This document discusses various compliance standards that organizations should consider when moving IT assets or applications to the public cloud, including SSAE 16, PCI DSS, HIPAA, ISO 27001, and others. It provides an overview of each standard, including whether it involves attestation or certification, relevance for service providers versus enterprises, approximate costs, and best practices for developing a compliance strategy. The key takeaway is that organizations need to determine which standards are relevant based on their business and clients, as pursuing all standards can add unnecessary complexity and cost.
Use Of Techniques And Technology In Internal AuditManoj Agarwal
The document discusses the role of internal audit and techniques used in internal auditing. It outlines the definition of internal auditing as an independent and objective assurance activity designed to add value and improve an organization's operations. The document then discusses the use of technology in internal auditing to allow auditors to do more work with less resources through tools like data analytics and continuous monitoring. Finally, it lists various techniques used in internal auditing such as planning, documentation, sampling, and reporting standards.
1. An audit is an evaluation of an organization, system, process, project or product performed by independent auditors who then issue a report on the results.
2. There are two main types of auditors - internal auditors who are employees of the company and external auditors who are independent.
3. The audit process involves planning the audit, identifying risks, reviewing internal controls, setting the audit scope and objectives, and developing an audit strategy.
This document summarizes COSO's guidance on monitoring internal control systems. It discusses how effective monitoring is an integral part of internal control and helps ensure controls continue operating effectively over time. The guidance clarifies the monitoring component and builds on principles from previous COSO frameworks. It describes three elements of effective monitoring: establishing a foundation, designing monitoring procedures, and assessing and reporting results. A variety of monitoring procedures are discussed that organizations can select from to strengthen their internal control systems.
Application Security Review 5 Dec 09 FinalManoj Agarwal
The document discusses the importance of conducting application security reviews to identify vulnerabilities. It outlines best practices for application security such as input validation, access controls, encryption, and ongoing patching and monitoring. The presentation notes that many applications are found to have significant security flaws and that securing both applications and infrastructure is needed for effective security.
This document discusses system-based auditing and the role of internal control. It defines internal control according to the Committee of Sponsoring Organizations of the Treadway Commission (COSO) as a process designed to provide reasonable assurance of achieving objectives related to operations, reporting, and compliance. The COSO internal control framework identifies five components of internal control: control environment, risk assessment, control activities, information and communication, and monitoring activities. System-based auditing involves assessing inherent and control risks to determine the nature and extent of substantive testing needed, with fewer tests required when control risk is low.
internal control and control self assessmentManoj Agarwal
The document discusses internal controls and control self-assessment. It begins with definitions of internal control and internal auditing. It then outlines the COSO internal control framework, including the five components and seventeen underlying principles of internal control. The presentation agenda and a case study are also mentioned. Sample templates for evaluating internal controls against the principles are included.
Evaluating Service Organization Control ReportsJay Crossland
Service Organization Control (SOC) reports evaluate the controls at service organizations and their impact on user entities. With the Sarbanes-Oxley Act of 2002, user entities were required to thoroughly evaluate SOC reports from their service organizations. However, most user entities do not fully understand SOC reports and how to properly assess them. A comprehensive evaluation of a SOC report examines factors like the scope, standards used, control objectives tested, and any issues or deficiencies identified.
The document discusses the COSO internal control framework's principles of monitoring internal controls. It states that monitoring ensures controls continue operating effectively through ongoing or separate evaluations. Planning and organizational support form the foundation for monitoring, including tone from management and the board's understanding of monitoring's importance. Monitoring procedures evaluate important controls over meaningful risks, and assessing results prioritizes and communicates deficiencies for corrective action. Effective monitoring uses a systematic process of identifying risks and determining optimal monitoring approaches.
Use Of Techniques And Technology In Internal AuditManoj Agarwal
The document discusses the role of internal audit and techniques used in internal auditing. It outlines the definition of internal auditing as an independent and objective assurance activity designed to add value and improve an organization's operations. The document then discusses the use of technology in internal auditing to allow auditors to do more work with less resources through tools like data analytics and continuous monitoring. Finally, it lists various techniques used in internal auditing such as planning, documentation, sampling, and reporting standards.
1. An audit is an evaluation of an organization, system, process, project or product performed by independent auditors who then issue a report on the results.
2. There are two main types of auditors - internal auditors who are employees of the company and external auditors who are independent.
3. The audit process involves planning the audit, identifying risks, reviewing internal controls, setting the audit scope and objectives, and developing an audit strategy.
This document summarizes COSO's guidance on monitoring internal control systems. It discusses how effective monitoring is an integral part of internal control and helps ensure controls continue operating effectively over time. The guidance clarifies the monitoring component and builds on principles from previous COSO frameworks. It describes three elements of effective monitoring: establishing a foundation, designing monitoring procedures, and assessing and reporting results. A variety of monitoring procedures are discussed that organizations can select from to strengthen their internal control systems.
Application Security Review 5 Dec 09 FinalManoj Agarwal
The document discusses the importance of conducting application security reviews to identify vulnerabilities. It outlines best practices for application security such as input validation, access controls, encryption, and ongoing patching and monitoring. The presentation notes that many applications are found to have significant security flaws and that securing both applications and infrastructure is needed for effective security.
This document discusses system-based auditing and the role of internal control. It defines internal control according to the Committee of Sponsoring Organizations of the Treadway Commission (COSO) as a process designed to provide reasonable assurance of achieving objectives related to operations, reporting, and compliance. The COSO internal control framework identifies five components of internal control: control environment, risk assessment, control activities, information and communication, and monitoring activities. System-based auditing involves assessing inherent and control risks to determine the nature and extent of substantive testing needed, with fewer tests required when control risk is low.
internal control and control self assessmentManoj Agarwal
The document discusses internal controls and control self-assessment. It begins with definitions of internal control and internal auditing. It then outlines the COSO internal control framework, including the five components and seventeen underlying principles of internal control. The presentation agenda and a case study are also mentioned. Sample templates for evaluating internal controls against the principles are included.
Evaluating Service Organization Control ReportsJay Crossland
Service Organization Control (SOC) reports evaluate the controls at service organizations and their impact on user entities. With the Sarbanes-Oxley Act of 2002, user entities were required to thoroughly evaluate SOC reports from their service organizations. However, most user entities do not fully understand SOC reports and how to properly assess them. A comprehensive evaluation of a SOC report examines factors like the scope, standards used, control objectives tested, and any issues or deficiencies identified.
The document discusses the COSO internal control framework's principles of monitoring internal controls. It states that monitoring ensures controls continue operating effectively through ongoing or separate evaluations. Planning and organizational support form the foundation for monitoring, including tone from management and the board's understanding of monitoring's importance. Monitoring procedures evaluate important controls over meaningful risks, and assessing results prioritizes and communicates deficiencies for corrective action. Effective monitoring uses a systematic process of identifying risks and determining optimal monitoring approaches.
Internal auditors require great expertise to provide advice on key control objectives and investigate fraud. They must also ensure compliance with laws and regulations, audit information systems, and help management promote economy, efficiency, and effectiveness. The scope of internal audits is wide and requires understanding operations as well as including management's needs in the terms of reference.
Evolving healthcare trends coupled with a slew of new features and functions to consider can overwhelm anyone charged with the task. Case managers typically are not been involved in the selection process, but that seems to be changing as organizations realize their input can be useful when it comes to choosing the most effective and efficient system.
Case managers who do get this opportunity can be prepared by staying up-to-date on the latest healthcare trends and technology that impact medical management functionality. While it is difficult to keep up with the expanding symbiotic interface between technology and care management workflow processes, case managers must understand how technology solutions can improve processes and patient outcomes.
Internal Control Certification – It’s Not Just an Accounting Thing (Credit Un...NAFCU Services Corporation
In this recorded 2012 NAFCU Technology & Security Conference session, you will learn about the internal control certification process and how it impacts more than just the accounting department. Discover the importance of becoming internal control certified, gain insight on the impact of recent regulation change from SAS70 to SSAE 16, and get a walkthrough of the process and audit reports (Type I & Type II) as well as discuss the involvement from the “technology side of the house,” including documentation of systems controls, disaster recovery and more!
Presented by Jeff Ziliani, CPA, Director of Finance and Administration, Burns-Fazzi, Brock
Burns-Fazzi, Brock is the NAFCU Services Preferred Partner for Executive Benefits and Compensation Consulting and Long Term Care Insurance.
More information at http://www.nafcu.org/bfb
This document discusses database auditing and security. It begins by stating that database auditing is key to ensuring data confidentiality, integrity and accessibility, and that database security is not effective without auditing. It then provides overviews of auditing, defining terms like audit logs, objectives, procedures and reports. It describes auditing activities, environments, processes and objectives. It outlines the components of a database auditing environment and classifications and types of audits, including internal, external, automatic, manual and hybrid audits.
Evaluate your CISA preparation. Attempt below 150 questions which are designed as per CISA exam pattern considering domain wise weightage.
http://datainfosec.blogspot.in/2016/04/cisa-mock-test-question-paper-1.html
Sap security compliance tools_PennonSoftPennonSoft
The document discusses using security compliance tools to detect and prevent security and controls violations in SAP systems. It outlines increased regulatory focus on security, risks like access control and segregation of duties issues, and how tools can help with real-time monitoring, resolving segregation of duties issues, and providing automated analysis and monitoring to assess authorization compliance. The benefits of these tools are that they can run with SAP, automate separation of duties analysis and monitoring of critical transactions, and provide quick assessments to business users, auditors, and security staff while avoiding manual analysis and false positives.
This document discusses tests of controls, which are used in SOC examinations to confirm that identified controls at a service organization are working effectively. There are five main methods for testing controls: inquiry, observation, examination of evidence, re-performance, and computer-assisted audit techniques. Inquiry involves asking questions, observation involves watching activities, examination of evidence involves reviewing documentation, re-performance involves redoing controls manually, and computer-assisted techniques use software to analyze large volumes of data. Audit sampling for tests of controls also falls into four categories: inquiry, observation, reperformance, and inspection of documents.
1. The document discusses the objectives, methodologies, and phases of performing an information systems audit.
2. Key methodologies discussed include the top-down and bottom-up approaches, with the top-down being business and risk focused and the bottom-up focusing on control objectives.
3. The phases of an audit include pre-engagement work, data collection through testing, interviews and documentation, data analysis to identify findings and risks, developing recommendations, and reporting results.
The document discusses COSO (Committee of Sponsoring Organizations of the Treadway Commission), an internal control framework that auditors use to assess clients' internal controls. It describes the five components of COSO - control environment, risk assessment, control activities, information and communication, and monitoring. The document also discusses how COSO fits into the audit process and provides an overview of COSO 2, which incorporates enterprise risk management.
This document discusses testing of controls during an audit. It provides details on the types of audit procedures used for testing controls, including physical examination, confirmation, documentation, observation, accuracy, analytical evidence, and client inquiry. The reliability of different types of evidence is also discussed, with physical evidence and confirmation considered the most reliable, followed by external documentation and tests of accuracy. Guidelines are provided around the extent of testing controls, including reliance on prior audits and testing controls related to significant risks in the current year. Examples are also given around sample sizes used for testing controls.
POSITION OF INTERNAL AUDIT IN THE CORPORATE FRAMEWORKHaresh Lalwani
This presentation is my endeavor to bring to notice the new position that internal audit enjoys today in the corporate framework, expectations of the industry and emerging opportunities for the professionals.
A dedicated audit management program helps streamline the audit preparation process and implements board directives by simplifying and systematically organizing the workflow. It allows companies to prove compliance with industry standards through internal and external audits required by their regulations. The program offers separate internal and external audit modules that use role-based security and provide a single source of control documentation for easy access.
The document discusses continuous auditing and how technology can enable it. It defines continuous auditing and continuous controls monitoring, noting that continuous auditing uses automated tools to provide assurance on financial and non-financial data, while continuous controls monitoring seeks to assure the effectiveness of internal controls. It discusses how technology can help audit by providing immediate insight into control violations, increasing audit scope and frequency while reducing costs, and enabling fully automated control testing with an integrated risk view. This allows reducing recurrent testing costs while focusing on more valuable areas.
Continuous auditing (CA) involves the collection of audit evidence on systems and transactions on a continuous basis. It can be used by both external and internal auditors. Continuous monitoring (CM) is a related process used by management to continuously monitor compliance, controls, and disclosures. CA has advantages over traditional auditing such as being more efficient and timely. Factors driving demand for CA include regulations like SOX, increasing business complexity, and data availability from ERP systems. Implementing CA requires establishing a business case, ensuring client prerequisites are met, developing an adoption strategy, planning the implementation approach, designing and executing the plan, and ongoing monitoring and communication of results. Barriers to adoption include cost constraints and difficulties demonstrating ROI
The document outlines the role of an auditor throughout the system development life cycle (SDLC) process. It discusses the auditor's involvement in each phase, including preliminary review, system requirements analysis, system design, development, testing, implementation, maintenance, and IT governance. The auditor helps set the project scope, assess business objectives, review requirements and design documents, evaluate test results, ensure correct implementation, and supervise maintenance. The overall process involves understanding needs, designing, building, testing, and implementing systems while maintaining governance, risk and compliance standards.
How to integrate risk into your compliance-only approachAbhishek Sood
Information security policies and standards can oftentimes cause confusion and even liability within an organization.
This resource details 4 pitfalls of a compliance-only approach and offers a secure method to complying with policies and standards through a risk-integrated approach.
Uncover 4 Benefits of integrating risk into your compliance approach, including:
Reduced risk
Reduced deployment time
And 2 more
The document provides 5 steps for conducting better risk assessments, including adopting a root-cause approach to risk identification, standardizing a 1-10 assessment scale and criteria, linking risks to controls and strategic goals, and embedding risk management into everyday activities. It explains how prioritizing risks based on their root causes and using a consistent 1-10 scale allows organizations to better understand their top risks and prioritize mitigation activities. Following these best practices can help risk assessments add more value to businesses by providing transparent and actionable risk information.
Use of audit clauses in information technology and outsourcing agreements including implications for the Cloud, OSFI Memorandum of February 29, 2012, control audits and CSAE 3416 Audits (Richard Austin and Ken Silverman)
How auditable is your disaster recovery programgeekmodeboy
This research note discusses best practices for preparing for and managing an IT disaster recovery audit. Key findings include that audits are based on general control testing principles and require evidence of control execution, not just definition. A minimum requirement is a documented recovery plan, testing plan, and evidence of past tests. Recommendations include ensuring the audit scope is clear and that supporting evidence of past recovery plan exercises is provided if possible.
The document discusses a workshop on system based auditing held by the OECD and EU in Tirana, Albania from September 10-12, 2014. It defines a financial audit as providing reasonable assurance that a company's financial reports are fairly presented according to standards. It also defines a compliance audit as the independent assessment of whether a subject is following applicable rules and regulations. The scope of the workshop was to discuss audit methodologies, with a focus on financial and compliance audits.
The document outlines the 9 key steps to implementing a management system standard: 1) Learn about the Standard, 2) Perform a GAP Analysis, 3) Prepare a Project Plan, 4) Train your Employees, 5) Document your Management System, 6) Implement your Management System, 7) Audit your Management System, 8) Prepare for Certification, and 9) Preparing for your Certification Audit. These steps include selecting an appropriate standard, comparing current practices to standard requirements, creating documentation and training, implementing the system, conducting internal audits, and preparing for an external certification audit.
SOC2 Audit is a report that comprises details of evaluation on the service organization’s internal controls, policies, and procedures related to AICPA’S Trust Service Criteria. It is a report that assures the suitability and effectiveness of the service organization’s controls in context to security, availability, processing integrity, confidentiality, and privacy. It is an audit report that typically aids the client’s decision making in selecting a service organization to work in collaboration
Internal auditors require great expertise to provide advice on key control objectives and investigate fraud. They must also ensure compliance with laws and regulations, audit information systems, and help management promote economy, efficiency, and effectiveness. The scope of internal audits is wide and requires understanding operations as well as including management's needs in the terms of reference.
Evolving healthcare trends coupled with a slew of new features and functions to consider can overwhelm anyone charged with the task. Case managers typically are not been involved in the selection process, but that seems to be changing as organizations realize their input can be useful when it comes to choosing the most effective and efficient system.
Case managers who do get this opportunity can be prepared by staying up-to-date on the latest healthcare trends and technology that impact medical management functionality. While it is difficult to keep up with the expanding symbiotic interface between technology and care management workflow processes, case managers must understand how technology solutions can improve processes and patient outcomes.
Internal Control Certification – It’s Not Just an Accounting Thing (Credit Un...NAFCU Services Corporation
In this recorded 2012 NAFCU Technology & Security Conference session, you will learn about the internal control certification process and how it impacts more than just the accounting department. Discover the importance of becoming internal control certified, gain insight on the impact of recent regulation change from SAS70 to SSAE 16, and get a walkthrough of the process and audit reports (Type I & Type II) as well as discuss the involvement from the “technology side of the house,” including documentation of systems controls, disaster recovery and more!
Presented by Jeff Ziliani, CPA, Director of Finance and Administration, Burns-Fazzi, Brock
Burns-Fazzi, Brock is the NAFCU Services Preferred Partner for Executive Benefits and Compensation Consulting and Long Term Care Insurance.
More information at http://www.nafcu.org/bfb
This document discusses database auditing and security. It begins by stating that database auditing is key to ensuring data confidentiality, integrity and accessibility, and that database security is not effective without auditing. It then provides overviews of auditing, defining terms like audit logs, objectives, procedures and reports. It describes auditing activities, environments, processes and objectives. It outlines the components of a database auditing environment and classifications and types of audits, including internal, external, automatic, manual and hybrid audits.
Evaluate your CISA preparation. Attempt below 150 questions which are designed as per CISA exam pattern considering domain wise weightage.
http://datainfosec.blogspot.in/2016/04/cisa-mock-test-question-paper-1.html
Sap security compliance tools_PennonSoftPennonSoft
The document discusses using security compliance tools to detect and prevent security and controls violations in SAP systems. It outlines increased regulatory focus on security, risks like access control and segregation of duties issues, and how tools can help with real-time monitoring, resolving segregation of duties issues, and providing automated analysis and monitoring to assess authorization compliance. The benefits of these tools are that they can run with SAP, automate separation of duties analysis and monitoring of critical transactions, and provide quick assessments to business users, auditors, and security staff while avoiding manual analysis and false positives.
This document discusses tests of controls, which are used in SOC examinations to confirm that identified controls at a service organization are working effectively. There are five main methods for testing controls: inquiry, observation, examination of evidence, re-performance, and computer-assisted audit techniques. Inquiry involves asking questions, observation involves watching activities, examination of evidence involves reviewing documentation, re-performance involves redoing controls manually, and computer-assisted techniques use software to analyze large volumes of data. Audit sampling for tests of controls also falls into four categories: inquiry, observation, reperformance, and inspection of documents.
1. The document discusses the objectives, methodologies, and phases of performing an information systems audit.
2. Key methodologies discussed include the top-down and bottom-up approaches, with the top-down being business and risk focused and the bottom-up focusing on control objectives.
3. The phases of an audit include pre-engagement work, data collection through testing, interviews and documentation, data analysis to identify findings and risks, developing recommendations, and reporting results.
The document discusses COSO (Committee of Sponsoring Organizations of the Treadway Commission), an internal control framework that auditors use to assess clients' internal controls. It describes the five components of COSO - control environment, risk assessment, control activities, information and communication, and monitoring. The document also discusses how COSO fits into the audit process and provides an overview of COSO 2, which incorporates enterprise risk management.
This document discusses testing of controls during an audit. It provides details on the types of audit procedures used for testing controls, including physical examination, confirmation, documentation, observation, accuracy, analytical evidence, and client inquiry. The reliability of different types of evidence is also discussed, with physical evidence and confirmation considered the most reliable, followed by external documentation and tests of accuracy. Guidelines are provided around the extent of testing controls, including reliance on prior audits and testing controls related to significant risks in the current year. Examples are also given around sample sizes used for testing controls.
POSITION OF INTERNAL AUDIT IN THE CORPORATE FRAMEWORKHaresh Lalwani
This presentation is my endeavor to bring to notice the new position that internal audit enjoys today in the corporate framework, expectations of the industry and emerging opportunities for the professionals.
A dedicated audit management program helps streamline the audit preparation process and implements board directives by simplifying and systematically organizing the workflow. It allows companies to prove compliance with industry standards through internal and external audits required by their regulations. The program offers separate internal and external audit modules that use role-based security and provide a single source of control documentation for easy access.
The document discusses continuous auditing and how technology can enable it. It defines continuous auditing and continuous controls monitoring, noting that continuous auditing uses automated tools to provide assurance on financial and non-financial data, while continuous controls monitoring seeks to assure the effectiveness of internal controls. It discusses how technology can help audit by providing immediate insight into control violations, increasing audit scope and frequency while reducing costs, and enabling fully automated control testing with an integrated risk view. This allows reducing recurrent testing costs while focusing on more valuable areas.
Continuous auditing (CA) involves the collection of audit evidence on systems and transactions on a continuous basis. It can be used by both external and internal auditors. Continuous monitoring (CM) is a related process used by management to continuously monitor compliance, controls, and disclosures. CA has advantages over traditional auditing such as being more efficient and timely. Factors driving demand for CA include regulations like SOX, increasing business complexity, and data availability from ERP systems. Implementing CA requires establishing a business case, ensuring client prerequisites are met, developing an adoption strategy, planning the implementation approach, designing and executing the plan, and ongoing monitoring and communication of results. Barriers to adoption include cost constraints and difficulties demonstrating ROI
The document outlines the role of an auditor throughout the system development life cycle (SDLC) process. It discusses the auditor's involvement in each phase, including preliminary review, system requirements analysis, system design, development, testing, implementation, maintenance, and IT governance. The auditor helps set the project scope, assess business objectives, review requirements and design documents, evaluate test results, ensure correct implementation, and supervise maintenance. The overall process involves understanding needs, designing, building, testing, and implementing systems while maintaining governance, risk and compliance standards.
How to integrate risk into your compliance-only approachAbhishek Sood
Information security policies and standards can oftentimes cause confusion and even liability within an organization.
This resource details 4 pitfalls of a compliance-only approach and offers a secure method to complying with policies and standards through a risk-integrated approach.
Uncover 4 Benefits of integrating risk into your compliance approach, including:
Reduced risk
Reduced deployment time
And 2 more
The document provides 5 steps for conducting better risk assessments, including adopting a root-cause approach to risk identification, standardizing a 1-10 assessment scale and criteria, linking risks to controls and strategic goals, and embedding risk management into everyday activities. It explains how prioritizing risks based on their root causes and using a consistent 1-10 scale allows organizations to better understand their top risks and prioritize mitigation activities. Following these best practices can help risk assessments add more value to businesses by providing transparent and actionable risk information.
Use of audit clauses in information technology and outsourcing agreements including implications for the Cloud, OSFI Memorandum of February 29, 2012, control audits and CSAE 3416 Audits (Richard Austin and Ken Silverman)
How auditable is your disaster recovery programgeekmodeboy
This research note discusses best practices for preparing for and managing an IT disaster recovery audit. Key findings include that audits are based on general control testing principles and require evidence of control execution, not just definition. A minimum requirement is a documented recovery plan, testing plan, and evidence of past tests. Recommendations include ensuring the audit scope is clear and that supporting evidence of past recovery plan exercises is provided if possible.
The document discusses a workshop on system based auditing held by the OECD and EU in Tirana, Albania from September 10-12, 2014. It defines a financial audit as providing reasonable assurance that a company's financial reports are fairly presented according to standards. It also defines a compliance audit as the independent assessment of whether a subject is following applicable rules and regulations. The scope of the workshop was to discuss audit methodologies, with a focus on financial and compliance audits.
The document outlines the 9 key steps to implementing a management system standard: 1) Learn about the Standard, 2) Perform a GAP Analysis, 3) Prepare a Project Plan, 4) Train your Employees, 5) Document your Management System, 6) Implement your Management System, 7) Audit your Management System, 8) Prepare for Certification, and 9) Preparing for your Certification Audit. These steps include selecting an appropriate standard, comparing current practices to standard requirements, creating documentation and training, implementing the system, conducting internal audits, and preparing for an external certification audit.
SOC2 Audit is a report that comprises details of evaluation on the service organization’s internal controls, policies, and procedures related to AICPA’S Trust Service Criteria. It is a report that assures the suitability and effectiveness of the service organization’s controls in context to security, availability, processing integrity, confidentiality, and privacy. It is an audit report that typically aids the client’s decision making in selecting a service organization to work in collaboration
Analytical procedures and two basic audit approaches - systems based approach and direct substantive testing - are commonly used in audits. Analytical procedures involve analyzing financial ratios and trends to identify unexpected fluctuations. The systems based approach relies on evaluating internal controls, while direct substantive testing gathers evidence through examining transactions without relying on controls. Both approaches use procedures like analytical reviews, sampling, confirmations, and documentation to gather evidence and assess audit risk. The level of substantive testing required depends on the risks identified and whether controls can be relied upon.
Adopting the Right Software Test Maturity Assessment ModelCognizant
A brief guide to software test maturity assesment models, weighing pros and cons of the TMMi Foundation certification approach vs. advisory assessment models.
The document discusses how organizations can simplify their compliance programs through implementing consolidated objectives. Consolidated objectives involve mapping common requirements across different regulatory frameworks. This allows organizations to design controls that satisfy multiple frameworks, cutting down on duplicative work. The benefits of consolidated objectives include better risk visibility, increased agility to change, and stronger justification of compliance budgets. The document recommends looking for compliance tools that make it easy to identify overlapping content between frameworks and allow for reusability of testing.
In the realm of Governance, Risk, and Compliance (GRC), the significance of effective tools cannot be overstated. Managing compliance, mitigating risks, and ensuring sound governance practices are essential for businesses navigating today's dynamic and highly regulated landscape. That's where GRC tools come into play. In this comprehensive guide, we will delve into the evaluation process for GRC tools and shed light on the must-have features that drive efficient compliance management. Specifically, we will showcase the essential elements of our compliance management software, demonstrating how it can enhance your organization's GRC efforts. So, join us as we explore the world of GRC tools and unveil the key factors to consider when evaluating their effectiveness.
Running head AUDITING INFORMATION SYSTEMS PROCESS .docxjoellemurphey
Running head: AUDITING INFORMATION SYSTEMS PROCESS
1
AUDITING INFORMATION SYSTEMS PROCESS 2
Auditing information systems process
Student’s Name
University Affiliation
Process of Auditing information systems
Information system is the livelihood of every huge company. As it has been in the past years, computer systems don’t simply document transactions of business, rather essentially compel the main business procedures of the venture. In this kind of a situation, superior administration and company managers usually have worries concerning an information system. assessment is a methodical process in which a proficient, autonomous person impartially gets and assesses proof concerning affirmations about a financial unit or occasion with the intent to outline an outlook about and giving feedback on the extent in which the contention matches an acknowledged standards set. information systems auditing refers to the administration controls assessment inside the communications of Information Technology. The obtained proof valuation is used to decide if systems of information are defensive assets, maintenance reliability of data, and also if they are efficiently operating in order to attain organization’s goals or objectives (Hoelzer, 2009).
Auditing of Information Systems has become an essential part of business organization in both large and small business environments. This paper examines the preliminary points for carrying out and Information system audit and some of the, techniques, tools, guidelines and standards that can be employed to build, manage, and examine the review function. The Certified Information Systems Auditor (CISA) qualifications is recognized worldwide as a standard of accomplishment for those who assess, monitor, control and audit the information technology of an organization and business systems. Information Systems experts with a concern in information systems security, control and audit. At least five years of specialized information systems security, auditing and control work practice is necessary for certification. An audit contract should be present to evidently state the responsibility of the management, purpose for, in addition to designation of power to audit of Information System . The audit contract should also summarize the general right, responsibilities and scope of the purpose of audit. The uppermost level of management should endorse the contract and on one occasion it is set up, this contract is supposed to be distorted merely if the amendment is and might be meticulously defensible.
The process of auditing information systems involves;-
Audit Function Management; this process includes assessment which is systematic of policies and methods of management of the organization in managemen ...
Understanding the Roles and Responsibilities of ISMS Auditor.docxINTERCERT
Information Security Management System (ISMS) auditing serves as an important principle in bridging the gap in information security risks controlling. In the role of ISMS Auditor, you incarnate the third party that impartially assesses whether the particular organization has already adopted the relevant rules, methods and measures to effectively overcome information security risks by implementing the set standards.
The document outlines an agenda for a training on audit documentation, tools, and techniques for internal auditors. It includes introductory lectures, product and case study presentations, exercises, and breaks. It also discusses the internal auditor's role, the audit process, internal controls, documenting controls, risks, and system documentation methods like flowcharts and questionnaires.
Legal Register / Compliance Obligations ISO 14001Nimonik
https://nimonik.com
An overview of why your organization should equip itself with a robust and integrated Legal Register (Compliance Obligations). Reviews of the purpose, intent and benefits of a Legal Register.
An introduction to the Data Protection & GDPR Health Check service provided by DVV Solutions. Ensure your compliance with GDPR and understand the gaps you need to fill.
The document discusses standards that must be followed by Wright Aircraft Corp to enable an effective information security program, noting that compliance is mandatory though deviation is possible with approval. The standards define minimum baseline procedures, practices, and configurations for systems and related topics to provide a single reference point during various stages of development and contracting. However, the standards do not provide detailed instructions for how to meet the company's policies.
The audit will review UNCCG's enterprise data warehouse platform over several phases:
1) A mobilization phase to develop audit plans and interview lists.
2) An execution phase to conduct interviews, review documents, and test controls.
3) A reporting phase to draft and finalize audit reports with findings and recommendations.
The audit will focus on data warehouse management, operations, and business integration, and assess risks relating to regulatory compliance, privacy, vendor access, and system availability. Regular communication with management will be maintained throughout the engagement.
The International Aerospace Quality Group (IAQG) expects to issue a revised version of the Aerospace Standard AS9101 later this year. The revision, called Rev E, will focus audits more on process effectiveness and the achievement of quality objectives. Auditors will intensely examine process management and will expect to see that quality performance is monitored and measured against objectives. Organizations need to select key performance indicators (KPIs) that reflect critical success factors and review them to ensure they still apply given changes to processes, objectives, or business scope. Rev E provides an opportunity for organizations to re-examine their quality policies and processes in preparation for the new audit standards.
How an Organization Can Elevate Compliance Standards360factors
Modern enterprises face increasing pressure to comply with various regulations regarding supply chains, materials, health, safety, and waste. They must develop robust internal controls and compliance programs to adhere to current and future laws and standards. This document outlines five best practices for effective compliance programs: understand requirements, identify risks, create transparency, ensure operational compliance, and resolve issues. It also discusses how AI-based compliance management software can help centralize and automate compliance activities across an organization.
This document discusses quality assurance and auditing. It defines quality assurance and audits, and outlines the key aspects of structuring an audit program including planning, performing, and reporting on audits. It discusses auditing specific activities, functions, product lines, and quality systems. It also covers quality surveys to assess overall quality performance, standards, and culture. Product audits and sampling for product audits are mentioned.
The document discusses a compliance solution called Compliance 360 that helps financial services organizations address regulatory challenges. It provides pre-built risk assessments, policy management, regulatory change monitoring, consumer complaint handling, third party management, compliance auditing and monitoring, and a virtual evidence room. Compliance 360 allows organizations to streamline compliance processes, identify compliance gaps and risks, eliminate duplicate efforts, and easily maintain records to demonstrate effective compliance management.
Similar to Dimension data pursuing compliance in public cloud white paper (20)
For the full video of this presentation, please visit: https://www.edge-ai-vision.com/2024/06/building-and-scaling-ai-applications-with-the-nx-ai-manager-a-presentation-from-network-optix/
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Dimension data pursuing compliance in public cloud white paper
1. Pursuing Compliance in the Public Cloud
Identifying the right compliance strategy for your business in the cloud
February 2014
Version 1.1
Jason Cumberland
2. Dimension Data White Paper: Compliance in the Public Cloud
Introduction:
Organisations considering moving IT assets or applications from an on-premise installation to the
cloud face a bewildering array of compliance options and certifications. Organisations commonly ask
themselves these questions when developing their own compliance roadmap and strategy:
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Which certifications do I need to achieve directly?
For which certifications can I leverage my data centre provider?
Do I need to bring in an outside auditor or can I conduct a self-audit?
What are my competitors doing in terms of compliance? Should my strategy be the same?
What will my clients expect of me in the sales process?
The key to successfully navigating the compliance waters is to determine which of the many available
certifications are relevant to your business and which add more cost and complexity to your business
than they’re worth. Given that each of the common compliance standards is accompanied by
significant costs, correctly identifying the requirements from your internal stakeholders and
clients is a critical initial step when developing your compliance strategy.
In this paper, we’ll discuss several of the most common compliance standards to help determine the
applicability of each to your business. These include:
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AICPA Statement on Standards for Attestation Engagements No. 16 (SSAE 16)
Payment Card Industry Data Security Standard (PCI DSS)
The Health Insurance Portability and Accountability Act of 1996 (HIPAA)
US–EU Safe Harbor Framework
International Standards Organization (ISO) 17799 / 27002
International Standards Organization (ISO) 27001
Food and Drug Administration (FDA) Title 21, Code of Federal Regulations (CFR) Part 11
Federal Information Processing Standards (FIPS) / Federal Information Security Management
Act (FISMA) / The Federal Risk and Authorization Management Program (FedRAMP)
Sarbanes–Oxley Act (SOX)
Gramm–Leach–Bliley Act (GLBA)
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3. Dimension Data White Paper: Compliance in the Public Cloud
Commonly used terminology
To aid in the detailed evaluation of each of the above certifications, it’s important to establish the
terminology that we’ll use throughout this paper.
Control objectives versus control procedures and activities
Control objectives provide high-level goals that organisations try to achieve using policies, procedures,
and systems. Control procedures and activities are the actual policies and procedures that are put in
place to achieve the objectives.
Best practice versus prescriptive standards
‘Best practice’ standards define control objectives, goals or methods that work across many
organisations but allow organisations to choose which ones to use and how to implement them.
‘Prescriptive’ standards provide detailed control requirements that need to be met exactly as outlined
in order to meet the standard.
Attestation versus certification
Attestation is the result of an audit conducted to measure compliance with control objectives set by
an organisation. The auditor measures whether the control objectives are met by the control
procedures in place. The auditor attests to the organisation’s ability to meet its own standards but
does not determine whether the standards are valid. In this case, because there are no prescriptive
standards, there’s no easy way to compare organisations simply by establishing whether an
attestation standard has been completed.
Certification is the result of an audit conducted to measure compliance with prescriptive standards.
The auditor can explicitly certify whether those standards have been met. From a buyer’s perspective,
these standards can be used to directly compare service providers given that the standards for each
organisation are the same.
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4. Dimension Data White Paper: Compliance in the Public Cloud
Detailed review of compliance and common security standards
SSAE 16 (Formerly SAS70)
The Statement on Standards for Attestation Engagements (SSAE) 16 is an attestation standard used
by auditors to evaluate the internal systems of a service provider. ‘Systems’ are generally defined as
the services provided, along with the supporting processes, policies, procedures, personnel and
operational activities that constitute the service organisation's core activities that are relevant to user
entities.
SSAE 16 is not a prescriptive standard. Instead, it reviews whether an organisation’s control
procedures are followed and whether those procedures achieve the organisation’s control objectives.
The audit does not make a judgment as to whether the control objectives are ‘good’ or will meet
security or other objectives. However, companies are now required to submit a management
assertion as part of the SSAE process attesting (among other items) that the control objectives were
suitably designed, and that the description of the system is accurate.
SSAE 16 control objective example: An organisation could define an SSAE 16 control objective
that stipulates only individuals with a green identity badge are allowed access to the data centre,
and a control activity that the posted security guard will allow anyone into the data centre as long
as their identity badge meets this criterion. In this case, as part of the SSAE 16 review, outside
auditors will evaluate whether the control activity (the security guard’s ability to enforce the control
objective) is sufficient to meet the control objective, and ask for proof (documentation) that the
control activity was consistently followed. So long as this documentation exists, this control
objective will be achieved.
While this is a ‘bad’ control objective from a security point of a view, as long as an organisation shows
that it meets the stated objective, it will be considered to be compliant from an SSAE 16 point of view.
There are two types of SSAE 16 audits, usually performed sequentially:
• SSAE 16 Type I – Type 1 is a “point in time” audit that evaluates the control procedures at a
single point in time, identifying whether the control procedures will meet the control
objectives.
• SSAE 16 Type II – Type II evaluates the effectiveness of control procedures over a period of
time, so the auditor looks to make sure the control procedures are being followed.
The result of a completed SSAE 16 audit is a SOC 1 (service organisation control) report.
Prevalence and relevance:
From a service provider perspective, the SSAE 16 Type II audit is generally considered ‘table stakes’
in the world of service providers of public cloud, managed hosting, and co-location services. It should
be a must-have for any commercial application hosting. The standard is most common in North
America, with acceptance among many global organisations as well.
While the controls and scope of an SSAE audit vary greatly for the reasons explained above,
generally, there are three broad areas of scope for an SSAE audit:
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5. Dimension Data White Paper: Compliance in the Public Cloud
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Software development control objectives
Operational control objectives
Data centre/facility control objectives
In the best case, a service provider can cover only two of these three, given that it has no involvement
in a client’s software development process. If a client manages its own environment (software
deployment, change control, patching procedures, etc.) – which is typical – then the provider’s
operational controls are of limited value to a prospective client in a sales cycle given that the
independent software vendor (ISV) will be responsible for managing its own operational controls. In
this case, relying on a provider’s SSAE audit covers only one of three areas of scope of the SSAE
audit.
Service providers offering managed services that extend the management of the client’s application
(i.e. Application Operations from Dimension Data) extend coverage to two of the three areas of scope,
which can offer prospective clients more assurance than if an ISV’s operational processes are
unaudited.
Service provider versus ISV/enterprise applicability:
While considered a must-have for service providers, the requirement for an independent software
vendor or enterprise to complete its own audit is far less definite. In some cases, ISVs can leverage
the SSAE certification of the data centre provider in its sales cycles to satisfy their clients’ control
requirements. However, sophisticated buyers of IT services or software-as-a-service (SaaS) offerings
will often insist on seeing the enterprise/ISV’s SSAE audit results as well.
Approximate costs:
The costs of any audit discussed in this paper include a combination of hard costs (money paid to an
outside firm to complete the audit, hardware and software costs to meet various security requirements,
etc.) as well as personnel costs related to the time required to prepare for the audit, implement the
required organisational controls, and work with the auditors throughout their review to ensure a
successful result. In many cases, the latter category of soft costs is far more expensive than the fees
paid to the auditors. These soft costs are also more difficult to generalise, as each organisation’s
experience will differ. Our advice is to work with your auditor to assess the time required before
beginning any outside audit process. This will ensure that internal expectations are properly
established to successfully complete the audit in the established timelines.
In general, the hard costs of an SSAE attestation paid to an outside firm range from USD 15,000 25,000 per site being inspected, with significant variation depending on the scope of audit. As
mentioned above, in the case of SSAE the organisational costs of SSAE compliance (including the
costs to prepare and gather documentation for the audit, employment of an internal security/control
officer, costs of ongoing internal audit activities throughout the year to maintain compliance, etc.)
easily outweigh the hard costs.
Best practices and recommendations:
When selling a service to a commercial or enterprise market (i.e. non-consumer services), SSAErelated questions will commonly come up in pre-sales conversations. If your organisation has the
Page 5 of 16
6. Dimension Data White Paper: Compliance in the Public Cloud
operational discipline to meet the control objectives you define (generally through a culture of strict
adherence to process, heavy documentation, and internal audit reinforcement), and you can justify the
costs of your own SSAE audit, our recommendation is that you pursue your own audit to remove
barriers in the pre-sales process. By selecting a service provider that has completed its own audit,
you can often limit the costs and scope of your own audit by ‘carving out’ the portions of the controls
already met by your service provider, and limit the scope of your own audit to only those items for
which your organisation is directly responsible.
Due to the costs of an SSAE audit as well as the maturity of organisational processes and controls
required, many smaller or early-stage organisations cannot justify the conducting their own SSAE
audit. In this case, organisations commonly utilise their service provider’s SSAE compliance
(generally at the facility level). Organisations can leverage more meaningful and extensive SSAE
compliance by selecting a vendor with a managed service offering that extends its SSAE compliance
through the operational controls related to the specific application being hosted. This allows the
ISV/enterprise to confidently respond to pre-sales questions regarding SSAE compliance covering
both facilities and operational controls, without incurring the significant costs of an individual SSAE
audit.
Lastly, regardless of whether you choose to pursue your own SSAE audit, ensure that you carefully
review your provider’s SSAE report (generally under a non-disclosure agreement). The details of
these tests will vary from one provider to another, and it is critical to your own risk mitigation strategy
to understand the scope and detailed results of each provider’s audit.
Payment Card Industry Data Security Standard (PCI DSS)
PCI DSS is a prescriptive data security standard that applies when storing, processing, or
transmitting credit and debit card data. The security standards are agreed to by the major credit
issuers (Visa, MasterCard, etc.) to eliminate the establishment of separate standards for each issuer.
All credit card companies require adherence to these standards in their terms of service.
‘Acquiring banks’ (banks processing the issuer’s credit card transactions) are responsible for ensuring
that their merchants are compliant with the PCI Data Security Standard and that the merchants use
PCI-certified service providers. Acquiring banks generally ‘pass through’ this requirement in their
agreement with their merchants, meaning that the merchants are financially responsible for any losses
if they are not compliant or were using non-compliant service providers.
There are currently four different levels of certification and related requirements*:
• Level 1 (> 6 million transactions per year, credit card processors/payment gateway):
o Requires an annual on-site audit and quarterly network scan
• Level 2 (> 1million credit/debit transactions per year):
o Requires an annual on-site audit and quarterly network scan or self-assessment
questionnaire (requirements vary depending on issuing bank)
• Level 3 (< 1million transactions per year):
o Requires an annual self-assessment questionnaire and quarterly network scan
• Level 4 (20k – 1million transactions per year):
o Requires an annual self-assessment questionnaire and quarterly network scan
Page 6 of 16
7. Dimension Data White Paper: Compliance in the Public Cloud
*Note that each major card issuer has slightly varying requirements for Level 1 through 4. The
information above is a generalisation of the different issuers.
Prevalence and relevance:
PCI is the compliance standard and the definitive standard for any organisation processing credit card
data.
Service provider vs. ISV/enterprise applicability:
Prospective buyers of SaaS or infrastructure-as-a-service (IaaS) often include PCI compliance in their
checklist of requirements without a complete understanding of the complexities involved in pursuing a
PCI compliance strategy. Similar to SSAE 16, PCI compliance can be achieved with varying audit
scopes. For a complete PCI compliance strategy, an organisation must be compliant at the hardware,
process, software, and facilities levels. A data centre provider’s PCI compliance cannot legitimately
cover all of these areas for a third-party hosting within their facilities (see best practices below for
further information).
Approximate costs:
Costs for a full-scale PCI audit vary significantly. The initial consulting fees to establish the scope of
the analysis and any gaps in current procedures commonly ranges from USD 25,000-100,000+
depending on the size of the organisation and established scope. A bare-bones onsite PCI audit
could cost as little as USD 20,000-30,000 per year, with in-depth audits for large organisations easily
costing more than USD 100,000 annually.
Key soft costs to consider:
The organisational process changes required to adhere to PCI compliance can be significant. Among
other things, organisations must nominate (or hire) an internal security officer who will be responsible
for managing compliance internally between audit periods.
Best practices and recommendations:
The first distinction that we recommend clients make when pursuing PCI-compliant hosting is to
decide whether they are pursuing a PCI-compliant provider solely for marketing value (i.e. making the
claim that the application is hosted in PCI-compliant facilities), or whether the organisation actually
intends to pursue its own PCI audit of the application being hosted.
While we do not generally dispute the marketing value of the former strategy, from a security
perspective, this is not a model that will carry significant value with an experienced INFOSEC
organisation. If your application is processing or storing any credit card data, to be compliant with the
card issuer’s terms of service, your organisation must complete its own PCI audit. Similar to SSAE,
portions of the PCI requirements can be ‘carved out’ of your own audit based on your service provider
having completed a separate audit, but the application itself must undergo its own evaluation.
Health Insurance Portability and Accountability Act (HIPAA)
The sections of HIPAA relevant to data centre service providers relate to the security of patient data
processed or stored by ‘covered entities’. Covered entities include those with a direct patient
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8. Dimension Data White Paper: Compliance in the Public Cloud
relationship, such as hospitals, doctors, pharmacies and insurance companies. These entities must be
HIPAA compliant under the provisions of the law.
This definition of ‘covered entities’ makes it technically impossible for any data centre service
provider to be HIPAA compliant because they are not covered entities under the law’s provisions.
For this reason, we advise that organisations seeking data centre providers proceed with caution
when dealing with a service provider claiming HIPAA compliance.
While service providers cannot be HIPAA compliant, they may qualify as a ‘business associate’ of a
HIPAA-covered entity if involved in a function or activity involving the use or disclosure of protected
health information. Generally this means that if any patient data is stored in the application
running in a service provider’s infrastructure, a service provider is obligated as a business
associate under HIPAA.
Prevalence and relevance:
HIPAA is a common compliance standard (though often misunderstood) and the definitive standard for
any organisation processing patient healthcare data.
Service provider vs. ISV/enterprise applicability:
HIPAA-covered medical organisations are required to contractually obligate business associates to
utilise security mechanisms and privacy procedures that include (but are not limited to):
• Security mechanisms that ensure all transmissions of data are authorised and employ the
standards necessary to protect the integrity and confidentiality of the data that is transmitted.
• Privacy procedures that require any unauthorised use or disclosure of protected health
information to be reported to the medical organisation.
• Security mechanisms that protect records and other data from improper access.
• Privacy policies that bind the service provider’s agents and subcontractors to the same
restrictions on the use and disclosure of protected health information as those imposed upon
the service provider.
In addition, the covered entity’s business associate agreement (BAA) with the service provider must
include specific procedures for the storage and transfer of patient data in the event that the contract is
terminated, the service provider goes out of business, and/or is acquired by or merged into an
organisation that is unsatisfactory to the entity.
Approximate costs:
While there are several organisations available to help you develop your HIPAA compliance strategy,
there is no third-party data centre audit requirement under HIPAA, so there’s no formal attestation or
certification that service providers can achieve. As a result, costs here are less definitive but may
include items such as backup software, data archiving tools, write-once storage media, etc. A service
provider experienced with HIPAA hosting will be able to provide for many of these requirements within
its standard offering.
Best practices and recommendations:
Given the structure outlined above, the key distinction when seeking out service providers to host
HIPAA-related data is that they are willing to accept liability for breach of the confidentiality of the data
Page 8 of 16
9. Dimension Data White Paper: Compliance in the Public Cloud
they’re hosting. This is key to fulfilling an organisation’s responsibilities under HIPAA and ensures that
the risk for data confidentiality flows through to all organisations involved in the processing or storage
of the related data.
While there are general requirements for HIPAA hosting, there is not one standard set of contract or
security terms related to HIPAA, so expect some discussion with your provider regarding your specific
BAA and the best way to meet the requirements under its specific business associate agreement.
US–EU Safe Harbor
European Union (EU) law prohibits the transfer of an individual’s personal data to non-EU nations that
do not meet the European adequacy standard for privacy protection. To provide a streamlined means
for US organisations to comply with the law, the United States Commerce Department developed the
Safe Harbor framework of prescriptive security standards.
Safe Harbor certification will assure EU that your company provides ‘adequate’ privacy protection.
Safe Harbor requires you put in place a privacy policy and procedure that covers the gathering and
use of personal information. At a high level, the policy needs to cover several areas:
• Notice – you must provide notification about the purpose for which you collect and use
information about individuals, and explain disclosures to third parties. You also have to
provide individuals with a way to contact the company with inquiries or complaints.
• Choice – you must give individuals the ability to opt out of having their personal information
disclosed to a third party.
• Third parties – any third parties to which you disclose information must follow the same
policies.
• Access – you must give individuals the ability to correct, amend, or delete collected
information if it is inaccurate.
• Security – you must take reasonable precautions to protect the data.
• Data integrity – you must have a relevant purpose for maintaining and using any personal
data collected.
• Enforcement – you must implement systems to enforce these policies and fix any problems
identified.
Service provider versus ISV/enterprise applicability:
This standard generally applies to enterprises, ISVs, and data centre providers. It’s uncommon for
organisations to rely completely on their data centre provider for this certification.
Approximate costs:
Safe Harbor is a self-audit certification. Certification consists primarily of developing a qualifying
privacy policy (for which you may wish to engage outside expertise) and identifying a company officer
who will certify that the organisation will follow the policy and Safe Harbor requirements. You must
also identify all data you are collecting about EU citizens. This information must be submitted to the
Commerce Department for review, after which the US Government will certify you under Safe Harbor.
There are no audit or application costs for achieving this certification.
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Best practices and recommendations:
It’s our recommendation that clients dealing with European organisations pursue their own Safe
Harbor certification in addition to ensuring that their data centres are compliant.
International Standards Organization 17799 / 27002
ISO 17799 was renamed to ISO 27002 but references to both are still regularly found.
ISO 17799 provides best practice recommendations for information security management, covering all
information (files, paper, faxes, phone calls, email, etc.) within an organisation. These
recommendations may not all apply and do not all need to be used. Organisations are expected to
review and decide what is relevant for their specific use case.
The standard includes 134 specific controls, categorised into approximately 36 control objectives
covering areas such as:
1. Risk assessments and treatment
2. System policy
3. Organising information security
4. Asset management
5. Human resources security
6. Physical and environmental security
7. Communications and operations management
8. Access control
9. Information systems acquisition, development and maintenance
10. Information security incident management
11. Business continuity management
12. Compliance
Information security is defined within the standard in the context of three areas
– Confidentiality: ensuring that information is accessible only to those authorised to have
access.
– Integrity: safeguarding the accuracy and completeness of information and processing
methods.
– Availability: ensuring that authorised users have access to information when required.
Prevalence and relevance:
Like the other ISO standards, this is most commonly pursued by global organisations.
Best practices and recommendations:
Due to the self-audit nature of this standard, organisations serving a global market but without the
budget or desire to pursue ISO 27001 certification may prefer to adhere to this standard, or portions of
this standard, as an interim step.
International Standards Organization: ISO 27001
ISO 27001 provides a prescriptive specification for an organisation’s information security
management system (ISMS), which includes all of the policies, procedures, roles, responsibilities,
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resources, and structures that are used to protect an organisation's information, as well as the
management and control of the security risks associated with the information.
ISO 27001 is based on ISO 17799 / ISO 270002. However, unlike ISO 27002, ISO 27001 is a
standard an organisation can be certified against.
The audit is normally conducted in two stages:
• A review of the existence and completeness of key documentation such as the organisation's
security policy, statement of applicability (SoA) and risk treatment plan (RTP).
• An actual audit to test the existence and effectiveness of the ISMS controls stated in the SoA
and RTP, as well as their supporting documentation.
Prevalence and relevance:
The various ISO certifications are generally preferred by organisations with operations outside North
America (in contrast to SSAE, which is more commonly accepted or preferred by organisations within
North America).
Service provider versus ISV/enterprise applicability:
Similar to SSAE 16, this is an audit that can be valid for both service providers and enterprises. Due
to the costs of this audit, however, it is not commonly pursued by small or mid-market organisations,
particularly those organisations without global operations.
Approximate costs:
Estimated hard costs: These vary widely based on the size of the organisation and auditing firm, but
generally run between USD 50,000-100,000 with certifications valid for up to three years. Years two
and three each require a smaller scale, follow-up audit that generally costs an additional USD 5,00010,000.
Key soft costs to consider:
Due to the prescriptive and detailed nature of this certification, the soft costs of implementation can be
significant. These costs come chiefly from establishing policy documents, changing existing
operational process to comply with ISO standards, and the internal controls that must be implemented
to ensure compliance with the standards between the formal external audit periods.
Best practices and recommendations:
For organisations dealing primarily with North American customers, an ISO certification may not be as
cost-effective or important as completing a well-scoped, in-depth SSAE audit. Due to the nonprescriptive nature of SSAE, that audit can actually be developed to meet many or all of the same
standards as ISO. While this strategy will not allow you to claim official ISO compliance, it will allow
you to provide prospective clients with an SSAE attestation and report showing the specific areas that
were audited, which will suffice in many situations. For organisations dealing primarily with clients
outside of North America, ISO certification is a requirement you will want to seriously consider.
Other less commonly cited certifications in the managed hosting / cloud service provider industry
include ISO 9001 (covering product quality management systems), ISO 14001 (also covering product
quality management systems, but those directly related to how a product is produced), ISO 50001
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(covering energy management systems), and OHSAS 18001 (standards for occupational health and
safety management systems).
FDA Title 21, CFR Part 11
This FDA regulation applies to all entities regulated by the FDA except food manufacturers. Common
examples are drug manufacturers, medical device manufacturers and biotechnology companies. This
regulation requires such companies to implement various controls, audits, validation systems and
documentation for software and systems related to electronic records and signatures maintained by
the organisations under FDA regulation.
These tend to be records or signatures that are being submitted to the FDA or stored as part of an
approval process for a new product
At a high level, the requirements include:
• Systems validation – all computer systems have to be ‘validated’. Essentially, the company
must identify and document what the system will be used for and who will use it, and ensure
that the hardware and software are adequate for the task (all verified through production
testing).
• Record retention – will vary depending on the FDA regulation to which the records are
related.
• Records security – securing data so only authorised users have access.
• Audit trails – maintenance of audit trails for the creation, modification, and deletion of
records, including who made the change and when.
• Electronic signatures – includes fingerprints, retinal scans, or ID names and passwords that
meet certain requirements. Signatures must include certain data (commonly the name of
person, whether the signature is providing an approval or denial, and a date and time). They
must also be protected so they cannot be modified once captured.
Service provider vs. ISV/enterprise applicability:
It is uncommon and improbable that service providers will need to meet this requirement directly.
Usually, the organisations outlined above are responsible for meeting these standards. A data centre
provider’s responsibility typically involves providing supporting hardware and tools such as write once,
read many (WORM) storage infrastructure.
Best practices and recommendations:
Given that this is an enterprise-only requirement, the service provider can provide only limited
assistance in helping you maintain compliance with this regulation. As such, we recommend that you
ensure your cloud provider has dealt with these requirements before and can recommend
technologies to meet your specific FDA requirements.
FIPS, FISMA, and FedRAMP
FIPS are Federal Information Processing Standards, many of which are incorporated into FISMA, the
Federal Information Security Management Act (2002). The act requires all federal agencies and their
contractors to safeguard their electronic systems (regardless of whether these agencies or systems
involve cloud providers).
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FedRAMP is the Federal Risk and Authorization Management Program (2012). It requires that all
federal organisations that use or plan to use a cloud environment implement the security controls of
this program. FedRAMP contains additional controls, not present in a FISMA assessment, specific to
cloud environments.
FedRAMP was created to establish a risk management programme that could be applied to the entire
federal government. At a high level, it covers four steps before establishing a cloud-based service:
•
Initiating: agencies or cloud service providers (CSPs) initiate the FedRAMP programme by
pursuing a security authorisation.
•
Assessing: based on the NIST SP 800-53 Rev. 3 requirements, CSPs must hire a third-party
assessment organisation to perform an independent assessment.
•
Authorising: upon completion, the security assessment package will then be forwarded to the
FedRAMP Joint Authorization Board (otherwise known as JAB) for review.
•
Leveraging: the CSP will then continue to work with the executive departments and agencies
for authority to operate (ATO) permissions.
Service provider vs. ISV/enterprise applicability:
Because of the scope of these federal compliance standards, in general ISVs or enterprises must
obtain their own compliance as well as operate in a data centre that meets these standards.
Approximate costs:
Like other audits, FedRAMP costs vary, but range from USD 40,000-100,000. The soft costs are far
more significant, with the average assessment process requiring six months or more.
Best practices and recommendations:
Companies whose government clients make up a large portion of their revenue will likely have no
choice but to pursue the FedRAMP certification process. As FedRAMP is still an emerging standard
as of the date of this paper, expect changes in the coming year as the government formalises the
programme. Due to the significant costs of compliance and limited relevancy outside government
agencies, non-government-centric organisations are not likely to pursue this standard.
Sarbanes–Oxley (SOX) Compliance
In 2002, the US Congress enacted the Sarbanes–Oxley (SOX) Act. The act was targeted at changing
the way public companies report their financial results and carried with it a significant impact to IT
organisations due to the heavy logging and documentation requirements included in the act. The act
also contains additional controls related to record retention, which must be carefully implemented into
any hosting strategy.
Section 404 of SOX covers the assessment of internal controls (to be conducted by an outside party).
COBIT stands for Control Objectives for Information and Related Technology. These objectives
require logging and reporting of key activities such as application level access control changes, events
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triggering access changes, transaction types, user IDs, and date and timestamps for all such activities.
All unauthorised attempts to access the application must also be logged and reported with a time and
IP address.
Service provider vs. ISV/enterprise applicability:
Due to the financial reporting focus of the SOX Act, data centre service providers cannot provide SOX
compliance for their clients. However, the internal controls of the service provider can make an
outside SOX audit far easier to complete successfully. In many cases, the controls from other, more
directly relevant IT standards such as SSAE 16 or ISO 27001 can also be used to help verify SOX
compliance. In addition, public cloud providers with user-based permissions, individual account
logins, and in-depth logging built into the application can make SOX compliance far easier.
Apart from the infrastructure controls in place, an ISV or enterprise must implement additional controls
at the server or application level to meet the requirements of SOX.
Gramm–Leach–Bliley Act (GLBA)
The GLBA was originally passed in 1999 and its implications were largely for financial institutions. In
the Act, financial institutions are defined as all businesses, regardless of size, that are ‘significantly
engaged’ in providing financial products or services. This includes, for example, cheque-cashing
businesses, payday lenders, mortgage brokers, non-bank lenders, personal property or real estate
appraisers, professional tax preparers, and courier services.
Service provider vs. ISV/enterprise applicability:
Two specific rules in the act are most directly relevant to conducting business in the cloud.
The Financial Privacy Rule, which governs the collection and disclosure of customers’ personal
financial information by financial institutions. It also applies to companies, regardless of whether they
are financial institutions, that receive such information – companies like cloud providers.
The Safeguards Rule requires all financial institutions to design, implement and maintain a
‘comprehensive information security programme’ to protect non-public customer information. It
requires period testing of the programme as well.
Lastly, prior to allowing a service provider to access customers’ personal information, the financial
institution must:
•
•
Take reasonable steps to select and retain service providers that are capable of maintaining
appropriate safeguards for the customer information.
Require the service providers, under contract, to implement and maintain such safeguards.
Cloud providers are included in the scope of the Financial Privacy Rule above. Prior to disclosing any
information to a cloud provider, cloud customers must enter into a contract with the provider which
prohibits the provider from disclosing or using the affected data in any manner other than to carry out
the purposes for which the information was disclosed. In practice, this is a common legal provision in
most cloud contracts.
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The GLBA also requires that all financial institutions provide their clients with the right to opt out of
sharing their personal financial information with non-affiliated third parties. In this case, the enterprise
must carefully develop provisions to remove specific client data from external storage systems as
soon as such a request is received.
Best practices and recommendations:
For financial institutions considering storing data in a cloud environment: ensure that the internal
operational controls and security policies put in place to comply with GLBA can be extended into your
cloud environment. Not all cloud providers are equal when it comes to security within the
environment. Be sure to review the relevant details carefully to understand whether GLBA can be
maintained in the cloud environment of your choice. Clients with GLBA exposure may also want to
explore hosted private cloud alternatives where greater degrees of data separation can be achieved.
Lastly, ensure that you follow the stipulations above regarding the Privacy Rule and related
contractual requirements to maintain compliance with GLBA when working with a third-party cloud
provider.
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Dimension Data cloud compliance
Dimension Data operates numerous data centre facilities around the world, and as such, our
compliance audits and certifications vary by location. In combination, Dimension Data and/or the
facilities in which we operate our data centres meet the following compliance standards:
•
•
•
•
•
•
•
•
SSAE 16 Type II
PCI Level 1
FISMA Moderate
EU Safe Harbor
ISO 9001(2008)
ISO 27001(2005)
ISO 50001(2011)
OHSAS 18001(2007)
In addition, while Dimension Data or its facilities cannot be directly certified against the following
standards (given that data centre providers are not the focus of these standards), we regularly help
clients achieve and maintain their own compliance against these standards:
•
•
•
•
HIPAA
FDA Title 21, CFR Part 11
Sarbanes–Oxley (SOX)
Gramm–Leach–Bliley Act (GLBA)
Successfully complying with any of these standards typically involves a joint effort between the
Dimension Data team and our client. We have significant experience in operating under all of these
compliance standards and would welcome the opportunity to answer any questions you have about
maintaining these standards in a cloud environment.
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