The PCAOB is introducing new guidance to help lower the overall cost and, presumably, increase the effectiveness of SOX 404 audits. It needs to use this opportunity to help fix some root causes, not just tell us how to find more symptoms.
This past December, the PCAOB announced that it would propose for public comment a “new standard on auditing internal control…designed to focus the auditor on the most important matters, increasing the likelihood that material weaknesses will be found…” The proposal itself can be found at http://www.pcaobus.org/Rules/Docket_021/2006-12-19_Release_No._2006-007.pdf.
Starting on page 93 of the document, there is a section on “Benchmarking of Automated Controls.” It includes guidance like “Entirely automated application controls are generally not subject to breakdowns due to human failure,” which is clearly not true since bad input makes functional application security controls fail all the time. Telling auditors that automated application controls automatically get a gold star is not a step in the right direction.
It does go on to suggest that the benchmarking strategy take into account the importance of the effect of related files, tables, data, and parameters on the consistent and effective functioning of the automated application. That’s a good thing.
The document then suggests that “If general controls over program changes, access to programs, and computer operations are effective and continue to be tested, and if the auditor verifies that the automated application control has not changed since the auditor established a baseline (i.e., last tested the application control), the auditor may conclude that the automated application control continues to be effective without repeating the prior year’s specific tests of the operation of the automated application control.”
So, never mind that new attacks are discovered with unnerving frequency and that perfectly good code can suddenly become not so great (think crypto algorithms), the apparent recommendation is that if you didn’t or couldn’t poke hard enough to break it over some time period, then it’s okay to skip it later. Approaches like this where we’re considering only functional changes and not testing skill and depth can’t be effective.
How many times has someone walked up and spotted a problem you failed to notice time and time again. As organizations periodically change auditing firms, expect huge increases in reported problems.
The proposed guidance gives the following factors to use when deciding to use benchmarking:
- The extent to which the application control can be matched to a defined program within an application;
- The extent to which the application is stable (i.e., there are few changes from period to period); and
- The availability and reliability of a report of the compilation dates of the programs placed in production. (This information may be used as evidence that controls within the program have not changed.)
This wording is still neglecting changes on the threat side of the equation. Just as many castles were considered impregnable until about five seconds before the first cannonball hit, many lines of code were considered secure right up to the point where the breach story appeared in the newspaper.
The guidance gives the following factors to use when deciding whether to reestablish the benchmarking baseline:
- The effectiveness of the IT control environment, including controls over application and system software acquisition and maintenance, access controls and computer operations;
- The auditor’s understanding of the nature of changes, if any, on the specific programs that contain the controls;
- The nature and timing of other related tests;
- The consequences of errors associated with the application control that was benchmarked; and
- Whether the control is sensitive to other business factors that may have changed. For example, an automated control may have been designed with the assumption that only positive amounts will exist in a file. Such a control would no longer be effective if negative amounts (credits) begin to be posted to the account.
Okay, so if I know that most auditors and organizations use COSO as a governance model, and COBIT 4 to interpret COSO to arrive some IT control objectives, and I consider AI2, Acquire and maintain application software, important to my environment, then I might understand what “controls over application and system software acquisition and maintenance” means above. And, I might even read COBIT and see AI2.4, Application Security and Availability, which states “Address application security and availability requirements in response to identified risks, in line with data classification, the organization’s information security architecture and risk profile. Issues to consider include access rights and privilege management, protection of sensitive information at all stages, authentication and transaction integrity, and automatic recovery.” Oh wait, I only need security software, not software security. Sigh. Another opportunity missed.
There is a need here for any words that introduce something like the following:
The customer may have written their own software that is directly used in the financial reporting process and you, the auditor, should be aware not only of the software’s functional controls (e.g., I&A, encryption, entitlements), but you must also accrue confidence that their internal development practices and testing are sufficient to produce quality software that has at least some capability to protect itself from attack even in the event of catastrophic failures other general and IT security controls being considered as part of this SOX audit. While security software may comprise the majority of IT security controls, software security is the property that gives us confidence in their continued successful operation even in the certainty of ongoing attack. You must use a risk-based approach to accruing confidence, focusing on relevant factors that have a material effect on the software’s ability to meet business objectives even in an overtly hostile environment.
Now we’re thinking more about the problem and less about the symptoms.
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