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 this 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.
The reliability of technology within business processes, including automated controls, depends on the selection, development, and deployment of general control activities over technology, referred to from here on as technology general controls. fn 22 Technology general controls over the acquisition and development of technology are deployed to help ensure that automated controls work properly when first developed and implemented. Technology general controls also help information systems continue to function properly after they are implemented.
For instance, suppose an organization wants to deploy an automated matching and edit check control that examines data entered on-line. If something does not match, or is in the wrong format, immediate feedback is provided so that corrections can be made. Error messages indicate what is wrong with the data, and exception reports allow for subsequent follow-up. Technology general controls over system development help ensure that this automated control works properly when first designed and implemented (e.g., the edit checks follow the business logic defined by management, the checks match data with the right transaction or standing data file, any error message completely and accurately reflects what is wrong, and all exceptions are reported according to the organization's policies).
Once this automated control is properly implemented, technology general controls help ensure its continued operation (e.g., the right files are being used in the matching process and the files are complete and accurate). Also, proper security control activities limit access to the system to only those who need it, reducing the possibility of unauthorized edits to the files. Control activities over any changes to the technology help ensure that it continues to function as designed.
As with other entity functions, processes are put in place to select, develop, operate, and maintain an entity's technology. These processes may be limited to a few activities over the use of standard technology purchased from an external party (e.g., a spreadsheet application) or expanded to support both in-house and externally developed technology. Selected and developed control activities contribute to the mitigation of specific risks surrounding the use of technology processes.
Technology general controls include control activities over the technology infrastructure, security management, and technology acquisition, development, and maintenance. They apply to all technology—from information technology applications on a mainframe computer; to client/server, desktop, end-user computing, portable computer, and mobile device environments; to operational technology, such as plant control systems or manufacturing robotics. The extent and rigor of control activities will vary for each of these technologies depending on various factors, such as the complexity of the technology and risk of the underlying business process being supported. Similar to business transaction controls, technology general controls may include both manual and automated control activities.
Technology requires an infrastructure in which to operate, ranging from communication networks for linking technologies to each other and the rest of the entity, to the computing resources for applications to operate, to the electricity to power the technology. The technology infrastructure can be complex. It may be shared by different business units within the entity (e.g., a shared service center) or outsourced either to third-party service organizations or to location-independent technology services (e.g., cloud computing). These complexities present risks that need to be understood and addressed. Given the broad range of possible changes in the use of technology likely to continue into the future, the organization needs to track these changes and assess and respond to the new risks.
Control activities support the completeness, accuracy, and availability of technology processing. Whether the infrastructure is batch scheduling for a mainframe computer, real-time processing in a client/server environment, mobile wireless devices, or a sophisticated communications network, the technology is actively checked for problems and corrective action taken when needed. Maintaining technology often includes backup and recovery procedures, as well as disaster recovery plans, depending on the risks and consequences of a full or partial outage.
Security management includes sub-processes and control activities over who and what has access to an entity's technology, including who has the ability to execute transactions. They generally cover access rights at the data, operating system (system software), network, application, and physical layers. Security controls over access protects an entity from inappropriate access and unauthorized use of the system and supports segregation of duties. By preventing unauthorized use of and changes to the system, data and program integrity are protected from malicious intent (e.g., someone breaking into the technology to commit fraud, vandalism, or terrorism) or a simple error (e.g., a well-intentioned employee using a vacationing colleague's account to get work done, and executing a transaction erroneously or deleting a file because he or she is not properly trained in the work).
Security threats can come from both internal and external sources. The external threat is particularly important for entities that depend on telecommunications networks and the Internet. Technology users, customers, and malicious parties may be halfway around the world or down the hall. The many potential uses of technology and points of entry underscore the importance of security management. External threats have become prevalent in today's highly interconnected business environments, and continual effort is required to address these risks.
Internal threats may come from former or disgruntled employees who pose unique risks because they may be both motivated to work against the entity and better equipped to succeed in carrying out a malicious act because they have greater access and knowledge of the entity's security management systems and processes.
User access to technology is generally controlled through authentication control activities where a unique user identification or token is authenticated against an approved list. Technology general controls are designed to allow only authorized users on an approved list. These control activities generally employ a policy of restricting authorized users to the applications or functions commensurate with their job responsibilities and supporting an appropriate segregation of duties. Control activities are used to check requests for access against the approved list. Other control activities are in place to update access when employees change job functions or leave the entity. A periodic review of access rights against the policy is often used to check if access remains appropriate. Access also needs to be controlled when different technology elements are connected to each other.
Technology general controls support the acquisition, development, and maintenance of technology. For example, a technology development methodology fn 23 provides a structure for system design and implementation, outlining specific phases, documentation requirements, approvals, and checkpoints with controls over the acquisition, development, and maintenance of technology. The methodology provides appropriate controls over changes to technology, which may involve requiring authorization of change requests, verifying the entity's legal right to use the technology in the manner in which it is being employed, reviewing the changes, approvals, and testing results, and implementing protocols to determine whether changes are made properly.
In some companies the development methodology covers the continuum from large development projects to the smallest changes. In other companies there is one distinct process for developing new technology and a separate process for change management. In either case, a change management process will be in place to track changes from initiation to final disposition. Changes may arise as a result of a problem in the technology that needs to be fixed or a request from the user community.
The technology general controls included in a development methodology will vary depending on the risks of the technology initiative. A large or complex development initiative will generally have greater risks than a small or simple initiative. The extent and rigor of the controls over the initiative should be sized accordingly.
One alternative to in-house development is the use of packaged software. Technology vendors provide flexible, integrated systems allowing customization through the use of built-in options. Many technology development methodologies address the acquisition of vendor packages as a development alternative and include the necessary steps to provide control over their selection and implementation. Once selected and implemented, technology general controls outlined above would also apply to the ongoing development and maintenance of technology,
Another alternative is outsourcing. While in principle the same considerations apply whether controls are performed internally or by an outsourced service provider, outsourcing presents unique risks and often requires selecting and developing additional controls over the completeness, accuracy, and validity of information submitted to and received from the outsourced service provider.
fn 22 Terminology typically used to describe these controls includes "general computer controls," "general controls," or "information technology controls." The term "technology general controls" is used here to refer to "general control activities over technology."
fn 23 There are many names for this process. One common name is "systems development life cycle" (SDLC).
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