© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. Information Technology Controls in the Audit Baltimore Chapter - Association of Government Accountants November 18, 2015
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. Considering IT Risks 2 Reassess and Respond Overall Understanding Understand entity and its environment Understand overall risks at the financial statement level ELCs Design and Implementation of entity level controls Significant accounts, disclosures, and assertions Identify significant accounts, disclosures, and assertions that present a reasonable possibility of material misstatement WCGWs, HLCs and PLCs Identify WCGWs and identify/test the relevant HLCs, then PLCs GITCs Identify and test GITCs that support relevant application controls
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. Entity-Level Controls – Deeper Dive – Debrief Control Environment Risk Assessment Information and Communication Monitoring Activities Control Activities Entity-Level Controls (ELCs) Higher-Level Controls (HLCs) Process-Level Controls (PLCs) Controls that do not specifically relate to an assertion (indirect) Controls that specifically relate to an assertion (direct) GITCs 13
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. Overall approach Apply top-down, risk-based approach −Indicators of risks include major changes in an IT environment −Define risks with the appropriate degree of specificity and calibrate response accordingly −Consider the overall IT environment (applications, databases, operating systems, networks, etc.) −IT controls may impact entity-level, higher- level, and process-level controls Continual reassessment of risks and recalibration of response is imperative Use professional standards 4
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. Objective of a Walkthrough – AS 5.34 Why do we perform walkthroughs? 5 Understand flow of transactions Verify points where misstatements could arise Identify controls to address misstatements Identify controls to prevent/ detect misappropriation of assets fraud
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. WCGWs and Controls 66 Don’t forget about HLCs (includes IT) Be specific when documenting WCGWs (includes IT) Identify controls that address WCGWs (includes IT) Testing automated vs. manual ≈ more effective and efficient Identify all WCGWs in the process Check control descriptions Trace flow – not controls!
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. IT Diagram 7 ApplicationDatabase Operating System NetworkLocation
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. Understanding Processes and Controls Conducted by Service Organization 8 During walkthrough at user entity, inquire about service organization activity that is relevant to the user entity’s financial statements and ICOFR Identify WCGWs and controls at user entity and, if applicable, expected control objectives at service organization Consider ROMM at user entity Consider availability of evidence at user entity If needed information is not at the user entity, Obtain SOC 1 Type 2 Report; Visit service organization; and/or Request another auditor perform procedures Examples of outsourced services: IT (e.g., software development, data processing, data backup) and accounting/finance/business processing (e.g., payroll, tax, benefit claims processing, transfer agent, fund administration, custody, and record keeping). Include in Walkthrough at User Entity Availability of Evidence at User Entity Type 2 Report / Visit/Request Procedures
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. Review of SOC Reports 9 Expected control objectives User entity FS assertions Control objectives in SOC report Type of tests performed by service auditor Exceptions in report User auditor response WCGWs End-user controls
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. Cloud Computing 10 “Cloud computing is a model for enabling ubiquitous, convenient, on-demand network access to a shared pool of configurable computing resources (e.g., networks, servers, storage, applications, and services) that can be rapidly provisioned and released with minimal management effort or service provider interaction.” NIST SP Subset of service organizations −Third party control of hardware, software and processes but in non ‑ traditional manner, for example: On-demand payroll system provided by a cloud provider Allows for access to functionality of system over Internet but does not include details such as location of the data center or other specifics about the technology infrastructure Risks depend on the nature of the services provided
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. How Do We Test IT Controls? 11
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. Information Produced by the Entity (IPE) 12 IPE must be evaluated to determine whether it is sufficiently reliable prior to being used in our risk assessment or audit procedures. We consider: −Precision and detail −Completeness −Accuracy If automated or manual controls over the C&A of IPE do not exist, or are not effective, we cannot use the IPE as the basis of the related process-level control. For IPE that is used in a substantive procedure, we can test controls over the C&A or we can perform substantive tests (often in combination with the substantive audit procedure itself).
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. A/R Allowance Review – IPE Relevant Data Elements 13 Relevant Data Elements: Invoice date Invoiced amounts Invoice by customer number Aging of the amounts Assessment of high and low risk customers Sales Process System configuration of A/R aging report
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. IPE Reminders 14 Understand and Properly Identify IPE −IPE includes general ledger reports such as trial balances, as well as data external to the financial systems. −All relevant data elements should be identified. −We should understand how each data element was initiated, processed, and ultimately reported as IPE. Apply Appropriate Testing Method for C&A −C&A cannot be substantively tested if it is being used as the basis for a control Consider End-user Computing −If end-user reports are used in the financial reporting process, they must be tested −End-user reports produced by activities that are not subject to the entity’s GITCs are considered to be prepared manually.
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. Evaluating Design and Implementation 15 Consider the following when designing procedures to evaluate D&I The objective of the control How the control is performed and documented The nature of the control Whether the control addresses a fraud risk How frequently the control is applied The knowledge, experience and skills of the person performing the control – for manual controls or manual controls with an automated component only The related IT application, if any The relevant general IT controls Whether the control addresses user considerations for a service organization. Whether the control is designed at the appropriate level of precision
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. Tests of Operating Effectiveness (TOEs) for Automated Controls 16 Operating effectiveness for an automated control includes the following elements: −How the controls were applied at relevant times during the period under audit −The consistency with which they were applied, −By whom or by what means they were applied, and −Sufficient understanding of important attributes. Consider the impact of other types of controls, particularly GITCs Consider the persuasiveness of the audit evidence needed Consider nature, timing and extent of tests of controls TOEs are required in an Integrated Audit!
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. Evaluating Control Exceptions 17 What is a deficiency? An internal control deficiency exists when a control does not allow management to prevent, or detect and correct misstatements on a timely basis. A deficiency can be in design or in operation, such as: −A control is missing −A control is not properly designed to meet the control objective −A properly designed control does not operate as designed, or −When the person performing the control does not possess the necessary authority or competence to perform the control effectively
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. 18 Severity of the Deficiency – Magnitude & Likelihood Severity MagnitudeLikelihood
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. GITC-Related Findings 19 Failure to appropriately evaluate the impact and/or severity of control deficiencies Failure to test appropriate GITCs or inappropriate reliance on application controls when deficiencies were identified in supporting GITCs Failure to evaluate GITC deficiencies with other control deficiencies Failure to consider the impact of ineffective GITCs on IPE and other relevant application controls
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. Segregation of Duties (SoD) 20 System access controls are the configuration controls to manage SoD in an automated environment System access controls are the configuration controls to manage SoD in an automated environment No single individual has control over two or more conflicting phases of a transaction or operation SoD is tested as a part of application controls and GITCs Assigning different people responsibility for authorizing transactions, recording transactions, and maintaining custody of assets is intended to reduce the opportunities for any one person to be in a position to both perpetrate and conceal errors or fraud in the normal course of his or her duties. We may identify SoD as a control activity in our walkthroughs
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. Linking Application Controls to GITCs 21 Do we understand the link between the automated controls and the GITCs we plan to test? Is our test work over the GITCs appropriate? We first link specific application controls to the relevant GITCs that support their ongoing effectiveness The only GITCs to be considered for testing are those that support the effective operation of application controls of interest Use walkthrough to help with the linking. Involve IRM specialists. Identify GITCs that cover all layers of the application control (network, OS, database, application), and support the actual operation of the app control.
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. Linking Application Controls to GITCs – Impact of GITC Deficiencies 22 If we identify a deficiency in a GITC, have we evaluated the impact on each related application control? We test each relevant GITC and conclude on its operating effectiveness If we find a deficiency in a GITC, we obtain an understanding of the impact on relevant application controls Linking provides a clear understanding of a GITC deficiency’s impact given its link back to affected application controls We first link specific application controls to the relevant GITCs that support their ongoing effectiveness
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. System Implementation Risks and Associated GITCs 23 System changes introduce IT risks in the year of change Certain GITCs are designed to mitigate these risks: −Program development GITCs address: Development or acquisition of new programs or infrastructure Major changes to existing IS −Program change GITCs address: Limiting the number of personnel who have access to migrate changes to the production environment to help control the process −Access to programs and data GITCs address: Security roles and segregation of duties over system testing and migrating changes to the production environment
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. Considerations Regarding Nature, Timing and Extent of Control Tests 24 FactorConsiderations Nature of Testing In the order of from when more audit evidence is needed to when less audit evidence is needed: Reperformance or recalculation Observation of the entity’s operations Inspection of relevant documentation Inquiries (in combination with other procedures) Timing of Testing When more persuasive audit evidence is needed: Move timing of procedure closer to “as of” date Test controls over a greater period of time throughout the year Perform tests at unannounced or unpredictable times Extent of Testing The extent of evidence may be increased by: Select larger sample sizes Increase the number of performances of the audit procedure Increase the number of selected operations of the control to be tested
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. Identifying and Evaluating IT Control Deficiencies – Debrief 25 The audit is iterative, by nature −General IT control deficiencies have an impact on the testing of application controls Discuss exceptions with the process/control owners for confirmation that a deficiency exists (AU-C-265.A1-A2) Assess severity and communicate deficiencies as they’re identified Avoid heavy reliance on manual controls as compensating controls when communicating deficiencies to management Consider IRM involvement when determining the impact of GITC deficiencies on relevant application controls and IPE
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. Reminders for Aggregating Deficiencies 26 Conclusions are judgment based; assess qualitative and quantitative data. Inquiry alone is insufficient (look for disconfirming evidence) Review work performed by IA and the service org report(s) to determine if there are deficiencies you need to consider. Communicate deficiencies to management on a timely basis. Aggregate not only process level controls, but also GITCs and ELCs. Participate in risk and audit quality assessment (RAQA) Completion meeting You are NOT done after evaluating deficiencies. Evaluate the need to modify risk assessment and, thus, the nature, timing, and extent of substantive audit procedures Document. Document. Document!
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. What Questions Do You Have? 27
© 2015 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. Printed in the U.S.A. FOR INTERNAL USE ONLY. For Further Information 28 For Further Information Johnny E. Ramsey, CPA, CGFM, CGMA, CISA Senior Manager, KPMG LLP