Auditing the Infrastructure and Operations – 2 Computer Audit Basics
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Auditing the Infrastructure and Operations – 2 Computer Audit Basics
Computer Audit Basics – 2 Auditing the Infrastructure and Operations Ross Palmer MIIA; FIIA; CISA; MBCS Computer Audit Manager, Hogg Robinson plc [email protected] 1. A Definition of Risk The potential that a given threat will exploit vulnerabilities of an asset or group of assets to cause loss or damage to those assets. Guidelines for the Management of IT Security (International Standards Organisation) Something bad WILL happen Something good WON’T happen 8. A Definition of Risk Management The co-ordinated activities that direct and control an organisation with regard to risk ISO17799 - Information Security Management Systems — Specification • Risk Identification • Prioritisation (Impact x Likelihood) • Treatment of inherent risk • Treatment of residual risk 9. Information Processing Objectives 10. Definitions: Confidentiality Prevention of disclosure of sensitive information resources to unauthorised individuals or organisations Failure to achieve this may result in: Loss of competitive advantage Loss of business Fraud (unauthorised diversion of goods or funds) Damage to customer or shareholder confidence, image and/or reputation Breach of statutory, regulatory or contractual obligations Damaging effect on staff motivation or morale 11. Definitions: Integrity Prevention of accidental corruption, deliberate unauthorised manipulation, or inaccurate entry and/or processing of business information resources Failure to achieve this may result in: All of the foregoing for “Confidentiality” Incorrect or inappropriate management decisions Disruption of business activity 12. Definitions: Availability Prevention of business information stored in or processed by systems becoming lost or unavailable for an extended period Failure to achieve this may result in: Difficulty in recovering from backlogs of processing Additional costs Loss of business Damage to customer or shareholder confidence, image and/or reputation Breach of statutory, regulatory or contractual obligations 13. Definitions: Effectiveness Maximising the conformance of outputs from an activity to a specification or need (Meaning: “Doing the right things”) Failure to achieve this may result in: Processes not in accordance with business requirements Breach of contract or SLA Legal proceedings 14. Definitions: Efficiency Optimising the ratio of inputs to outputs for an activity. (Meaning: “Doing things right”) Failure to achieve this may result in: Wasted processing resources Loss of profits Difficult systems maintenance 15. Definitions: Economy Minimising the cost of the inputs to an activity or the resources needed to deliver a service (Meaning: “Doing things cheap”) Failure to achieve this may result in: Additional, unnecessary costs Imprudent management Loss of business Enforced cost-cutting (redundancies; skills loss; etc.) 16. Definitions: Compliance Avoidance of breaches of any criminal and civil law, statutory, regulatory or contractual obligations and of any security requirements. Failure to achieve this may result in: Civil or criminal lawsuits (corporate/individual) Invocation of contractual penalties Inability of the Board to implement corporate governance protocols 18. A Hierarchy of Internal Control Internal controls can be categorised into the following 1. Preventive Controls – (“before the fact”) hierarchy: The most important control type since, if 100% effective (which it never is), none of the others would be necessary – physical barriers, passwords Healthcare analogy: Prophylactics (e.g. immunisation programmes) 2. Detective Controls – (“after the fact”) If a preventive mechanism fails, this is the first type of control necessary to identify this fact prior to correction – audit trails, monitoring Healthcare analogy: Diagnoses (e.g. check-ups; ECGs) 3. Corrective Controls – (“before or after the fact”) This type of control is designed to correct a problem – change control, overrides Healthcare analogy: Surgery (e.g. heart by-pass; tumour excision) 4. Deterrent Controls – (“instead of the fact”) Designed to advise against certain forms of action – security policy, logon warning Healthcare analogy: Government Health Warnings (e.g. tobacco; 20. alcohol) Typical IT Organisational Infrastructure Audit Committee Board Internal Audit Marketing Projects Data Mgt Sales IT Directorate Finance Quality Assurance Operations Security Admin Media Library Job Control 21. Human Resources Database Admin Control Group Network Mgt Let’s take it from the top …. You can’t operate in a vacuum. If nobody at the top of the organisational infrastructure is going to take control seriously, then it is highly likely that others will not do so. At risk of teaching granny to suck eggs, here are some top-level essentials to consider: 1. 2. 3. 4. 5. 6. 7. Strategy Risk Appetite Planning (short/long term) Monitoring & Control Organisational Structure Policies & Standards Classification of Information 23. High-Level Essentials (1) Strategy 1. 2. 3. 4. Does the IT Department have formalised objectives? • Obtain notes of departmental planning meetings • Get inside IT Directorate’s world and regular forums (“fora”?) Do they map on to the needs of the organisation? Caveat • Obtain minutes of Board Meetings Do not secondguess or • Review public-facing websites question Who has determined/approved them? business or IT • Review attendance and actions arising from minutes strategies Have they been prioritised on the basis of risk? • Ask for and inspect the risk register • Review regularity of risk register maintenance 24. High-Level Essentials (2) Risk Appetite 1. 2. 3. Is there a rolling programme of risk management within the IT Dept? • Review risk register/reports for appropriate participation • Look for a business focus for risks Is there a defined risk assessment model? • Review adequacy of identification (e.g. brainstorming; right people) • Review process of risk scoring (e.g. as a product of business impact and likelihood) and prioritisation Are “high” risks treated appropriately? • Look for evidence of appropriate treatment (if any) – see next slide Caveat Do not second-guess or question the risks identified or their 25. scoring STRATEGIES FOR TREATING RISKS (TRAP) Terminate the activity being undertaken which generates risk Terminate Reduce Pass on Accept Reduce the risk by introducing new or enhancing existing controls Accept the risk where existing controls are felt to be adequate Pass on the risk to another party – usually through insurance or redefining responsibility 26. High-Level Essentials (3) Planning 1. Has an IT Planning/Steering Committee been established? • 2. Look for evidence of formal establishment and duties, e.g. charter, minutes Does it comprise appropriate membership? Caveat • From documentation, look for representation from business Do not management, IT and the user base second• The chairperson should be suitably appointed from the Board or guess or senior management (i.e. who understands the business and question technology needs) 3. Are long and short term plans maintained? plans • Review output from the planning committee, looking for “hard” (1 – 3 months) and “soft” (3 months – 2 years) plans/reviews/approvals for IT • Look for planning reviews as high on a regular meeting agenda • Plans should reflect budgets,27. skill pools, “the market place” High-Level Essentials (4) Monitoring & Control Definitions (from the Institute of Internal Auditors): Monitoring: Encompasses supervising, observing and testing activities and appropriately reporting to responsible individuals. Monitoring provides an ongoing verification of progress toward the achievement of objectives and goals. 1. 2. Control: Any action taken by management, the board, and other parties to enhance risk management and increase the likelihood that established objectives and goals will be achieved. Management plans, organises, and directs the performance of sufficient actions to provide reasonable assurance that objectives and goals will be achieved Are the activities of the IT Dept monitored against plans and objectives? • Obtain evidence of SLAs, processing schedules, tolerances, quality standards, etc • Establish the means by which such targets are monitored Are control measures implemented to restore deviations from plans? • Review Planning/Steering Committee minutes for change requirements • Review related change records for completeness 28. High-Level Essentials (5) Organisational Infrastructure 1. Does the IT Department have a formalised structure? • 2. 3. Obtain and review up-to-date organisation charts and job descriptions Does the IT Dept organisation provide for commitment and capability? • Look for appointments to the Board (e.g. IT Director) or other “clout” • Look for chain of reporting throughout the IT Dept to this position Have IT Dept duties been effectively segregated? Duties – for 2 definitions: • ReviewSegregation organisationofstructure obvious compromises A method for reducing the risk of accidental or deliberate system misuse. Separating the management or execution of certain duties or areas of responsibility, in order to reduce opportunities for unauthorised modification or misuse of information or services, should be considered. (ISO17799) A basic control that prevents or detects errors and irregularities by assigning responsibility for initiating transactions, recording transactions and custody of assets to separate individuals. Commonly used in large IT organizations so that no single person is in a position to introduce fraudulent or malicious code without detection. (ISACA) 30. Segregation of Duties (per CISA Manual) 31. High-Level Essentials (6) Policies & Standards 1. Does the organisation have an IT security policy in place? • 2. Does this policy address key security issues? • 3. Review the processes for creation, approval, review, maintenance, distribution and understanding Obtain an up-to-date copy and look for content governing: IT Systems (incl. Internet/Email) access & security incidents Data Protection Unauthorised software (installation, copyright) Care and (mis)use of equipment Are technology standards formally defined and available? • Establish and review configuration standards, operating instructions, etc. 32. High-Level Essentials (7) Classification of Information 1. 2. Does the enterprise apply a system of information classification? • Look for a documented standard for information classification • Establish its availability to staff and how it is communicated Does it address criticality, sensitivity and availability of data? • 3. Ensure the classification scheme takes account of: Business impact of a loss of confidentiality, integrity or availability Sensitivity of information processed, stored or transmitted (electronic and paper) Identified risks particular to the installation Do all classified systems and data have an owner? • Seek documentation (e.g. inventory) specifying data/data type ownership, classification approval, data access criteria, last review date 35. THE OPERATIONS ENVIRONMENT - BASIC REQUIREMENTS What does an operational environment need to make it function? : Achievement of realistic service targets Run in accordance with sound and sensible disciplines – security, safety, efficiency, good humour, etc. Ability to identify incidents ones) Ability to resolve or escalate incidents Ability to respond to changes (but not necessarily adverse 37. THE OPERATIONS ENVIRONMENT - SESSION FEEDBACK The following were the first 5 spontaneous responses from the September 7th session audience (good effort) to the question “What does an Operations department do?”: Schedule jobs Process jobs Data maintenance System maintenance Back-ups 37. THE OPERATIONS ENVIRONMENT 13 CRITICAL FACTORS TO CONSIDER People (and contractors) Media Handling Operating Procedures Back-ups and Restoration Contingency Planning Change Management Operator Logs Problem Management System Maintenance Security Network Management Outsourcing Operations Corporate Governance 38. THE OPERATIONS ENVIRONMENT 1. PEOPLE (and contractors) Personnel who run the computer installation should: 1. have the necessary skills to run the operations competently 2. be in sufficient numbers to provide absentee cover, shift patterns and segregation of essential tasks 3. have their responsibilities clearly defined in job descriptions 4. be provided with adequate training to maintain knowledge 5. be screened for suitability and should sign confidentiality agreements 6. have the ability and commitment to work under normal, peak, exceptional and emergency conditions 7. have their motivation and morale maintained 39. THE OPERATIONS ENVIRONMENT 2. OPERATING PROCEDURES 50-year employment “a British company” 1945 - 2000 by Operations functionsprofile and of staff should be supported 100% documented procedures that overcome “Organisational 90% Amnesia” “ORGANISATIONAL AMNESIA” arises from: 80% (Percentage of managers with at least 6-year tenure) 70%Recall “ORGANISATIONAL MEMORY” is: of memory selectively (through “defensive reasoning”) 60%Resignations when employees leave to join other organisations The institution-specific knowledge accrued from experience 50%Redundancies 40% An intellectual asset unique to each organisation Retirement of key individuals 30% The most important constituent of any institution’s durability Rotation of staff 20% 10% So, companies cannot benefit from tried and tested experiences, resulting (from Arnold in: Kransdorff, Business Historian) • reinventing the1970 wheel 1945 1950 1955 1960 1965 1975 1980 1985 1990 1995 2000 • repeating mistakes (there go those “R”s again) 41. THE OPERATIONS ENVIRONMENT 2. OPERATING PROCEDURES Operations functions and staff should be supported by documented procedures that overcome “Organisational 1. are comprehensive, available (butand protected, Amnesia” that: especially for use of system utilities), approved, periodically reviewed, clear and unambiguous 2. specify start-up, shut-down, back-up, restart and recovery routines 3. are subject to formal change/version control 4. specify scheduling requirements (e.g. earliest job start and latest job completion times) and interdependencies with other systems 5. clearly explain how to deal with specific error messages or other exceptional conditions (including third-party supplier software) 6. provide support contacts for unexpected difficulties 7. include mandatory safety factors 42. THE OPERATIONS ENVIRONMENT 3. MEDIA HANDLING (1) Damage to/loss of information assets, unauthorised access or business interruptions can be minimised through: 1. Media library and information storage/handling procedures, responsibilities and access controls specified, formalised and allocated 2. Media library inventory and discrepancy reporting/resolution 3. Minimising/encrypting external labelling … 4. … but labelling with the correct security classification … 5. … and standardised retention periods with storage criteria (e.g. write permit devices) … 6. … and data ownership (not custody) 7. Provision of secure and environmentally sound physical storage 44. THE OPERATIONS ENVIRONMENT 3. MEDIA HANDLING (2) 8. Continued data integrity mechanisms (e.g. version control, output validation) to minimise fraud and humna error 9. Secure, segregated access to system documentation (e.g. system descriptions, operating procedures, run authorisations, data entities) 10. Restricted printer destinations 11. Minimised copies of sensitive output (“need to know” basis) 12. Secure disposal of redundant media: Up to 10x over-writing of electronic media Physical destruction (very therapeutic !) of hard drives, CDs, etc. Secure shredding/incineration of sensitive printout Secure contracts for media disposal 45. THE OPERATIONS ENVIRONMENT 4. BACK-UPS AND RESTORATION (1) The ability to recover from data loss or corruption can be optimised by: 1. Formalisation of a media (data and software) back-up and restoration strategy. The strategy must anticipate failure at any point in the processing cycle. 2. Taking software back-up copies (considering intellectual property rights and escrow agreements, where appropriate) together with updates, upgrades, patches, service packs, documentation, etc. 3. Transporting and storing software back-ups securely and appropriately (e.g. physically secure in an off-site fire-safe, at a location where fast retrieval can be achieved). 4. Taking critical data back-ups regularly (possibly more than once a day) on a cyclical basis agreed by the business data owner (as opposed to custodian) 46. THE OPERATIONS ENVIRONMENT 4. BACK-UPS AND RESTORATION (2) Typical data back-up cycle: 1. Create and label daily backup media (e.g. DLT cartridge (<35Gb ); Diskette (<1.4Mb), make incremental copies of changed data and transfer securely to offsite store O DAY-1 DAY-1 F D B/UP DAY-1 B/UP DATA F A S T DAY-2 DAY-2 DAY-2 B/UP B/UP I A DATA T DAY-3 DAY-3 E DAY-3 C B/UP B/UP DATA E DAY-4 S N DAY-4 DAY-4 B/UP B/UP T T DATA O R DAY-5 DAY-5 DAY-5 R B/UP E B/UP DATA E 47. THE OPERATIONS ENVIRONMENT 4. BACK-UPS AND RESTORATION (2) Typical data back-up cycle: 2. Create and label weekly backup media and make full copies of data and transfer securely to offsite store D A T A WEEK-1 DATA WK-1 B/UP WK-1 B/UP DAY-1 B/UP DAY-2 B/UP DAY-3 B/UP C E N T R E DAY-4 B/UP DAY-5 B/UP 48. O F F S I T E S T O R E THE OPERATIONS ENVIRONMENT 4. BACK-UPS AND RESTORATION (2) Typical data back-up cycle: 2. Create and label weekly backup media and make full copies of data and transfer securely to offsite store D A T A C E N T R E WEEK-1 DATA WEEK-2 DATA WEEK-3 DATA WEEK-4 DATA WEEK-5 DATA WK-5 B/UP WK-1 B/UP DAY-1 B/UP WK-2 B/UP DAY-2 B/UP WK-3 B/UP DAY-3 B/UP WK-4 B/UP DAY-4 B/UP WK-5 B/UP 49. DAY-5 B/UP O F F S I T E S T O R E THE OPERATIONS ENVIRONMENT 4. BACK-UPS AND RESTORATION (3) 6. Backing up masterfiles, databases, transaction files, parameter settings and system documentation on-site and off-site 7. Formalisation of off-site storage facilities, i.e. receipt procedure, log of media locations, write-permit devices, dual check of tapes to be re-used 8. Suitable data archive storage conditions, e.g. humidity, fire/flood hazards 9. Periodic sample testing of data back-ups for “readability” and observance of media manufacturer’s “shelf life” recommendations 10. A clear and protected window of opportunity for data back-ups to complete 11. The use of checkpoints during processing, to minimise the need for complete re-starts or restorations 12. Segregating the security privilege permitting recovery from other data processing/programming tasks 50. 13. Awareness of statutory, etc. requirements, e.g. DPA; Inland Revenue THE OPERATIONS ENVIRONMENT 5. CONTINGENCY PLANNING Interruptions to business activities can be minimised and critical business processes protected from major failures or disasters by: 1. Formalising the requirement for a business continuity facility within the organisation driven by the business (not by IT) 2. Involvement of Operations personnel in the Business Impact Analysis 3. Location of the Business Continuity Plan (Operations), Disaster Recovery and Crisis Management Procedures in secure, on-site and off-site locations 4. Operations representation in the organisation’s Crisis Response Team 5. Operations involvement in testing, feedback and review of plans 51. THE OPERATIONS ENVIRONMENT 6. CHANGE MANAGEMENT Unauthorised or erroneous changes to software are minimised in the Operations environment by: 1. Organisational change controls being formalised, approved and maintained 2. Ensuring only the current, tested, approved version handed over from developers is promoted to live and only by authorised personnel 3. Operations Dept. being involved in change management and testing, where appropriate, e.g. capacity planning, volume testing, performance monitoring 4. Controls over emergency changes, e.g. emergency passwords controlled by the shift manager and change formalisation at the earliest opportunity 5. Strong controls, e.g. dual control, over use of powerful utilities for one-time record changes 6. Regular back-ups of program libraries and recoverability testing 52. THE OPERATIONS ENVIRONMENT 7. PROBLEM MANAGEMENT The effects of problems and security incidents are minimised through: 1. A standard procedure for reporting and logging software malfunctions 2. A reliable means of communicating incidents, symptoms, causes and resolutions to the support personnel 3. Clear and concise documentation to identify known (expected) program errors, e.g. error codes, validation exception reports, job “abends” (abnormal endings) 4. Up to date and step-by-step instructions to rectify expected errors, including contact numbers of technical support (and software vendors, if appropriate) for further information 5. Resolving and learning (“post facto” analysis) from incidents 6. Effective training for Operations work and concepts 53. THE OPERATIONS ENVIRONMENT 8. OPERATOR LOGS The integrity and availability of information processing services are maintained through: 1. Operating procedures clearly identifying the logs that need to be kept 2. Internal review of operator logs and satisfactory resolution of faults, ensuring that security has not been compromised (this will require definition and understanding by Operations management) 3. All shift changes, carry-over operations and special requirements being recorded 4. Archiving of operator logs (manually and electronically) such that they can be identified and retrieved when required 55. THE OPERATIONS ENVIRONMENT 9. SYSTEM MAINTENANCE Continued availability and integrity of systems can be 1. Formalising enhanced by: a cyclical schedule of maintenance tasks with accountability for their performance 2. Carrying out regular approved and specified back-ups (described earlier) 3. Optimising system performance through secure use of appropriate utilities, e.g. off-line file compression; disk defragmentation 4. Following approved equipment manufacturer’s prescribed maintenance regime, e.g. regular cleaning of drive mechanisms, air filters and printers 5. Effective service warranties and supplier contracts 6. Realistic Service Level Agreements (SLAs)/contracts 7. Maintaining a record of percentage “up-time” against SLA 8. Fostering a sense of teamwork with other departments, including 56. socially THE OPERATIONS ENVIRONMENT 10. NETWORK MANAGEMENT Integrity, security and availability of networks and applications can be enhanced through: 1. Organisational segregation of Network Management responsibility from Operations (where possible) 2. Additional dual-control of Network Management and Operations (where not possible) – alternative preventive mechanism against conspiracy, minimising the need for trust 3. Activity monitoring (where not possible) - alternative detective mechanism against conspiracy 4. On-screen warnings about unauthorised network access, including by Operations - alternative deterrent mechanism 58. THE OPERATIONS ENVIRONMENT 11. OUTSOURCING OPERATIONS When the responsibility for information processing has been outsourced to another organisation, security of information can be enhanced by: 1. Ensuring that information resources processed are only in the custody of the third party and that data ownership is clear and formalised 2. Establishing contracts between both organisations specifying responsibility for: Performance criteria System availability Security of information – logical/physical controls Integrity testing Penalty clauses/defaults Rights to audit 59. THE OPERATIONS ENVIRONMENT 12. SECURITY Security within the Operations environment can be optimised by: to systems and data 1. Enforcing logical access restrictions Segregation of access, e.g. between media library and job control Authorised levels of security profile, changes and monitoring 2. Enforcing physical access restrictions to systems and data Perimeter/internal security, e.g. security guards; card access/time zones 3. Enforcing environmental security measures Environmental controls – humidity, fire/flood precautions Restrictions on smoking and food/drink consumption Power back-ups, cabling and telecommunications 60. THE OPERATIONS ENVIRONMENT 13. CORPORATE GOVERNANCE Corporate governance responsibilities have increased through: 1. 2. Progressive requirements and guidance: Rutteman – directors’ reporting guidance (1994) Hampel – financial controls, listed companies (1998) Cadbury – financial controls guidance (1999) Combined Code/Turnbull (2000): 3. Higgs/Smith (2003): 4. Need to report on review of effectiveness of system of financial, operational and compliance internal controls and risk management Non-executive directors and audit committee responsibilities Sarbanes-Oxley (U.S.2004) Law enforcement, rather than regulation 61. MORE INFORMATION …… “Using information from another source is plagiarism. Using information from a number of sources is research …..” The presenter’s own experiences and opinions in this session have been complemented by references from a variety of sources including: • Information Security Forum ( www.securityforum.org ) • Information Systems Audit and Control Association ( www.isaca.org ) • IT Governance Institute ( www.itgi.org ) • Information Technology – Code of Practice for Information Security Management ( www.bsi-global.com ) • Institute of Internal Auditors – UK & Ireland ( www.iia.org.uk ) • IT Information Library ( www.itilpeople.com ) • European Corporate Governance Institute ( www.ecgi.org ) • Guidance for NHS Board members – Information Management & Technology (thanks to Tim Moynihan for this subsequent link) (www.nhsia.nhs.uk/nhid/pages/resource_informatics/IMT_guidance_bookl et.pdf ) 62.