When
SOX projects were initiated in 2004, the IT Audit profession was looked
upon as the background required to establish and test the controls.
IT Auditors performing IT General Controls Audits traditional take
the “issue oriented” approach. The
issue oriented approach involved identifying specific issues which relate
to potential system vulnerabilities.
For instance they perform extracts of system security parameters to
identify settings which are set to values which increase the risk of
unauthorized actions. For
instance, checking the primary domain account policies/password policies
to ensure that a Minimum Password Length is set to less than 6 would be a
typical “gotch-ya” type of audit issue.
This
IT Audit approach is not the approach taken in an IT General Controls SOX
Project. Sarbanes Oxley is
the assessment of controls over financial reporting. It assumes that
controls would provide assurance of accurate financial reporting. SOX
does not validate the accuracy of financial statements.
This is the objective of the Financial Statement Audit.
In
regards to security parameter settings, SOX Control Activities need to be
designed to provide assurance that the security parameters would always be
set correctly. It is not a
one time validation of the parameter which would be the approach of a
traditional IT Audit.
The
control objective for the example discussed previously would be
“Logon
Security parameters are defined and are continuously monitored to ensure
they are to set to prevent an unauthorized takeover of IDs”
The
control activities would include the following:
-
OS Configuration checklist are established which specify key security
related system configuration requirements
-
OS Configuration checklist are completed prior to the rollout of new
production domains
-
Audit Trails are enables and a review process occurs which would detect
changes to security parameters
-
Annual validation to ensure compliance with configuration checklists
occurs for sample number of servers
When
designing the SOX tests for all of these control activities, none of the
tests would consist of checking the value of the security parameter which
would be the case for a traditional IT General controls audit.
Even the test for the annual validation to ensure compliance with
configuration checklists would only assess whether the validation process
occurred but not validate the results of the review.
In
conclusion, SOX Controls and testing focuses on the establishing control
activities to ensure a desired value where IT Audits would check the
value. SOX requires IT
Auditors to reorient their approach when establishing and testing SOX
controls