COSO Committee of Sponsoring Organizations of the Treadway Commission
Principle 11. The organization selects and develops general control activities over technology to support the achievement of objectives.
The following points of focus highlight important characteristics relating to the principle:
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Determines Dependency between the Use of Technology in Business Processes and Technology General Controls—Management understands and determines the dependency and linkage between business processes, automated control activities, and technology general controls.
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Establishes Relevant Technology Infrastructure Control Activities—Management selects and develops control activities over the technology infrastructure, which are designed and implemented to help ensure the completeness, accuracy, and availability of technology processing.
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Establishes Relevant Security Management Process Control Activities—Management selects and develops control activities that are designed and implemented to restrict technology access rights to authorized users commensurate with their job responsibilities and to protect the entity's assets from external threats.
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Establishes Relevant Technology Acquisition, Development, and Maintenance Process Control Activities—Management selects and develops control activities over the acquisition, development, and maintenance of technology and its infrastructure to achieve management's objectives.
• Determines Dependency between the Use of Technology in Business Processes and Technology General Controls
Establishes Relevant Technology Infrastructure Control Activities
Establishes Relevant Security Management Process Control Activities
Establishes Relevant Technology Acquisition, Development and Maintenance Process Control Activities
Management documents the underlying technology that supports control activities in risk and control matrices, flow charts, or narratives. Using this information, management can document the linkage between control activities and technology. Management should understand which aspects of technology (infrastructure, security, technology acquisition, development, and maintenance processes) are important to the continued, proper operation of the technology and any associated automated controls. Management also develops an understanding of how various applications and technologies interface with each other.
A global publicly traded information services organization, Signal Corp., recently acquired a privately held newspaper chain. During the due diligence process, Signal Corp. determined that the management of the newspaper chain did not have a good understanding of which applications were critical to the integrity and reliability of its financial information. To assess this linkage, the internal audit department of Signal Corp. performed a walkthrough of each of the newspaper chain's significant financial processes and documented in a process flow diagram all the applications that supported these processes. These included the automated controls and any controls that depended on system-generated reports.
The walkthrough covered each major class of transactions. The internal audit team asked the relevant personnel of the newspaper chain about all significant aspects of the process.
• Determines Dependency between the Use of Technology in Business Processes and Technology General Controls
• Establishes Relevant Technology Infrastructure Control Activities
• Establishes Relevant Security Management Process Control Activities
• Establishes Relevant Technology Acquisition, Development and Maintenance Process Control Activities
Management understands the use of end-user computing, which includes spreadsheets, that supports its financially significant processes and associated control activities. Management assesses the risks of a misstatement resulting from an error in one of these end-user computing applications. Based on the level of risk, management selects and develops general control activities over the technology covering the relevant processes over:
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Technology infrastructure
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Security management
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End-user computing development and maintenance
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Completeness and accuracy controls between the end-user computing system and other systems
For high-risk end-user computing applications, management considers converting to an IT-supported application.
Smythe & Smythe International recently evaluated the use of spreadsheets in its financial close process. In doing so, it identified that the spreadsheets supporting the calculation of LIFO (last-in, first-out) adjustment and the fair values of goodwill, intangible assets, and debt were of high risk, based on their susceptibility to error and significance to the financial statements.
Smythe & Smythe also classified the spreadsheets as high in complexity because they included the use of macros and multiple supporting spreadsheets to which cells and values were interlinked. The spreadsheets were used either as the basis for journal entries into the general ledger (LIFO reserve) or as financial statement disclosures (fair value of goodwill, intangible assets, and debt).
The company considered the security, maintenance, and update risks of the spreadsheets and then selected and developed the following control activities: fn 19
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Input Control—Input data is reconciled to source documentation to cover its completeness and accuracy.
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Access Control—File-level access to the spreadsheets on a central server is limited to approved users, and a password is required to access the LIFO reserve spreadsheet.
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Version Control—Standard naming conventions and directory structures are in place so only current and approved versions of the spreadsheets are used.
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Calculation Testing—When changes to formulas are made they are tested against a manual calculation for accuracy. All spreadsheet formulas are checked for accuracy at least once a year.
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Overall Analytics—Analytical business process reviews using pre-established thresholds based on operating income and working capital function as a detective control to find errors in any of the spreadsheets.
• Determines Dependency between the Use of Technology in Business Processes and Technology General Controls
• Establishes Relevant Technology Infrastructure Control Activities
• Establishes Relevant Security Management Process Control Activities
• Establishes Relevant Technology Acquisition, Development and Maintenance Process Control Activities
Management outsources certain aspects of its IT infrastructure to an outside service provider, which may or may not have a "report on controls at a service organization" following an appropriate local or international standard. If a report is available, management uses it to determine what financially significant IT processes are covered, whether appropriate controls are in place at the service organization, and what controls are required in its own organization to mitigate risks to external financial reporting to an acceptable level.
If an appropriate report does not exist, management uses internal resources (e.g., internal audit) to review the controls at the third party, verifying that the combination of the company's controls and those at the service organization mitigate risks to external financial reporting to an acceptable level.
E-Book Frontier, a retailer of electronic books, has outsourced its enterprise resource planning (ERP) application to a cloud-based service provider (CSP). To prepare for its initial public offering, the company began to develop and implement a system of internal control in support of its anticipated external financial reporting objectives. E-Book Frontier uses the ERP application to support its revenue, inventory, purchasing, and payables processes, so it supports a number of financial statement line items and their associated assertions.
To that end, the management of E-Book Frontier assessed the risks associated with the business processes outsourced to the ERP cloud service provider and determined a number of control activities and information requirements that needed to be addressed. E-Book Frontier management obtained a Statement on Standards for Attestation Engagements (SSAE) No. 16 (SOC 1) report on internal controls prepared by a third-party service auditor. As part of developing and deploying internal controls across the end-to-end business processes managed in part by the CSP, E-Book Frontier incorporated the review of the audit report as a control activity. In performing its review, management noted the following:
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The scope of the report included certain application controls and technology general controls that were evaluated for both design and operating effectiveness. The controls relating to the customized configuration for the organization were not addressed in the service auditor's report. Management evaluated the impacted business process and related financial reporting risks and selected and developed additional actions and control activities to address these risks.
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The tests of controls covered a time period that correlated with ten months of the company's fiscal year, resulting in a gap of the last two months. Based on management's analysis on the relevance and risk of the related controls, E-Book Frontier determined that corroborative inquiry with the CSP would be adequate for the gap period. To evaluate the continued operation of the CSP controls, management interviewed key CSP personnel to assess whether any changes in the controls or known failures had occurred since the date of the report.
Management reviewed the results of the tests of controls and the service auditor's opinion on the operating effectiveness of the controls to determine whether each control objective was achieved. Two exceptions were noted in the report, and management reviewed the additional information related to these that was provided by the CSP in the unaudited portion of the report. They concluded that one exception was not relevant to their organization. For the second exception, additional procedures were needed.
The second exception related to evidence of customer approval of program changes; management evaluated the sufficiency of E-Book Frontier's controls over approval of changes requested to be performed by the CSP. In addition, it requested a report of all changes for the past six months from the CSP and verified that the report of all changes was complete and accurate. It then compared the list of changes and noted no variances from its internal records.
Based on these additional procedures, management concluded that the exceptions did not result in a deficiency of their system of internal control.
Determines Dependency between the Use of Technology in Business Processes and Technology General Controls
Establishes Relevant Technology Infrastructure Control Activities
• Establishes Relevant Security Management Process Control Activities
Establishes Relevant Technology Acquisition, Development and Maintenance Process Control Activities
The applications, databases, operating systems, and networks that support financially significant processes are configured to support restricted access to financial applications and data consistent with the organization's policies and procedures. The configuration includes a means to authenticate users or systems and enforce restricted access, as well as key parameters, such as minimum password length and the aging of passwords.
Woodlawn Wireless Telecommunications, which has a number of applications critical to its financial reporting process, was recently cited for poor infrastructure security controls by its internal audit group. Specifically, the setup of key security parameters, such as password length and complexity, was not consistently applied across these applications, and in many cases they were below industry standards for good practices. To correct the situation, Woodlawn developed a four-step approach:
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Create a three-tier risk rating of the importance of an application and its data to the reliability of the financial-reporting process.
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Develop policies for the settings of key security parameters for all financially relevant technology in use at the company for each risk rating level.
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Assess the importance of each application and its associated infrastructure to the reliability of financial reporting and assign it a risk rating.
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Implement procedures to put in place and monitor compliance with the policies for each application consistent with its associated rating.
Determines Dependency between the Use of Technology in Business Processes and Technology General Controls
• Establishes Relevant Technology Infrastructure Control Activities
Establishes Relevant Security Management Process Control Activities
Establishes Relevant Technology Acquisition, Development and Maintenance Process Control Activities
Management selects and develops control activities so that transaction processing, whether batch or real-time, is complete, accurate, and valid. Processing is actively checked for problems, either through a manual review of system status and logs or by automated programs with alarms. Timely corrective action is taken when problems are identified. Critical financial data and programs are regularly backed up and procedures are in place to completely and accurately do a restore. The restoration process is regularly tested to help ensure the backup and restoration processes work properly.
In the data center of Sullivan Financial Services, the IT operations staff monitors the batch and real-time processing of applications (including all financially significant applications) for errors using automated software. The scheduling software on the mainframe application checks for various problems with batch jobs, including data errors and programs that don't complete properly or that run out of order. The operators are alerted to any of these issues and alert the appropriate business process owner based on standard documented procedures.
For applications that process in real time, software is also used to automatically monitor for errors, such as incomplete, inaccurate, or invalid record transfers between systems. When a possible error is detected, the software attempts to resend the record without error. If the error persists, an email alert is sent to an operator who corrects the error following standard documented procedures. Financial management is notified of any errors in a weekly report. The weekly report is reviewed to determine if any accounting record adjustments are required due to the system problems. The controller reviews and approves any changes. (Note: this could be considered a process-level control.)
Determines Dependency between the Use of Technology in Business Processes and Technology General Controls
Establishes Relevant Technology Infrastructure Control Activities
• Establishes Relevant Security Management Process Control Activities
Establishes Relevant Technology Acquisition, Development and Maintenance Process Control Activities
Financial management establishes policies that define appropriate access rights to be consistent with job functions, including segregation of duties, for financially significant applications and processes. New access requests or changes to access are reviewed against the policy by the functional owner of the IT resource (i.e., application, database, operating system, or network). The owner of the IT resource periodically recertifies access to ensure it is commensurate with policy. Problem reports, such as excessive improper logins, are regularly reviewed, and follow-up actions are taken when issues are identified.
The management team of a compensation and benefits consultancy reviews logical security controls to prevent unauthorized access to its financial reporting systems as follows:
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User Accounts—Formal user account setup and maintenance procedures are in place to request, establish, issue, suspend, change, and delete user accounts.
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Authentication Controls—Authentication standards establish minimum requirements for password length and a finite number of login attempts. Only unique user IDs are used to promote accountability and auditability.
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Privileged Accounts—The use of privileged ("super-user") accounts is limited to two-system and application administrators who are responsible for IT security management and therefore deemed appropriate. These accounts are monitored by management for improper use.
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Application Reviews—The configuration settings for who has access to data related to critical applications and systems are periodically reviewed. Any violations detected are reported to management and corrective action is taken.
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Security Reviews—Applications and systems generate security logs, enabling user activity to be monitored and security violations to be reported to management.
Determines Dependency between the Use of Technology in Business Processes and Technology General Controls
Establishes Relevant Technology Infrastructure Control Activities
Establishes Relevant Security Management Process Control Activities
• Establishes Relevant Technology Acquisition, Development and Maintenance Process Control Activities
Management considers many factors when selecting new packaged software, including functionality, application controls, security features, and data conversion requirements. Management utilizes competent internal resources or hires a third-party vendor to implement the software, following the organization's requirements.
Management follows a defined change-control process to implement system upgrades or patches. This includes assessing the nature of the upgrade or patch and whether it is appropriate to implement. If deemed appropriate, the patch or upgrade is system and user tested in an environment that mirrors production before being implemented. Key stakeholders, such as the functional users, finance, and IT, sign off on the change before it is implemented. Appropriate documentation is maintained to provide evidence that the changes have been made.
FabFun Toys is a manufacturer of plastic toys. For several years it has been using packaged general ledger software, and it has developed a set procedure for managing vendor announcements of software upgrades, which is as follows:
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Obtain a description of the change, the rationale for it, the impact on the company's security environment, and implications for user interfaces.
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Outline steps for a back-out plan should the upgrade not perform as expected.
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Develop a plan to test that the edit and validation rules work properly, desired system functions operate as expected and produce the desired results, undesired processing results are prevented, and existing technical capabilities, including control activities critical to external financial reporting, continue to work properly.
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Execute the tests and document the results.
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Maintain a change control log.
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Obtain approval from financial and operational management and end users of the test results prior to releasing the upgrade into production.
Determines Dependency between the Use of Technology in Business Processes and Technology General Controls
Establishes Relevant Technology Infrastructure Control Activities
Establishes Relevant Security Management Process Control Activities
• Establishes Relevant Technology Acquisition, Development and Maintenance Process Control Activities
Management follows a full system development life cycle (SDLC) covering problem fixes to major implementations. The SDLC covers a number of process steps and control activities, including the following:
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Initiation, Authorization, Tracking, and Analysis—Changes are captured in a change control or development specification. The change's progress is tracked and authorization to proceed is made by the appropriate stakeholders. The possible impact to internal controls over financial reporting is assessed, and changes are approved by relevant financial stakeholders.
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Design and Construction—Programming standards are followed during the design phase and procedures are put in place to provide version control.
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Testing and Quality Assurance—Testing is performed before going live to check if the change meets the specification and has not caused any unintended changes to the existing software. The amount and type of testing varies based on the nature of the change (size, complexity, etc.) and includes unit, system, integration, and user acceptance testing, as appropriate.
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Data Conversion—When applicable, data is converted completely, accurately, and validly from the previous technology.
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Program Implementation and Go-Live Authorization—The change is approved by the relevant stakeholders before going live, and only the approved version of the software is implemented.
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Documentation and Training—End-user and IT support documentation and training are created and updated as needed.
Summer Run Co. provides material-based solutions for electronic, acoustical, thermal, and coated metal applications. IT has recently decided to significantly modify inventory management software, which is considered a financially significant application. To do so, the company must rely on the only two developers on staff to develop, test, and migrate the software to production.
Because Summer Run does not have an automated code promotion utility to control versions and migrations to the production environment, the IT manager, James Robb, takes the following steps:
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Identifies and analyzes risk resulting from the required changes
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Assigns changes to developers so that each works on specific tasks only
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Assigns to the developer not working on a particular change the responsibility for testing the change and migration to production
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Reviews any significant changes
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Locks versions following user acceptance testing to prohibit further change prior to release
Mr. Robb also relies on these manual controls to manage the code version and migration:
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Creating a manual log listing the version of the code copied to the development environment, along with date and time, and manually tracking the migration to test and then to production.
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Separating the review of all version control procedures prior to moving the code to production from those performed by the individual responsible for the IT functions.
The multi-billion-dollar telecommunications organization, Brassen Systems, uses an SDLC to update and maintain more than 200 applications. The changes vary from large and complex development initiatives to simple report changes. Brassen seeks to match the degree and rigor of control activities to the range of risks of these changes.
The organization assigns the level of risk to one of four categories based on several factors, including the length, level of effort, possible risks to financial processing and control activities, and complexity of the change. Level 1 changes (the most risky) are required to go through twenty quality gates, or control points, before implementation, while Level 4 changes (the least risky) are required to go through only ten gates. All changes that may affect financial processing and control activities are required to be reviewed by someone in the finance department before being implemented.
fn 19 Note that not all these control activities are technology general controls only. The first and last bullets could be considered business process–level controls; however the entire list is included to illustrate a more complete consideration of spreadsheets.
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