CPRIT audited system user accounts, including third-party agency sponsored accounts (e.g. USAS, GMS), network access, facility system access keys, and badge access lists. A formal assessment report will be created and quarterly reviews will be implemented. Person Responsible: Therry Simien / Lisa Nelson Target Date for Implementation: June 30, 2012 Cancer Prevention and Research Institute of Texas (CPRIT) Information Technology Internal Audit Report – FINAL Page 12 Self-Assessment Review The State Auditor’s Office website provides a self-assessment document to help state agencies determine their compliance with TAC §202. Per the results of the FY 2012 audit, a TAC 202 self- assessment was scheduled to be completed by June 2013. As of July 2013, CPRIT has not yet performed a TAC 202 selfassessment. Recommendation: CPRIT management should complete the self-assessment for state agencies annually. By performing the self-assessment, the IT department can help ensure compliance with TAC 202. Management’s Response: CPRIT is continuing to address areas of noncompliance with requirements in TAC §202 and working to establish an annual self-assessment review schedule. Person Responsible: Heidi McConnell / Therry Simien / Lisa Nelson Target Date for Implementation: December 31, 2013 Prior Year (FY2012) Management’s Response: Management agrees that a regular self-assessment be performed. While the self-assessment was not completed as originally anticipated due to resource needs for other IT, CPRIT performed an initial selfassessment in June 2012 to determine compliance with TAC §202. CPRIT is addressing areas of noncompliance specified in TAC §202 and will establish an annual assessment schedule.
  • 14. Person Responsible: Heidi McConnell / Therry Simien / Lisa Nelson Target Date for Implementation: June 30, 2013 Cancer Prevention and Research Institute of Texas (CPRIT) Information Technology Internal Audit Report – FINAL Page 13 Additional Recommendations The following was noted in 2011 and 2012 to improve IT operations and to align with leading practices. Grants Management System Third Party Provider Review The grants management application is hosted by a third party service provider, SRA International, Inc. CPRIT does not currently require SRA to provide any evidence of review of SRA processes or control environment. Recommendation: Because safeguarding the information contained within the grants management application is crucial to CPRIT's reputation, CPRIT should ensure that the information contained in the SRA application is appropriately safeguarded from unauthorized external users. If SRA has had a third-party perform an independent controls attestation report for the current period, CPRIT should obtain a copy the report and review the report to ensure that SRA's controls are operating effectively. One of the common reports obtained by service providers is the SOC 2 (Service Organization Controls) Report. A SOC 2 Report is a report on controls at a service organization relevant to security, availability, processing integrity, confidentiality or privacy. This type of report is applicable when an entity outsources a business task or function to another entity (usually one that specializes in that task or function). One way a user auditor may obtain evidence about the quality and accuracy of the data provided to a user entity by a service organization is to obtain a service auditor’s report on controls at the service organization that affect data provided to the user entities. The rationale for this approach is that controls are designed to prevent, or
  • 15. detect and correct, errors or misstatements. If controls at a service organization are operating effectively, errors in data provided to the user entities will be prevented, or detected and corrected, and misstatements in the user entities’ financial statements will be avoided. Management’s Response: SRA has been providing the annual and quarterly SSAE 16 reports, also called Service Organization Controls (SOC) 1 Reports for assurance of the suitability of design and operating effectiveness of controls. CPRIT will work with SRA to obtain a SOC 2 Report to provide the assurances of security, availability, processing integrity, confidentiality and privacy at the service organization. Person Responsible: Heidi McConnell / Therry Simien / Lisa Nelson Target Date for Implementation: June 30, 2014 Cancer Prevention and Research Institute of Texas (CPRIT) Information Technology Internal Audit Report – FINAL Page 14 Prior Year (FY2012) Management’s Response: Management agrees with the recommendation that CPRIT complete a formal written assessment of the SSAE 16 annual and quarterly reports to verify that CPRIT understands the management controls over logical controls, physical controls, and change management in place at Savvis, where SRA- managed systems for CPRIT are housed. CPRIT will use these assessments to have SRA rectify any findings identified in these reports. The SSAE 16 annual report is available in December of each year, so the written assessment will be completed by the end of January and assessments of quarterly reports will be completed within 30 days after they are received by CPRIT. Person Responsible: Heidi McConnell / Therry Simien / Lisa Nelson Target Date for Implementation: January 31, 2013 Cancer Prevention and Research Institute of Texas (CPRIT) Information Technology Internal Audit Report – FINAL Page 15 Appendix A – Texas Administrative Code,
  • 16. Subchapter B, Rule §202.22 (a) A risk assessment of information resources shall be performed and documented. The risk assessment shall be updated based on the inherent risk. The inherent risk and frequency of the risk assessment will be ranked, at a minimum, as either "High," "Medium," or "Low," based primarily on the following criteria: (1) High Risk-annual assessment--Information resources that: (A) Involve large dollar amounts or significantly important transactions, such that business or government processes would be hindered or an impact on public health or safety would occur if the transactions were not processed timely and accurately, or (B) Contain confidential or other data such that unauthorized disclosure would cause real damage to the parties involved, or (C) Impact a large number of people or interconnected systems. (2) Medium Risk-biennial assessment--Information resources that: (A) Transact or control a moderate or low dollar value, or (B) Data items that could potentially embarrass or create problems for the parties involved if released, or (C) Impact a moderate proportion of the customer base. (3) Low Risk-biennial assessment--Information resources that: (A) Publish generally available public information, or (B) Result in a relatively small impact on the population. (b) A system change could cause the overall classification to move to another risk level. Cancer Prevention and Research Institute of Texas (CPRIT) Information Technology Internal Audit Report – FINAL Page 16 Appendix B – Texas Administrative Code, Subchapter B, Rule §202.25 – IT Policies The following IT policies have been created and/or updated at the Agency: Rule §202.25 Recommended IT Policy Area Policy Created? Acceptable Use Account Management Administrator/Special Access Application Security Backup/Recovery Change or Configuration Management Encryption
  • 17. Firewall Incident Management Identification/Authentication Internet/Intranet Use Intrusion Detection Network Access Network Configuration Physical Access Portable Computing Privacy Security Monitoring Security Awareness and Training Platform Management Authorized Software System Development and Acquisition Third Party Access Malicious Code Wireless Access Vulnerability Assessment Total 11 / 26 Solution When planning an engagement, the IT auditor should consider: Objectives should be developed for each engagement and the scope should be sufficient to satisfy the objectives. Types of recommendations The IT auditor can make four types of recommendations: