leverage informationtechnology: turn risk into reward ™ copyright ©. fulcrum information...

30
Leverage Information Technology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls Application Controls Monitoring Best Practices Adil Khan, Sr. Client Director Fulcrum Information Technology, Inc. [email protected]

Upload: garrison-hindsley

Post on 14-Jan-2016

217 views

Category:

Documents


0 download

TRANSCRIPT

Page 1: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

Leverage Information Technology:

Turn Risk into Reward ™

Copyright ©. Fulcrum Information Technology, Inc.

Top Five Reasons for Automating Application

Controls

Application Controls Monitoring Best Practices

Adil Khan, Sr. Client DirectorFulcrum Information Technology, Inc.

[email protected]

Page 2: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

Top 5 Reasons for Automating Application Controls

IntroductionIT Governance Risk and Compliance NeedsFulcrum-IIA Controls SurveyIT Controls Framework Application Controls OverviewAuditing Challenges Automation ApproachAccess Controls Automation Example Case Studies Top Five Reasons

AGENDA

Page 3: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

About Fulcrum

We are a Leading provider of Governance, Risk and Compliance solutions for enterprise customers. Our solutions focus on:

Enterprise Application Controls Monitoring

GRC Process Management

GRC Intelligence

FulcrumWare GRC Tools include Content and On-line services to rapidly reduce risks such as Segregation of Duty violations in Enterprise Systems such as Oracle E-business Suite, PeopleSoft, JD Edwards, SAP and other Legacy Apps

FulcrumWay Professionals are leading experts with real world experience in Internal Audit, Enterprise Systems and GRC Process Management.

FulcrumPoint Insight provides the latest trends, best practices and thought leadership through regional and national conferences held by OAUG, IIA, ISACA

Privately Held Delaware corporation with US presence in:New York, Texas and California

International Presence in UK and India

Page 4: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

Fulcrum Credentials

Media and Entertainment

Financial Services

Healthcare

Natural Resources

Life Sciences

Industrial Manufacturing

Defense/ Aerospace

Retail

Construction

High Technology

Readers Digest

Retail

Food

Page 5: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

FulcrumPoint Insight

Thought Leadership - Events

Compliance Week Magazine - Healthcare Firm Aligns Compliance Efforts, Cuts Costs

Economist Magazine –Compliance Guide for Enterprise Systems

POD Cast – How Automating the Enterprise Risk Management Process helps organizations comply with regulations

OAUG - Impact of AS5 for Oracle Enterprise Customers

IIA – Top Five Reasons for Automating Application Controls

Oracle Open World – Annual GRC Dinner, GE and Birds Eye Case Study

Web casts – GRC Best Practices, Trends and Expert Insight.

Page 6: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

IT Governance, Risk and Compliance Needs

Common Compliance NeedsCommon Compliance Needs

MandateMandateProcesses and Processes and

Risk Risk ManagementManagement

Enterprise Enterprise Content Content

ManagementManagement

Security and Security and Identity Identity

ManagementManagement

Learning Learning ManagementManagement

Cross IndustryCross Industry

Sarbanes-Oxley ActSarbanes-Oxley Act XX XX XX XX

HIPAAHIPAA XX XX XX

California Senate Bill 1386California Senate Bill 1386 XX XX XX

International Accounting StandardsInternational Accounting Standards XX XX

EU Data Privacy DirectiveEU Data Privacy Directive XX XX XX

Federal Sentencing GuidelinesFederal Sentencing Guidelines XX

Industry-SpecificIndustry-Specific

Basel IIBasel II XX XX XX XX

Gramm-Leach BlileyGramm-Leach Bliley XX XX XX

Payment Card Industry Data SecurityPayment Card Industry Data Security XX XX XX XX

FDA 21 CFR Part 11FDA 21 CFR Part 11 XX XX XX

Freedom of Information ActFreedom of Information Act XX XX

USA PATRIOT ActUSA PATRIOT Act XX XX XX

Multiple Compliance Needs

Page 7: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

DemographicsFulcrum Survey

Page 8: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

Results – Financial Reporting Process

Fulcrum Survey

Page 9: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

Results – Internal ControlsFulcrum Survey

Page 10: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

IT Controls Framework

IT organizations should consider the nature and extent of theiroperations in determining which, if not all, of the following control objectives need to be included in internal control program:

PLAN AND ORGANIZE

ACQUIRE AND IMPLEMENT

DELIVER AND SUPPORT

MONITOR AND EVALUATE

IT Controls

Page 11: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

What are Application Controls?

Application controls apply to the business processes they support. These controls are designed within the application to prevent or detect unauthorized transactions. When combined with manual controls, as necessary, application controls ensure completeness, accuracy, authorization and validity of processing transactions

Control objectives can be supported with automated application controls. They are most effective in integrated ERP environments, such as SAP, PeopleSoft, Oracle, JD Edwards and others.

Examples:Orders are processed only within approved customer credit limits.Orders are approved by management as to prices and terms of sale.Purchase orders are placed only for approved requisitions. Purchase orders are accurately entered. All purchase orders issued are input and processed. All recorded production costs are consistent with actual direct and indirect expenses associated with production.All direct and indirect expenses associated with production are recorded as production costs.

Application Controls Overview

Page 12: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

Risk Assessment

The IT organization has an entity- and activity-level risk assessment framework, which is used periodically to assess information risk to achieving business objectives.Management’s risk assessment framework focuses on the examination of the essential elements of risk and the cause and effect relationship among them.A risk assessment framework exists and considers the risk assessment probability and likelihood of threats.The IT organization’s risk assessment framework measures the impact of risks according to qualitative and quantitative criteria.The IT organization’s risk assessment framework is designed to support cost-effective controls to mitigate exposure to risks on a continuing basis, including risk avoidance, mitigation or acceptance.A comprehensive security assessment is performed for critical systems and locations based on their relative priority.

Application Controls Overview

Page 13: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

Control Activities

An organization has and does the following : A system development life cycle methodology that considers security, availability and processing integrity requirements of the organization. This ensures that information systems are designed to include application controls that support complete, accurate, authorized and valid transaction processing.An acquisition and planning process that aligns with its overall strategic direction.Acquires software in accordance with its acquisition and planning process.Procedures ensure that system software is installed and maintained in accordance with the organization’s requirements.Procedures ensure that system software changes are controlled in line with the organization’s change management procedures.Ensures that the implementation of system software do not jeopardize the security of the data.

Application Controls Overview

Page 14: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

Control Monitoring

Changes to IT systems and applications are performed and designed to meet the expectations of users.IT management monitors its delivery of services to identify shortfalls and responds with actionable plans to improve.IT management monitors the effectiveness of internal controls Monitoring in the normal course of operations through management and supervisory activities, comparisons and benchmarks.Serious deviations in the operation of internal control, Monitoring including major security, availability and processing integrity events, are reported to senior management.Internal control assessments are performed periodically, using Monitoring self-assessment or independent audit, to examine whether internal controls are operating satisfactorily.

Application Controls Overview

Page 15: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

Stages of Application Controls Implementation

Automation Approach

Define: Define Audit Units, Application Environments, and Controls in-scope for Audit Testing

Detect: Analyze Control Violations based on risk, impact. Eliminate false-positives, exceptions

Remediate: Resolve Control Violations

Prevent: Automated Controls deny unauthorized access, transactions and system changes in real-time

Monitor: Analytics to notify management of all control violations

Page 16: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

Establish Rules

RepositoryDetect

ViolationsAnalyzeIssues

RemediateIssues

ImplementChanges

MonitorApplication

Environment

DetermineScope

by Application

Extract ERP Data

ManageExceptions

SetupPreventiveControls

Application Control TeamsCorporate Access

Controls

Business Process Teams

IT Management

Establish Test

Environment

Application Controls Management Best Practices

Automation Approach

Page 17: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

Achieving regulatory compliance requires more than IT policies and process documentation

Effective application audit planning requires mapping controls over application test environments, audit units and significant business processes based on risk likelihood and impact to thousands of functions and activities accessible through many roles, menus and functions. Detecting users that have unauthorized access to one or more critical business functions such as purchase to pay requires business analytics based on application control rules.Compensating controls are needed for certain users and transactions where business constraints require exceptions. Remediation effort requires strong collaboration among Audit, IT and Business stakeholders to reconfigure security, reassign users, prevent configuration changes, monitor transaction thresholds. ERP Access Provisioning and Configurations must be approved in “real time” to keep up with business needs.

Auditing Challenges

Page 18: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

Rules Library is the master repository that contains all SOD Rules stored in Access Control

Page 19: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

User can create multiple access control tests to detect SOD violations. Violation Results are stored in the database for analysis and change management

Page 20: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

Security Managers can assign remediation requests and monitor progress to ensure “Closed-Loop” detection to remediation cycle

Page 21: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

Access provision requests is key financial systems can be process quickly while complying with SOD Policies

Page 22: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

Analytics to monitor SOD violations and notify management

Page 23: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

A. Case Study – Improve User Provisioning

Company OverviewWholly owned subsidiary of Fortune 500 focused on communication and information technologies for security, safety and lifestyle enhancements.Operations in more than 30 countriesOracle E Business Suite

GRC Challenges/OpportunitiesComply with SOX Needed to automate a manual and labor-intensive process to define and approve user access.Segregation of Duties ConcernsOracle E-Business Environment

– 40 Modules – 2500 Users, 100 + user

responsibilities

GRC Solutions Automate User Access Provisioning Compliant with SOD Policies

Results

Implemented access provisioning solution to identify users violations and allow auditable override capability for authorized access. 

Security provisioning time reduction

Management Commitment to GRC

SOD Rules Content jump started the process

Detected over 5,000 violations

Reduced access provisioning time from 14 days to 4 hours

Trained Process Owners through online self-service portal

Page 24: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

B. Case Study – Remediate Access Control Deficiency

Company OverviewLeading manufacturer of electrical and mechanical motion control productsGrowing Rapidly through acquisitions Manufacturing and service facilities are located worldwideMultiple Enterprise Applications

GRC Challenges/OpportunitiesRemediate Significant Deficiency identified by external AuditorNeeded a central system to detect over 5000 user access violations and implement new roles across multiple systems within 90 daysLimited IT Audit Resources – One Full Time Equivalent (FTE)

GRC Solutions Risk Analytics Service Access PoliciesDetection and Remediation Service

Results

Completed First Test in 24 hours

No time or resources wasted on additional IT Infrastructure with the On Demand Web Service

Setup Compensating Controls for Waived Users

Preventive Controls Functions reduced the risk of security violations in real time.

Fully Compatible with all Enterprise Systems

Access Controls Content helped management define risk likelihood and impact

Faster Remediation through Analytical Reports and Filters

What-if Analysis Improved Self-Service User Provisioning Process

Page 25: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

C. Case Study – Reduce Expense through Configurable Controls

Company Overview

World’s pre-eminent gold producer, with a portfolio of 27 operating minesMany advanced exploration and development projects located across five continentsThe largest gold reserves in the industry

GRC Challenges/OpportunitiesNeed to reduce SOX Compliance Audit expenseImplement continuous controls monitoringBaseline ERP Configurable Controls for AS5

GRC Solutions Identify Controls for full or partial automation. Benchmark ERP ConfigurationsSetup audit logs on all configuration changes.

Results

Analyzed over 1,000 controls

Application Audit Portal provides audit trail on all configuration changes in ERP Systems

Track changes to key application setup data and code.

Approval workflows and notifications facilitate change management without negatively impacting core business operations.

Increase visibility into the actual operations of the controls environment

Reduced Testing Time by 30%

Page 26: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

Scope application control rules based on IT/Business Risk Likelihood and Impact.

Create application test environment based on a central Master Control Content Library.

Maintains Change Controls over Test Plans to manage changes in application environments.

Top 5 Reasons to Automate Controls

Reason #5: Build Effective Test Plan

Page 27: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

Top 5 Reasons to Automate Controls

Remove false-positives e.g. view-only, hidden or excluded functions.

Exclude control violations where business constraints require “waivers”. Track exception justifications and test compensating controls.

Analyze direct violations within user/role and indirect violations across multiple roles assigned to user.

Reason #4: Detect Control Violations Accurately

Page 28: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

Top 5 Reason to Automate Controls

Document and assign remediation tasks to Application and Process Owners.

Perform “what-if” analysis to identify business impact of control operation.

Promote successfully tested application controls to production application environment without error prone

manual entries .

Reason #3: Faster Remediation Time Reduces Business Risk

Page 29: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

Top 5 Reason to Automate Controls

Identify Control Violations based on pre-defined IT Policies to prevent Segregation of Duties Violations, Unapproved Configuration Changes and Erroneous Transactions.

Improve Application Change Management Process through electronic approval workflow.

Restrict Access to Sensitive Data.

Reason #2: Achieve Sustainable Compliance with Preventive Monitoring

Page 30: Leverage InformationTechnology: Turn Risk into Reward ™ Copyright ©. Fulcrum Information Technology, Inc. Top Five Reasons for Automating Application Controls

www.fulcrumway.com

Reduce Internal and External Application Testing effort by auditing changes to Application Baseline.

Improve Detection to Remediation Cycle through electronic workflow management of control violations.

Reduce Cost of Compliance by replacing manual detection, remediation and prevention activities with streamlined and automated processes.

Reason #1: reduce Auditing Time and Expense

Top 5 Reasons to Automate Controls