IT Audit Amy Vuong, Director KPMG LLP April 14, 2015 KPMG IT Audit FY 2013-14 Results • In Scope Systems • Common Financial System (CFS) – Effective • Data Warehouse (DW) – Effective • Findings • 4 total IT deficiencies April 2014 Year-End GAAP Training (webcast) 2 Prior Year IT Findings (1 of 4) Finding Description Exists as of 6/30/14 Management Response Root Cause for the Finding Recommendation Password Policy: The San Marcos campus did not have a formal password policy documented. Password Configuration: The password policy configurations set at the campus level did not adhere to their campus password policies. 1) Chancellor's Office: Maximum failed password attempts (policy denoted 3 maximum attempts, configuration set at 5 maximum attempts) 2) Channel Islands: Password aging schedule (policy denoted 180 days, configuration set to 200 days) 3) Dominguez Hills: Maximum failed password attempts (policy denoted 5 maximum attempts, configuration set at 10 maximum attempts) 4) San Francisco: Minimum password length (policy denoted 8 characters, configuration set at 0) April 2014 No All campuses have remediated the noted issues. Year-End GAAP Training (webcast) The password configurations established at each campus should be reviewed/updated to reflect Non-adherence to policies the requirements stated in and procedures the Access Control Standards document and the campus password policies. 3 Prior Year IT Findings (2 of 4) Finding Description Windows Administration: KPMG noted 11 CSU employees with domain administrator privileges on the Windows network. Although these access rights were once appropriate and necessary for the installation of network applications, these users no longer require these privileges, and domain administrator access rights should be restricted to Unisys personnel. April 2014 Exists as of 6/30/14 Yes Management Response Root Cause for the Finding Recommendation Windows domain access has been removed for CSU A periodic review of users personnel. This was Lack of user access review with privileged access reviewed and validated by should be performed. CO Information Security. Year-End GAAP Training (webcast) 4 Prior Year IT Findings (3 of 4) Finding Description Granting/Modifying Access: KPMG noted that the Dominguez Hills campus was not able to provide user access request forms for 3 sampled users. We noted that they experienced a change in the personnel responsible for overseeing the CFS access provisioning and de-provisioning process beginning January 2014. In addition, they were in the process of transitioning their recordkeeping of user access forms from hardcopies to softcopies. As a result, they were unable to locate evidence of access approvals for 3 of our sampled users. April 2014 Exists as of 6/30/14 Yes Management Response Root Cause for the Finding The Chancellor's Office will disseminate a memo directing campuses to Non-adherence to policies implement appropriate and procedures business practices to track and retain CMS user access records. Year-End GAAP Training (webcast) Recommendation Policies and procedures must be followed in order for processes to be deemed effective. Review the established process and ensure that campuses are following the procedures as documented. 5 Prior Year IT Findings (4 of 4) Finding Description Terminating Access: KPMG noted that campuses did not remove terminated users' access rights in a timely manner. 1) Dominguez Hills: Access for 4 users was not removed until 11, 26, 41, and 46 days after they were terminated 2) San Francisco: Access for 1 user was not removed until 16 days after they were terminated 3) San Luis Obispo: Access for 3 users was not removed until 10, 11, and 18 days after they were terminated 4) San Jose: Access for 4 users was not removed until 11, 12, 21, and 23 days after they were terminated 5) San Marcos: Access for 4 users was not removed until 19 days, 34 days, 4 months, 6 months, and 8 months after they were terminated April 2014 Exists as of 6/30/14 Yes Management Response Root Cause for the Finding Recommendation A general timeline should be implemented on how quickly a terminated user should be removed from the system. KPMG will be testing the removal/disabling of The Chancellor's Office will access for terminations disseminate a memo within a one week directing the campus to timeframe after the Non-adherence to policies terminate CMS user termination date. and procedures access rights within 10 days of an employee's last The majority of campuses active day of employment. do not conduct a regular review over terminated users. Campuses should implement a regular review process to catch terminated users that were not disabled within one week. Year-End GAAP Training (webcast) 6 KPMG IT Audit – Approach • Perform IT Audit for FY 2014 -15 • IT General Controls • IT Application Controls • Purpose • Gain assurance over internal controls in place over IT systems to limit the risk of material misstatement to the financial statements • Reliance on IT system controls over computerized output reduces substantive procedures required for financial statement audits April 2014 Year-End GAAP Training (webcast) 7 KPMG IT Audit – Scope of Work • In Scope Systems • Common Financial System (CFS) • Data Warehouse (DW) • Current year procedures are in the process of being conducted at the following locations: Chancellor’s Office Northridge San Jose Fullerton Sacramento San Luis Obispo Long Beach San Francisco April 2014 Year-End GAAP Training (webcast) 8 KPMG IT Audit – Overview of IT General Controls • IT General Controls • Controls that support the foundation of the system. • Includes 4 components: • Access to Programs and Data • Program Changes • Program Development • Computer Operations April 2014 Year-End GAAP Training (webcast) 9 KPMG IT Audit – IT General Controls Procedures • Access to Programs and Data • • • • • • • • April 2014 IT Security Policies Passwords Security Access Rights / Privileged Access DBA Access Granting / Modifying Access Terminating Access Physical Access Annual User Access and SOD Review Year-End GAAP Training (webcast) 10 KPMG IT Audit – IT General Controls Procedures (continued) • Program Changes • • • • April 2014 Change Management Policies and Procedures Change Management Request and Approval Change Management Testing Change Management Security Access Rights Year-End GAAP Training (webcast) 11 KPMG IT Audit – IT General Controls Procedures (continued) • Computer Operations • • • • • April 2014 Job Processing Backup Procedures Restoration Testing Access to Backup Tapes Incident Management Year-End GAAP Training (webcast) 12 KPMG IT Audit – Overview of IT Application Controls • Application Controls – are automated controls or manual controls with an automated component • Steps, requirements, that a computer system executes to achieve a specific objective—the objective of the automated control to prevent, detect and/or correct the risk of a financial misstatement • Types of IT Application controls include: • system configuration/account mapping • exception/edit reports, including review of these reports • interface controls, and • system access, including enforcing segregation of duties. • If the IT General Controls are operating effectively KPMG IT will conduct testing over select IT Application Controls April 2014 Year-End GAAP Training (webcast) 13 KPMG IT Audit – IT Application Controls Procedures • IT Application Controls • Current year procedures include: • Journal Entries Completeness testing • Access to enter/post Journal Entries • GAAP Derivation process • Access to the GAAP Override feature April 2014 Year-End GAAP Training (webcast) 14 KPMG IT Audit – Deficiency and Communication • Control deficiencies • Confirm deficiencies with control owners before finalizing and reporting • Perform additional testwork/identify compensating controls to mitigate the risk • Perform remediation procedures April 2014 Year-End GAAP Training (webcast) 15 KPMG IT Audit – Deficiency and Communication (continued) • Impact on Financial Audit Team • As the IT team leads in their testwork timing, KPMG IT will report all deficiencies to the financial audit team. • The financial audit team will analyze these deficiencies as they relate to the year-end financial statement audit and modify the audit approach as may be necessary. This may include performing additional substantive procedures, making additional sample selections, etc. April 2014 Year-End GAAP Training (webcast) 16 KPMG IT Audit – Key Dates Task Day Date KPMG to provide PBC Request Lists to CSU Friday April 10th, 2015 CMS and Campus to provide PBC items to KPMG Monday April 27th, 2015 On-site fieldwork begins Monday April 27th, 2015 KPMG will perform testwork over IT General Controls and IT Application Controls April 27th, 2015 – June 30, 2015 Rollforward Testing / Project Wrap up / Close out Meeting July 2015 April 2014 Year-End GAAP Training (webcast) 17 www.calstate.edu April 2014 Year-End GAAP Training (webcast) 18