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27 Ensure that an effective process exists for recording, tracking, escalating, and resolving problems that arise after implementation 28 Review and evaluate the project s conversion plan Ensure that the project has an adequate conversion plan and follows this plan 29 Review plans for converting the support of the new system or software from the project team to an operational support team 30 Ensure that sufficient documentation has been created for use of the system or process being developed and maintenance of the system or software Evaluate processes for keeping the documentation up-to-date Evaluate change controls and security over that documentation
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31 Review plans for ensuring that all affected users are trained in the use of the new system, software, or process 32 Ensure that processes are in place for keeping training materials up-to-date Evaluate change controls and security over the training materials
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33 Ensure that a process exists for closing out the project and recording lessons learned and that the process is followed
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PART III
Frameworks, Standards, and Regulations
16 17 18
Frameworks and Standards Regulations Risk Management
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CHAPTER
Frameworks and Standards
As information technology (IT) matured during the late twentieth century, the IT department within each organization typically developed its own methods for managing operations Eventually, frameworks and standards emerged to provide guidelines for the management and evaluation of IT processes In this chapter we will look at some of today s most prominent frameworks and standards related to the use of technology Our discussion will cover the following: Introduction to internal IT controls, frameworks, and standards Committee of Sponsoring Organizations (COSO) Control Objectives for Information and Related Technology (COBIT) IT Infrastructure Library (ITIL) ISO 27001 National Security Agency (NSA) INFOSEC Assessment Methodology Frameworks and standards trends
Introduction to Internal IT Controls, Frameworks, and Standards
In the 1970s, concern over the rise in corporate bankruptcies and financial collapses began to heighten a demand for more accountability and transparency among publicly held companies The Foreign Corrupt Practices Act of 1977 (FCPA) criminalized bribery in foreign countries and was the first regulation that required companies to implement internal control programs to keep extensive records of transactions for disclosure purposes When the savings and loan industry collapsed in the mid-1980s, there was a cry for governmental oversight of accounting standards and the auditing profession In an effort to deter governmental intervention, an independent private-sector initiative, later called Committee of Sponsoring Organizations (COSO), was initiated in 1985 to assess how best to improve the quality of financial reporting COSO formalized the concepts of internal control and framework in 1992 when it issued the landmark publication Internal Control Integrated Framework
IT Auditing: Using Controls to Protect Information Assets, Second Edition
Since that time, other professional associations have continued to develop additional frameworks and standards to provide guidance and best practices to their constituents and the IT community at large The following sections highlight COSO and some of the other most prominent IT frameworks and standards in use today
COSO
In the mid-1980s, the National Commission on Fraudulent Financial Reporting was formed in response to growing US financial crises and the cry for governmental oversight of accounting and audit practices This independent private-sector consortium was more commonly referred to as the Treadway Commission because it was headed by James C Treadway, Jr, executive vice president and general counsel at Paine Webber Incorporated and a former commissioner of the US Securities and Exchange Commission In its initial 1987 report, the group recommended that the organizations sponsoring the commission work together to develop comprehensive guidelines for internal control Hence COSO was formed by the five major professional associations in the United States: American Institute of Certified Public Accountants (AICPA) American Accounting Association (AAA) Financial Executives Institute (FEI) Institute of Internal Auditors (IIA) Institute of Management Accountants (IMA) The commission is wholly independent of each of the sponsoring organizations and includes representatives from industry, public accounting, investment firms, and the New York Stock Exchange COSO published the first formalized guidelines for internal controls, Internal Control Integrated Framework, in 1992 This publication established a common definition for internal control and a framework against which organizations can assess and improve their control systems In 1994, COSO s work was endorsed by the head of the General Accounting Office (GAO) of the US Congress These voluntary industry guidelines were intended to help public companies become self-regulating and thus avoid the need for governmental regulation of the accounting and auditing industries In 2001, COSO began its second major initiative aimed at expanding previous work on internal controls to address the growing emphasis on risk management At about the same time, the United States was barraged with the sensational failures of Enron, Tyco, Global Crossing, Kmart, Adelphia, WorldCom, HealthSouth, and many others The US government quickly enacted the Sarbanes-Oxley Act of 2002 to mandate the requirement for internal controls to be audited along with financial statements (as discussed in more detail in 17) On the heels of all this high-profile activity, COSO published Enterprise Risk Management Integrated Framework in 2004 This second document provided a more comprehensive framework for identifying, assessing, and managing risk
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