Information Security Management Audit/Assurance Program Information Security Management Audit/Assurance Program ISACA® With more than 86,000 constituents in more than 160 countries, ISACA (www.isaca.org) is a leading global provider of knowledge, certifications, community, advocacy and education on information systems (IS) assurance and security, enterprise governance of IT, and IT-related risk and compliance. Founded in 1969, ISACA sponsors international conferences, publishes the ISACA® Journal, and develops international IS auditing and control standards. It also administers the globally respected Certified Information Systems Auditor™ (CISA®), Certified Information Security Manager ® (CISM®), Certified in the Governance of Enterprise IT ® (CGEIT®) and Certified in Risk and Information Systems Control™ (CRISC™) designations. ISACA offers the Business Model for Information Security™ (BMIS™) and the IT Assurance Framework™ (ITAF™). It also developed and maintains the COBIT®, Val IT™ and Risk IT frameworks, which help IT professionals and enterprise leaders fulfill their IT governance responsibilities and deliver value to the business. Disclaimer ISACA has designed and created Information Security Management Audit/Assurance Program (the “Work”) primarily as an informational resource for audit and assurance professionals. ISACA makes no claim that use of any of the Work will assure a successful outcome. The Work should not be considered inclusive of all proper information, procedures and tests or exclusive of other information, procedures and tests that are reasonably directed to obtaining the same results. In determining the propriety of any specific information, procedure or test, audit and assurance professionals should apply their own professional judgment to the specific circumstances presented by the particular systems or information technology environment. Reservation of Rights © 2010 ISACA. All rights reserved. No part of this publication may be used, copied, reproduced, modified, distributed, displayed, stored in a retrieval system or transmitted in any form by any means (electronic, mechanical, photocopying, recording or otherwise) without the prior written authorization of ISACA. Reproduction and use of all or portions of this publication are permitted solely for academic, internal and noncommercial use and for consulting/advisory engagements, and must include full attribution of the material’s source. No other right or permission is granted with respect to this work. ISACA 3701 Algonquin Road, Suite 1010 Rolling Meadows, IL 60008 USA Phone: +1.847.253.1545 Fax: +1.847.253.1443 E-mail: info@isaca.org Web site: www.isaca.org ISBN 978-1-60420-156-7 Information Security Management Audit/Assurance Program CRISC is a trademark/service mark of ISACA. The mark has been applied for or registered in countries throughout the world. © 2010 ISACA. All rights reserved. Page 2 Information Security Management Audit/Assurance Program ISACA wishes to recognize: Author Norm Kelson, CISA, CGEIT, CPA, CPE Interactive Inc., USA Expert Reviewers Bok Hai Suan, CISM, CGEIT, Singapore Kerrie Douglas, CISA, CGEIT, Six Sigma Green Belt, DaVita, USA Gbadamosi Folakemi Toyin, CGEIT, APDM, CGRC-IT, CICA, CIPM, Flooky-Tee Computers, Nigeria Anuj Goel, Ph.D., CISA, CGEIT, Citigroup, Inc., USA Michael Lloyd Jones, CISA, CIA, CISSP, FLMI, BMO Financial Group, Canada Prashant Khopkar, CISA, CA, USA Raul Millan, CISA, CISM, CCSE, CEH, CISSP, Consultores de Seguridad Informatica, Panama Philippe Rivest, TransForce, Canada Vinoth Sivasubramanian, ABRCCIP, CEH, ISO 27001 LA, UAE Exchange Center LLC, UAE Babu Srinivas, CISA, CISM, SP AusNet, Australia Vikrant V. Tanksale, CISA, ACWA, CMA, ALBahja Industrial Holdings LLC, Oman Bart van Lodensteijn, CISA, CGEIT, Ordina Consultancy B.V., The Netherlands Jeff Warren, CISM, JPW Consult, Australia ISACA Board of Directors Emil D’Angelo, CISA, CISM, Bank of Tokyo-Mitsubishi UFJ Ltd., USA, International President Hitoshi Ota, CISA, CISM, CGEIT, CIA, Mizuho Corporate Bank Ltd., Japan, Vice President Jose Angel Pena Ibarra, CGEIT, Alintec S.A., Mexico, Vice President Christos K. Dimitriadis, Ph.D., CISA, CISM, INTRALOT S.A., Greece, Vice President Rolf M. von Roessing, CISA, CISM, CGEIT, KPMG Germany, Germany, Vice President Robert E. Stroud, CGEIT, CA Technologies, USA, Vice President Kenneth L. Vander Wal, CISA, CPA, Ernst & Young LLP (retired), USA, Vice President Ria Lucas, CISA, CGEIT, Telstra Corp. Ltd., Australia, Vice President Everett C. Johnson Jr., CPA, Deloitte & Touche LLP (retired), USA, Past International President Lynn C. Lawton, CISA, FBCS CITP, FCA, FIIA, KPMG Ltd., Russian Federation, Past International President Gregory T. Grocholski, CISA, The Dow Chemical Co., USA, Director Tony Hayes, CGEIT, AFCHSE, CHE, FACS, FCPA, FIIA, Queensland Government, Australia, Director Howard Nicholson, CISA, CGEIT, CRISC, City of Salisbury, Australia, Director Jeff Spivey, CPP, PSP, Security Risk Management, USA, ITGI Trustee Knowledge Board Gregory T. Grocholski, CISA, The Dow Chemical Co., USA, Chair Michael Berardi Jr., CISA, CGEIT, Nestle USA, USA John Ho Chi, CISA, CISM, CBCP, CFE, Ernst & Young LLP, Singapore Jose Angel Pena Ibarra, CGEIT, Alintec S.A., Mexico Jo Stewart-Rattray, CISA, CISM, CGEIT, CSEPS, RSM Bird Cameron, Australia Jon Singleton, CISA, FCA, Auditor General of Manitoba (retired), Canada Patrick Stachtchenko, CISA, CGEIT, CA, Stachtchenko & Associates SAS, France Kenneth L. Vander Wal, CISA, CPA, Ernst & Young LLP (retired), USA Guidance and Practices Committee Kenneth L. Vander Wal, CISA, CPA, Ernst & Young LLP (retired), USA, Chair Kamal Dave, CISA, CISM, CGEIT, Hewlett-Packard, USA Urs Fischer, CISA, CRISC, CIA, CPA (Swiss), Switzerland Ramses Gallego, CISM, CGEIT, CISSP, Entel IT Consulting, Spain Phillip J. Lageschulte, CGEIT, CPA, KPMG LLP, USA Ravi Muthukrishnan, CISA, CISM, FCA, ISCA, Capco IT Service India Pvt. Ltd., India Anthony P. Noble, CISA, CCP, Viacom Inc., USA Salomon Rico, CISA, CISM, CGEIT, Deloitte, Mexico Frank Van Der Zwaag, CISA, CISSP, Westpac, New Zealand, New Zealand © 2010 ISACA. All rights reserved. Page 3 Information Security Management Audit/Assurance Program ISACA and ITGI Affiliates and Sponsors American Institute of Certified Public Accountants ASIS International The Center for Internet Security Commonwealth Association for Corporate Governance Inc. FIDA Inform Information Security Forum Information Systems Security Association Institut de la Gouvernance des Systèmes d’Information Institute of Management Accountants Inc. ISACA chapters ITGI Japan Norwich University Solvay Brussels School of Economics and Management University of Antwerp Management School Analytix Holdings Pty. Ltd. BWise B.V. Hewlett-Packard IBM Project Rx Inc. SOAProjects Inc. Symantec Corp. TruArx Inc. Table of Contents Table of Contents .......................................................................................................................................... 4 I. Introduction ......................................................................................................................................... 4 II. Using This Document........................................................................................................................... 5 IV. Assurance and Control Framework ..................................................................................................... 9 V. Executive Summary of Audit/Assurance Focus................................................................................. 11 VI. Audit/Assurance Program .................................................................................................................. 14 1. Planning and Scoping the Audit.................................................................................................... 14 2. Information Security Management ............................................................................................... 16 3. Information Security Operations ................................................................................................... 20 4. Information Security Technology Management ........................................................................... 27 VII. Maturity Assessment .......................................................................................................................... 33 VIII. Assessment Maturity vs. Target Maturity .......................................................................................... 38 I. Introduction Overview ISACA has developed the IT Assurance Framework TM (ITAFTM) as a comprehensive and good-practicesetting model. ITAF provides standards that are designed to be mandatory and are the guiding principles under which the IT audit and assurance profession operates. The guidelines provide information and direction for the practice of IT audit and assurance. The tools and techniques provide methodologies, tools and templates to provide direction in the application of IT audit and assurance processes. Purpose The audit/assurance program is a tool and template to be used as a road map for the completion of a specific assurance process. ISACA has commissioned audit/assurance programs to be developed for use by IT audit and assurance professionals with the requisite knowledge of the subject matter under review, © 2010 ISACA. All rights reserved. Page 4 Information Security Management Audit/Assurance Program as described in ITAF, in section 2200—General Standards. The audit/assurance programs are part of ITAF, section 4000—IT Assurance Tools and Techniques. Control Framework The audit/assurance programs have been developed in alignment with the ISACA COBIT framework— specifically COBIT 4.1—using generally applicable and accepted good practices. They reflect ITAF sections 3400—IT Management Processes, 3600—IT Audit and Assurance Processes, and 3800—IT Audit and Assurance Management. Many organizations have embraced several frameworks at an enterprise level, including the Committee of Sponsoring Organizations of the Treadway Commission (COSO) Internal Control Framework. The importance of the control framework has been enhanced due to regulatory requirements by the US Securities and Exchange Commission (SEC) as directed by the US Sarbanes-Oxley Act of 2002 and similar legislation in other countries. Enterprises seek to integrate control framework elements used by the general audit/assurance team into the IT audit and assurance framework. Since COSO is widely used, it has been selected for inclusion in this audit/assurance program. The reviewer may delete or rename these columns to align with the enterprise’s control framework. IT Governance, Risk and Control IT governance, risk and control are critical in the performance of any assurance management process. Governance of the process under review will be evaluated as part of the policies and management oversight controls. Risk plays an important role in evaluating what to audit and how management approaches and manages risk. Both issues are evaluated as steps in the audit/assurance program. Controls are the primary evaluation point in the process. The audit/assurance program identifies the control objectives and the steps to determine control design and effectiveness. Responsibilities of IT Audit and Assurance Professionals IT audit and assurance professionals are expected to customize this document to the environment in which they are performing an assurance process. This document is to be used as a review tool and starting point. It may be modified by the IT audit and assurance professional; it is not intended to be a checklist or questionnaire. It is assumed that the IT audit and assurance professional holds the Certified Information Systems Auditor (CISA) designation, or has the necessary subject matter expertise required to conduct the work and is supervised by a professional with the CISA designation and/or necessary subject matter expertise to adequately review the work performed. II. Using This Document This audit/assurance program was developed to assist the audit and assurance professional in designing and executing a review. Details regarding the format and use of the document follow. Work Program Steps The first column of the program describes the steps to be performed. The numbering scheme used provides built-in work paper numbering for ease of cross-reference to the specific workpaper for that section. The physical document was designed in Microsoft® Word. The IT audit and assurance professional is encouraged to make modifications to this document to reflect the specific environment under review. Step 1 is part of the fact-gathering and prefieldwork preparation. Because the prefieldwork is essential to a successful and professional review, the steps have been itemized in this plan. The first level steps, e.g., 1.1, are shown in bold type and provide the reviewer with a scope or high-level explanation of the purpose for the substeps. © 2010 ISACA. All rights reserved. Page 5 Information Security Management Audit/Assurance Program Beginning in step 2, the steps associated with the work program are itemized. To simplify the use of the program, the audit/assurance program describes the audit/assurance objective is described—the reason for performing the steps in the topic area; the specific controls follow. Each review step is listed below the control. These steps may include assessing the control design by walking through a process, interviewing, observing or otherwise verifying the process and the controls that address that process. In many cases, once the control design has been verified, specific tests need to be performed to provide assurance that the process associated with the control is being followed. The maturity assessment, which is described in more detail later in this document, makes up the last section of the program. The audit/assurance plan wrap-up—those processes associated with the completion and review of work papers, preparation of issues and recommendations, report writing, and report clearing—has been excluded from this document since it is standard for the audit/assurance function and should be identified elsewhere in the enterprise’s standards. COBIT Cross-reference The COBIT cross-reference provides the audit and assurance professional with the ability to refer to the specific COBIT control objective that supports the audit/assurance step. The COBIT control objective should be identified for each audit/assurance step in the section. Multiple cross-references are not uncommon. Processes at lower levels in the work program are too granular to be cross-referenced to COBIT. The audit/assurance program is organized in a manner to facilitate an evaluation through a structure parallel to the development process. COBIT provides in-depth control objectives and suggested control practices at each level. As professionals review each control, they should refer to COBIT 4.1 or the IT Assurance Guide: Using COBIT for good-practice control guidance. COSO Components As noted in the introduction, COSO and similar frameworks have become increasingly popular among audit/assurance professionals. This ties the assurance work to the enterprise’s control framework. While the IT audit/assurance function uses COBIT as a framework, operational audit and assurance professionals use the framework established by the enterprise. Since COSO is the most prevalent internal control framework, it has been included in this document and is a bridge to align IT audit/assurance with the rest of the audit/assurance function. Many audit/assurance organizations include the COSO control components within their report and summarize assurance activities to the audit committee of the board of directors. For each control, the audit and assurance professional should indicate the COSO component(s) addressed. It is possible, but generally not necessary, to extend this analysis to the specific audit step level. The original COSO internal control framework contained five components. In 2004, COSO was revised as the Enterprise Risk Management (ERM) Integrated Framework and was extended to eight components. The primary difference between the two frameworks is the additional focus on ERM and integration into the business decision model. ERM is in the process of being adopted by large enterprises. The two frameworks are compared in figure 1. © 2010 ISACA. All rights reserved. Page 6 Information Security Management Audit/Assurance Program Figure 1—Comparison of COSO Internal Control and ERM Integrated Frameworks Internal Control Framework ERM Integrated Framework Control Environment: The control environment sets the tone of an organization, influencing the control consciousness of its people. It is the foundation for all other components of internal control, providing discipline and structure. Control environment factors include the integrity, ethical values, management’s operating style, delegation of authority systems, as well as the processes for managing and developing people in the organization. Risk Assessment: Every entity faces a variety of risks from external and internal sources that must be assessed. A precondition to risk assessment is establishment of objectives, and, thus, risk assessment is the identification and analysis of relevant risks to achievement of assigned objectives. Risk assessment is a prerequisite for determining how the risks should be managed. Control Activities: Control activities are the policies and procedures that help ensure management directives are carried out. They help ensure that necessary actions are taken to address risks to achievement of the entity's objectives. Control activities occur throughout the organization, at all levels and in all functions. They include a range of activities as diverse as approvals, authorizations, verifications, reconciliations, reviews of operating performance, security of assets and segregation of duties. Information and Communication: Information systems play a key role in internal control systems as they produce reports, including operational, financial and compliance-related information that make it possible to run and control the business. In a broader sense, effective communication must ensure information flows down, across and up the organization. Effective communication should also be ensured with external parties, such as customers, suppliers, regulators and shareholders. Monitoring: Internal control systems need to be monitored—a process that assesses the quality of the system’s performance over time. This is accomplished through ongoing monitoring activities or separate evaluations. Internal control deficiencies detected through these monitoring activities should be reported upstream and corrective actions should be taken to ensure continuous improvement of the system. Internal Environment: The internal environment encompasses the tone of an organization, and sets the basis for how risk is viewed and addressed by an entity’s people, including risk management philosophy and risk appetite, integrity and ethical values, and the environment in which they operate. Objective Setting: Objectives must exist before management can identify potential events affecting their achievement. Enterprise risk management ensures that management has in place a process to set objectives and that the chosen objectives support and align with the entity’s mission and are consistent with its risk appetite. Event Identification: Internal and external events affecting achievement of an entity’s objectives must be identified, distinguishing between risks and opportunities. Opportunities are channeled back to management’s strategy or objective-setting processes. Risk Assessment: Risks are analyzed, considering the likelihood and impact, as a basis for determining how they could be managed. Risk areas are assessed on an inherent and residual basis. Risk Response: Management selects risk responses—avoiding, accepting, reducing or sharing risk—developing a set of actions to align risks with the entity’s risk tolerances and risk appetite. Control Activities: Policies and procedures are established and implemented to help ensure the risk responses are effectively carried out. Information and Communication: Relevant information is identified, captured and communicated in a form and time frame that enable people to carry out their responsibilities. Effective communication also occurs in a broader sense, flowing down, across and up the entity. Monitoring: The entirety of enterprise risk management is monitored and modifications are made as necessary. Monitoring is accomplished through ongoing management activities, separate evaluations or both. Information for figure 1 was obtained from the COSO web site, www.coso.org/aboutus.htm. The original COSO internal control framework addresses the needs of the IT audit and assurance professional: control environment, risk assessment, control activities, information and communication, and monitoring. As such, ISACA has elected to utilize the five-component model for these audit/ assurance programs. As more enterprises implement the ERM model, the additional three columns can be added, if relevant. When completing the COSO component columns, consider the definitions of the components as described in figure 1. © 2010 ISACA. All rights reserved. Page 7 Information Security Management Audit/Assurance Program Reference/Hyperlink Good practices require the audit and assurance professional to create a workpaper for each line item, which describes the work performed, issues identified and conclusions. The reference/hyperlink is to be used to cross-reference the audit/assurance step to the workpaper that supports it. The numbering system of this document provides a ready numbering scheme for the workpapers. If desired, a link to the work paper can be pasted into this column. Issue Cross-reference This column can be used to flag a finding/issue that the IT audit and assurance professional wants to further investigate or establish as a potential finding. The potential findings should be documented in a workpaper that indicates the disposition of the findings (formally reported, reported as a memo or verbal finding, or waived). Comments The comments column can be used to indicate the waiving of a step or other notations. It is not to be used in place of a workpaper describing the work performed. III. Controls Maturity Analysis One of the consistent requests of stakeholders who have undergone IT audit/assurance reviews is a desire to understand how their performance compares to good practices. Audit and assurance professionals must provide an objective basis for the review conclusions. Maturity modeling for management and control over IT processes is based on a method of evaluating the enterprise, so it can be rated from a maturity level of nonexistent (0) to optimized (5). This approach is derived from the maturity model that the Software Engineering Institute (SEI) of Carnegie Mellon University defined for the maturity of software development. The IT Assurance Guide: Using COBIT, Appendix VII—Maturity Model for Internal Control, seen in figure 2, provides a generic maturity model showing the status of the internal control environment and the establishment of internal controls in an enterprise. It shows how the management of internal control, and an awareness of the need to establish better internal controls, typically develops from an ad hoc to an optimized level. The model provides a high-level guide to help COBIT users appreciate what is required for effective internal controls in IT and to help position their enterprise on the maturity scale. Maturity Level Figure 2—Maturity Model for Internal Control Status of the Internal Control Environment Establishment of Internal Controls 0 Non-existent There is no recognition of the need for internal control. Control is not part of the organization’s culture or mission. There is a high risk of control deficiencies and incidents. There is no intent to assess the need for internal control. Incidents are dealt with as they arise. 1 Initial/ad hoc There is some recognition of the need for internal control. The approach to risk and control requirements is ad hoc and disorganized, without communication or monitoring. Deficiencies are not identified. Employees are not aware of their responsibilities. There is no awareness of the need for assessment of what is needed in terms of IT controls. When performed, it is only on an ad hoc basis, at a high level and in reaction to significant incidents. Assessment addresses only the actual incident. 2 Repeatable but Intuitive Controls are in place but are not documented. Their operation is dependent on the knowledge and motivation of individuals. Effectiveness is not adequately evaluated. Many control weaknesses exist and are not adequately addressed; the impact can be severe. Management actions to resolve control issues are not prioritized or consistent. Employees may not be aware of their responsibilities. Assessment of control needs occurs only when needed for selected IT processes to determine the current level of control maturity, the target level that should be reached and the gaps that exist. An informal workshop approach, involving IT managers and the team involved in the process, is used to define an adequate approach to controls for the process and to motivate an agreed-upon action plan. © 2010 ISACA. All rights reserved. Page 8 Information Security Management Audit/Assurance Program Maturity Level 3 Defined 4 Managed and Measurable 5 Optimized Figure 2—Maturity Model for Internal Control Status of the Internal Control Environment Establishment of Internal Controls Controls are in place and adequately documented. Operating effectiveness is evaluated on a periodic basis and there is an average number of issues. However, the evaluation process is not documented. While management is able to deal predictably with most control issues, some control weaknesses persist and impacts could still be severe. Employees are aware of their responsibilities for control. There is an effective internal control and risk management environment. A formal, documented evaluation of controls occurs frequently. Many controls are automated and regularly reviewed. Management is likely to detect most control issues, but not all issues are routinely identified. There is consistent follow-up to address identified control weaknesses. A limited, tactical use of technology is applied to automate controls. An enterprise-wide risk and control program provides continuous and effective control and risk issues resolution. Internal control and risk management are integrated with enterprise practices, supported with automated real-time monitoring with full accountability for control monitoring, risk management and compliance enforcement. Control evaluation is continuous, based on self-assessments and gap and root cause analyses. Employees are proactively involved in control improvements. Critical IT processes are identified based on value and risk drivers. A detailed analysis is performed to identify control requirements and the root cause of gaps and to develop improvement opportunities. In addition to facilitated workshops, tools are used and interviews are performed to support the analysis and ensure that an IT process owner owns and drives the assessment and improvement process. IT process criticality is regularly defined with full support and agreement from the relevant business process owners. Assessment of control requirements is based on policy and the actual maturity of these processes, following a thorough and measured analysis involving key stakeholders. Accountability for these assessments is clear and enforced. Improvement strategies are supported by business cases. Performance in achieving the desired outcomes is consistently monitored. External control reviews are organized occasionally. Business changes consider the criticality of IT processes and cover any need to reassess process control capability. IT process owners regularly perform self-assessments to confirm that controls are at the right level of maturity to meet business needs and they consider maturity attributes to find ways to make controls more efficient and effective. The organization benchmarks to external best practices and seeks external advice on internal control effectiveness. For critical processes, independent reviews take place to provide assurance that the controls are at the desired level of maturity and working as planned. The maturity model evaluation is one of the final steps in the evaluation process. The IT audit and assurance professional can address the key controls within the scope of the work program and formulate an objective assessment of the maturity levels of the control practices. The maturity assessment can be a part of the audit/assurance report and can be used as a metric from year to year to document progression in the enhancement of controls. However, it must be noted that the perception of the maturity level may vary between the process/IT asset owner and the auditor. Therefore, an auditor should obtain the concerned stakeholder’s concurrence before submitting the final report to management. At the conclusion of the review, once all findings and recommendations are completed, the professional assesses the current state of the COBIT control framework and assigns it a maturity level using the sixlevel scale. Some practitioners utilize decimals (x.25, x.5, x.75) to indicate gradations in the maturity model. As a further reference, COBIT provides a definition of the maturity designations by control objective. While this approach is not mandatory, the process is provided as a separate section at the end of the audit/assurance program for those enterprises that wish to implement it. It is suggested that a maturity assessment be made at the COBIT control level. To provide further value to the client/customer, the professional can also obtain maturity targets from the client/customer. Using the assessed and target maturity levels, the professional can create an effective graphic presentation that describes the achievement or gaps between the actual and targeted maturity goals. A graphic is provided as the last page of the document (section VIII), based on sample assessments. IV. Assurance and Control Framework ISACA IT Assurance Framework and Standards ITAF section 3630.7—Information Security Management is of primary relevance to the audit/ assurance of information security management. However, information security management is pervasive throughout the IT organization and its functional responsibility. Components of information security are also included in the following ITAF sections: © 2010 ISACA. All rights reserved. Page 9 Information Security Management Audit/Assurance Program 3410—IT Governance 3425—IT Information Strategy 3427—IT Information Management 3450—IT Processes 3630—Auditing IT General Controls ISACA Controls Framework COBIT is a framework for the governance of IT and supporting tool set that allows managers to bridge the gap among control requirements, technical issues and business risks. COBIT enables clear policy development and good practice for IT control throughout enterprises. Utilizing COBIT as the control framework from which IT audit/assurance activities are based aligns IT audit/assurance with good practices as developed by the enterprise. COBIT IT process DS5 Ensure systems security, from the Deliver and Support (DS) domain, is the primary control framework and addresses good practices for ensuring security of corporate information. Secondary COBIT processes are cross-referenced within the audit/assurance program. The COBIT areas for this evaluation include: DS5.1 Management of IT security—Manage IT security at the highest appropriate organizational level, so the management of security actions is in line with business requirements. DS5.2 IT security plan—Translate business, risk and compliance requirements into an overall IT security plan, taking into consideration the IT infrastructure and the security culture. Ensure that the plan is implemented in security policies and procedures together with appropriate investments in services, personnel, software and hardware. Communicate security policies and procedures to stakeholders and users. DS5.3 Identity management—The information security function has defined policies and monitors activities relating to unique user identification; authentication mechanisms; user access rights according to job definition; and documented, appropriate authorization and approval mechanisms. DS5.4 User account management—The information security function has established policies and monitoring procedures that address: requesting, establishing, issuing, suspending, modifying and closing user accounts and related user privileges with a set of user account management procedures. The process includes an approval procedure outlining the data or system owner granting the access privileges and applies to all users, including administrators (privileged users) and internal and external users, for normal and emergency cases. DS5.5 Security testing, surveillance and monitoring—Test and monitor the IT security implementation in a proactive way. IT security should be reaccredited in a timely manner to ensure that the approved enterprise’s information security baseline is maintained. A logging and monitoring function will enable the early prevention and/or detection and subsequent timely reporting of unusual and/or abnormal activities that may need to be addressed. DS5.6 Security incident definition—The security incident management process is defined and monitored by the information security function, and an incident response team has been established and is operationally effective. DS5.7 Protection of security technology—Make security-related technology resistant to tampering, and do not disclose security documentation unnecessarily. DS5.8 Cryptographic key management—Policies and procedures are in place to organize the generation, change, revocation, destruction, distribution, certification, storage, entry, use and archiving of cryptographic keys to ensure the protection of keys against modification and © 2010 ISACA. All rights reserved. Page 10 Information Security Management Audit/Assurance Program unauthorized disclosure. DS5.9 Malicious software prevention, detection and correction—Preventive, detective and corrective measures are in place (especially up-to-date security patches and virus control) across the enterprise to protect information systems and technology from malware (e.g., viruses, worms, spyware, spam). DS5.10 Network security—Information security management is included in the selection, implementation and approval of security techniques and related management procedures (e.g., firewalls, security appliances, network segmentation, intrusion detection) to authorize access and control information flows from and to networks. DS5.11 Exchange of sensitive data—Information security has approved policies concerning the exchange of sensitive transaction data through a trusted path or medium with controls to provide authenticity of content, proof of submission, proof of receipt and nonrepudiation of origin. All incidents involving the exchange of sensitive data are reported through the incident reporting system and are directed to the CIRT team. Information security management is an integral part of the entire IT infrastructure. The Information Security Management Audit/Assurance Program cross-references numerous COBIT domains and processes. These sections appear in the COBIT cross-reference of the audit/assurance program. For the purposes of reporting, information security is a component of these areas, but the scope of the assessment would be too limited to include these sections in the summary of the information security management assessment. Refer to the ISACA publication COBIT Control Practices: Guidance to Achieve Control Objectives for Successful IT Governance, 2nd Edition, 2007, for the related control practice value and risk drivers. V. Executive Summary of Audit/Assurance Focus Information Security Management Information security is an essential component of governance and management that affects all aspects of entity-level controls. Audit and assurance professionals include appropriate information security evaluations throughout their audit universe. However, the process of assessing the design and operating effectiveness of information security management does not receive the focus it requires. The information security management function is responsible for the governance, policy, enforcement, monitoring and innovation necessary for the modern business to establish cost-effective information security processes, while providing adequate information security assurance within the risk appetite and budget of the organization. The information security management function provides: Management direction, including policy creation, involvement in significant information security strategies, establishment of and adherence to an information security architecture, and alignment of information security strategies with business strategies Management oversight and execution of essential information security operations. The former focuses on routine operations that affect information security, including access control; user identity management; and configuration management of other security building blocks, including intrusion detection and penetration testing systems, antimalware, and other processes. The latter includes information security incident management and security forensics. Management of information security technologies utilized within the organization © 2010 ISACA. All rights reserved. Page 11 Information Security Management Audit/Assurance Program Business Impact and Risk Information security touches all aspects of the business environment. Failure to implement adequate information security could result in the following operational issues: Security breaches, both detected and undetected Exposure of information Breach of trust with other enterprises Violations of legal and regulatory requirements Inadequate physical security measures Unauthorized external connections to remote sites Disclosure of corporate assets and sensitive information accessible to unauthorized parties Systems and data that are prone to malware Damage to the enterprise’s reputation Financial loss The risks associated with inadequate information security management include: Information security strategies not aligned with IT or business requirements Information security value (cost-benefit) structure not aligned with business needs or goals Undefined or confusing information security accountability Noncompliance with internal and external requirements Ineffective use of financial resources allocated to information security Information security not included in portfolio selection and maintenance and/or architecture design resulting in ineffective, inefficient or misguided information security solutions Information security not monitored and policies not applied uniformly with varying enforcement Information security is about minimizing exposures, based upon risk management. Failure to implement and monitor risk mitigation processes in one area may compromise the entire organization. Objective and Scope Objective—The information security management audit/assurance review will: Provide management with an assessment of the effectiveness of the information security management function Evaluate the scope of the information security management organization and determine whether essential security functions are being addressed effectively It is not designed to replace or focus on audits that provide assurance of specific configurations or operational processes. Scope—The review will focus on: Information Security Management—Processes associated with governance, policy, monitoring, incident management and management of the information security function Information Security Operations Management—Processes associated with the implementation of security configurations Information Security Technology Management—Processes associated with the selection and maintenance of security technologies To ensure a comprehensive audit of information security management, it is recommended that the following audit/assurance reviews be performed prior to the execution of the information security management review and that appropriate reliance be placed on these assessments: Identity management © 2010 ISACA. All rights reserved. Page 12 Information Security Management Audit/Assurance Program Security incident management Network perimeter security Systems development Project management IT risk management Data management Vulnerability management Minimum Audit Skills Information security management addresses many IT processes. Since the focus is on the management of information security, the audit and assurance professional should have the requisite knowledge of the scope and requirements of information security, governance of IT and the information security components therein, information security components of IT architecture, risk management, and the direct information security processes. In addition, this audit/assurance program addresses organizational human resource reporting, management planning and senior management interfaces. Therefore, it is recommended that the audit and assurance professional conducting the assessment have the requisite experience and organizational relationships to effectively execute the assurance processes. © 2010 ISACA. All rights reserved. Page 13 VI. Audit/Assurance Program 1. PLANNING AND SCOPING THE AUDIT 1.1 Define audit/assurance objectives. The audit/assurance objectives are high level and describe the overall audit goals. 1.1.1 Review the audit/assurance objectives in the introduction to this audit/assurance program. 1.1.2 Modify the audit/assurance objectives to align with the audit/assurance universe, annual plan and charter. 1.2 Define boundaries of review. The review must have a defined scope. The reviewer should understand the information security organization and function, and prepare a proposed scope, subject to a later risk assessment. 1.2.1 Obtain and review the information security organization chart and/or current job descriptions. 1.2.2 Obtain the information security organization charter (or a purpose, goals and objectives statement). 1.2.3 Obtain and review any previous audit reports with remediation plans. Identify open issues and assess updates of documents with respect to these issues. 1.2.4 Identify limitations and/or constraints affecting the audit of information security. 1.3 Identify and document risks. The risk assessment is necessary to evaluate where audit resources should be focused. In most enterprises, audit resources are not available for all processes. The risk-based approach assures utilization of audit resources in the most effective manner. 1.3.1 Identify the business risk associated with information security with business owners and key stakeholders. 1.3.2 Verify that the business risks are aligned, rated or classified with information security criteria such as confidentiality, integrity or availability. 1.3.3 Review previous audits of information security management and/or information security operations. 1.3.4 Determine whether issues identified previously have been remediated. 1.3.5 Evaluate the overall risk factor for performing the review. 1.3.6 Based on the risk assessment, identify changes to the scope. 1.3.7 Discuss the risks with IT management, and adjust the risk assessment. © 2010 ISACA. All rights reserved. Page 14 Monitoring Information and Communication Crossreference Control Activities COBIT Audit/Assurance Program Step Control Environment Risk Assessment COSO Reference Issue HyperCross- Comments link reference 1.3.8 Based on the risk assessment, revise the scope. 1.4 Define the change process. The initial audit approach is based on the reviewer’s understanding of the operating environment and associated risks. As further research and analysis are performed, changes to the scope and approach may result. 1.4.1 Identify the senior IT assurance resource responsible for the review. 1.4.2 Establish the process for suggesting and implementing changes to the audit/assurance program, and the authorizations required. 1.5 Define assignment success. The success factors need to be identified. Communication among the IT audit/assurance team, other assurance teams and the enterprise is essential. 1.5.1 Identify the drivers for a successful review (this should exist in the assurance function’s standards and procedures). 1.5.2 Communicate success attributes to the process owner or stakeholder, and obtain agreement. 1.6 Define the audit/assurance resources required. The resources required are defined in the introduction to this audit/assurance program. 1.6.1 Determine the audit/assurance skills necessary for the review. 1.6.2 Estimate the total audit/assurance resources (hours) and time frame (start and end dates) required for the review. 1.7 Define deliverables. The deliverable is not limited to the final report. Communication between the audit/assurance teams and the process owner is essential to assignment success. 1.7.1 Determine the interim deliverables, including initial findings, status reports, draft reports, due dates for responses or meetings, and the final report. 1.8 Communications The audit/assurance process must be clearly communicated to the customer/client. 1.8.1 Conduct an opening conference to: Discuss the review objectives with the information security management assessment Identify documents and information security resources required to effectively perform the review Establish timelines and deliverables © 2010 ISACA. All rights reserved. Page 15 Monitoring Information and Communication Crossreference Control Activities COBIT Audit/Assurance Program Step Control Environment Risk Assessment COSO Reference Issue HyperCross- Comments link reference Monitoring Information and Communication Crossreference Control Activities COBIT Audit/Assurance Program Step Control Environment Risk Assessment COSO Reference Issue HyperCross- Comments link reference 2. INFORMATION SECURITY MANAGEMENT 2.1 Management of IT Security Audit/Assurance Objective: Manage IT security at the highest appropriate organizational level so that the management of security actions is in line with business requirements. 2.1.1 Governance Control: Processes are in practice to assure applicable management oversight of the information security function. 2.1.1.1 Determine whether a security steering committee exists with representation from key functional areas, including internal audit, HR, finance, operations, IT security and legal. 2.1.1.2 Obtain the security steering committee charter. 2.1.1.3 Determine whether the committee membership is aligned with the organization and the information security stakeholders. 2.1.1.4 Obtain the minutes of selected steering committee meetings. 2.1.1.5 Determine whether the committee members regularly attend committee meetings. 2.1.1.6 Inquire whether and confirm that a security management communication process exists that informs the board, business and IT management of the status of information security. 2.1.1.7 Review the security steering committee charter to identify the communication plan and reporting relationships. Determine whether a common language (i.e., COBIT’s information criteria) is in the communication plan and that the reporting lines are clearly established. 2.1.1.8 Select several board meeting dates, obtain the information security presentations, and determine the board-level discussions relating to information security. 2.1.1.9 Inquire whether and confirm that an adequate organizational structure and reporting line for information security exist, and assess whether the security management and administration functions have sufficient authority. 2.1.1.10 Based on the organization chart of the information security organization, determine whether the structure provides for the information security function to report to and interface with the upper levels of management. © 2010 ISACA. All rights reserved. Page 16 PO4 DS5.1 ME4 x x x 2.1.1.5.1 2.1.1.5.7 2.1.1.5.2 2.1.1.5.3 2.1.1.5.4 2.1.1.5.5 2.1.1.5.6 2.1.1.5.8 2.1.1.11 Determine whether the placement of the information security function provides for appropriate independence, objectivity and authority over its constituencies to be effective. 2.1.1.12 Determine whether subordinate organizational hierarchy is adequate to provide appropriate policy definition and monitoring. 2.1.2 Risk Assessment Control: Risk assessments are regularly conducted to prioritize information security initiatives and ensure alignment with business risks. 2.1.2.1 Determine whether a process exists to prioritize proposed security initiatives and directives, including required levels of policies, standards and procedures. 2.1.2.2 Obtain recent risk assessment documents. 2.1.2.3 Determine whether the risk assessment has been utilized and addresses reasonable risks. 2.1.2.4 Determine whether the risk assessment is aligned with the IT risk assessment, if one exists, and the enterprise risk methodology, if one exists. 2.1.2.5 Test the design of the risk assessment for completeness, relevancy, timeliness and measurability. 2.1.3 Policies Control: Policies are created according to a defined format and are distributed following a distribution list based on subject matter and relevance, and the scope of the policies are appropriate to ensure that the information security is adequate to address the risk tolerance. 2.1.3.1 Determine whether and confirm that an information security charter exists. 2.1.3.2 Review and analyze the charter to verify that it refers to the organizational risk appetite relative to information security and that the charter clearly includes: Scope and objectives of the security management function Responsibilities of the security management function Compliance and risk drivers 2.1.3.3 Inquire whether and confirm that the information security policies cover the responsibility and accountability of the board, executive management, line © 2010 ISACA. All rights reserved. Page 17 PO9 DS5.2 ME4 x PO4 PO6 PO9 DS5.2 ME3 ME4 x x Monitoring Information and Communication Crossreference Control Activities COBIT Audit/Assurance Program Step Control Environment Risk Assessment COSO x x x x Reference Issue HyperCross- Comments link reference 2.1.3.1.1 2.1.3.1.7 2.1.3.1.2 2.1.3.1.3 2.1.3.1.4 2.1.3.1.5 2.1.3.1.6 2.1.3.1.8 Monitoring Information and Communication Crossreference Control Activities COBIT Audit/Assurance Program Step Control Environment Risk Assessment COSO management, staff members and all users of the enterprise IT infrastructure and that it refers to detailed security standards and procedures. 2.1.3.4 Inquire whether and confirm that detailed security policies, standards and procedures exist. Examples of policies, standards, procedures and best practices concerning these topics (COBIT, ISO27001/2) include: Security compliance policy Management risk acceptance (security noncompliance acknowledgement) External communications security policy Firewall policy E-mail security policy An agreement to comply with IS policies Laptop/desktop computer security policy Internet usage policy 2.2 IT Security Plan Audit/Assurance Objective: Translate business, risk and compliance requirements into an overall IT security plan, taking into consideration the IT infrastructure and the security culture. Ensure that the plan is implemented in security policies and procedures, together with appropriate investments in services, personnel, software and hardware. Communicate security policies and procedures to stakeholders and users. 2.2.1 Security Plan Integration Control: Information security requirements are integrated into other processes. © 2010 ISACA. All rights reserved. Page 18 PO1 PO2 PO3 PO4 PO6 PO9 AI1 AI2 DS1 DS2 DS4 DS5.2 DS9 DS12 x x x Reference Issue HyperCross- Comments link reference DS13 ME3 ME4 2.2.1.1 Determine whether a process exists to integrate information security requirements and implementation advice from the IT security plan into the development of service level agreements (SLAs) and operating level agreements (OLAs) (Refer to COBIT DS1 and DS2). 2.2.1.2 Review the SLAs and OLAs for an information security focus. Determine whether the information security function had been involved in the development of these SLAs/OLAs. 2.2.1.3 Determine whether a process exists to integrate information security requirements and implementation advice from the IT security plan into automated solution (AI1) and application (AI2) requirements. 2.2.1.4 Obtain systems development methodology documentation and determine whether information security involvement and review are required by the policies and procedures. 2.2.1.5 Select several high-risk and/or high-profile development projects. Obtain requirements documentation, and determine whether information security requirements were included in the project requirements documentation. 2.2.1.6 Determine whether information security resources were regularly involved in key information security decisions at appropriate points in the process. 2.2.1.7 Determine whether a process exists to integrate information security requirements and implementation advice from the IT security plan into the IT infrastructure components (AI3). 2.2.1.8 Obtain the IT infrastructure plan. 2.2.1.9 Determine whether the information security function is involved in the development of the security components of the IT infrastructure. 2.2.1.10 Determine whether the IT infrastructure team and the information security function routinely interface on common initiatives. 2.2.1.11 Determine whether the IT security plan addresses: IT tactical plans (PO1) data classification (PO2), technology standards (PO3), HR/user access policies, i.e., © 2010 ISACA. All rights reserved. Page 19 Monitoring Information and Communication Crossreference Control Activities COBIT Audit/Assurance Program Step Control Environment Risk Assessment COSO Reference Issue HyperCross- Comments link reference segregation of duties, key personnel, contractors (PO4), security and control policies (PO6), risk management (PO9), and external compliance requirements (ME3). 2.2.1.12 Obtain and review the IT security plan 2.2.1.13 Determine whether enterprise information security baselines for all major platforms are commensurate with the overall IT security plan, whether the baselines have been recorded in the configuration baseline (DS9) central repository and whether a process exists to periodically update the baselines based on changes in the plan. 2.2.1.14 Determine that information security issues are included in the IT continuity plan. 2.2.2 Security Plan Maintenance Control: The security plan is reviewed on a regular basis to determine that it is updated to reflect changes to the operating environment and new threats. 2.2.2.1 Determine the effectiveness of the collection and integration of information security requirements into an overall IT security plan that is responsive to the changing needs of the organization. 2.2.2.2 Determine whether the appropriate triggers are built into the interfaces between IT, business units and the information security organization to ensure that there is timely notification of a need to update the information security plan. 2.2.2.3 Determine whether a process exists to periodically update the IT security plan and whether the process requires appropriate levels of management review and approval of changes 2.2.2.4 Determine the review process for updating the IT security plan; consider: Quality of documentation including security policies Approval process of changes Job functions involved in the review process 3. INFORMATION SECURITY OPERATIONS 3.1 Identity Management Audit/Assurance Objectives: The information security function has defined policies and monitors © 2010 ISACA. All rights reserved. Page 20 AI2 AI3 DS4 DS5.2 DS9 DS12 DS13 x x Monitoring Information and Communication Crossreference Control Activities COBIT Audit/Assurance Program Step Control Environment Risk Assessment COSO Reference Issue HyperCross- Comments link reference activities relating to the following: Ensure that all users (internal, external and temporary) and their activity on IT systems (business application, IT environment, system operations, development and maintenance) are uniquely identifiable. Enable user identities via authentication mechanisms. Confirm that user access rights to systems and data are in line with defined and documented business needs and that job requirements are attached to user roles. Ensure that user access rights are requested by user management, approved by system owners and implemented by the person responsible for security. Ensure that information security operations functions maintain user roles and access rights in a central repository. Deploy cost-effective technical and procedural measures, and keep them current to establish user identification, implement authentication and enforce access rights. 3.1.1 Identity Management Control: The information security function has established identity management policies and monitoring functions. 3.1.1.1 Determine the role of the information security function relating to identity management. If the information security function establishes policy and monitors enforcement, the remainder of this section needs to be reviewed from a definition and monitoring perspective. If the information security function also performs the information security operations, the assessment must include the tests of the operational follow-through. 3.1.1.2 Determine whether security policies require users and system processes to be uniquely identifiable and systems to be configured to enforce authentication before access is granted. 3.1.1.3 If policies require predetermined and preapproved roles to grant access, determine whether the policies require the roles to clearly delineate responsibilities based on least privileges and ensure that the establishment and modification of roles are approved by process owner management. 3.1.1.4 Determine whether appropriate policies and monitoring have been implemented to control access provisioning and whether authentication control mechanisms are utilized for controlling logical access across all users, system processes and IT resources for in-house and remotely managed users, processes and systems. © 2010 ISACA. All rights reserved. Page 21 DS5.3 DS11.6 DS12 ME4 x Monitoring Information and Communication Crossreference Control Activities COBIT Audit/Assurance Program Step Control Environment Risk Assessment COSO x Reference Issue HyperCross- Comments link reference 3.1.2 Identity Management Operations Control: Identity management policies are enforced, and appropriate review processes are in place to evaluate their operating effectiveness. x x x PO4 DS5.4 ME3 ME4 x x x Crossreference Monitoring Information and Communication DS5.3 ME1 ME2 ME3 COBIT Audit/Assurance Program Step Control Environment Risk Assessment Control Activities COSO 3.1.2.1 Determine whether a previous audit/assurance assessment of the identity management system has been performed. 3.1.2.2 If an audit/assurance assessment has been performed recently, as defined by internal audit procedures, review the findings of that review, and determine whether additional findings, including failure to complete previous open recommendations, are appropriate. 3.1.2.2.1 If an assessment has not been performed, consider using the ISACA Identity Management Audit/Assurance Program to complete a detailed review. 3.1.2.2.2 If an assessment has been performed, but not within the internal audit definition of “recent,” consider reperforming key control process to update the assessment and provide current findings. 3.1.2.3 Determine whether the information security function performs annual assessments of identity management operations and receives timely reports/scorecards of identity management operations activities. 3.1.2.4 Determine whether the information security function has routinely monitored and evaluated the effectiveness of identity management operations. 3.2 Account Management Audit/Assurance Objective: The information security function has established policies and monitoring procedures that address: requesting, establishing, issuing, suspending, modifying and closing user accounts and related user privileges with a set of user account management procedures. The process includes an approval procedure outlining the data or system owner granting the access privileges and applies to all users, including administrators (privileged users); internal and external users; normal and emergency cases; and system, shared and generic accounts. 3.2.1 User Account Management Policy Control: The information security function has established policies and monitoring procedures to ensure the effectiveness of user account management controls. © 2010 ISACA. All rights reserved. Page 22 Reference Issue HyperCross- Comments link reference © 2010 ISACA. All rights reserved. Page 23 DS5.4 ME1 ME2 x x Monitoring Information and Communication 3.2.1.1 Obtain the information security policy addressing user account management. 3.2.1.2 Determine whether procedures exist to periodically assess and recertify system and application access and authorities. 3.2.1.3 Determine whether access control procedures exist to control and manage system and application rights and privileges according to the organization’s security policies and compliance and regulatory requirements. 3.2.1.4 Determine whether user provisioning policies, standards and procedures extend to all system users and processes, including vendors, service providers and business partners. 3.2.1.5 Determine whether a data classification policy is in place. 3.2.1.5.1 Ensure that the protection controls implemented are adequate for the classification of data (refer to the classification of data policy). 3.2.1.5.2 Determine whether the data classification affecting information security is reviewed periodically. 3.2.1.5.3 Determine whether systems, applications and data have been classified by levels of importance and risk and whether process owners have been identified and assigned. 3.2.2 User Account Management Operations Control: The information security function monitors the control effectiveness of user account management operations on a timely basis and reports the operating efficiency and effectiveness. 3.2.2.1 Obtain management reports for user account management. 3.2.2.2 Assess the level of information security oversight for the operational aspects of user account management. 3.2.2.3 Determine whether a previous audit/assurance assessment of the user account management has been performed. 3.2.2.3.1 If an assessment has been performed recently, as defined by internal audit procedures, review the findings of that review, and determine whether additional findings, including failure to complete previous open recommendations are appropriate. Crossreference Control Activities COBIT Audit/Assurance Program Step Control Environment Risk Assessment COSO x Reference Issue HyperCross- Comments link reference Monitoring Information and Communication Crossreference Control Activities COBIT Audit/Assurance Program Step Control Environment Risk Assessment COSO 3.2.2.3.2 If an assessment has not been performed, consider using the ISACA User Account Management Audit/Assurance Program to complete a detailed review. 3.2.2.3.3 If an assessment has been performed, but not within the internal audit definition of “recent,” consider reperforming key control process to update the assessment and provide current findings. 3.3 Security Testing and Monitoring Audit/Assurance Objective: The IT security implementation is tested and monitored in a proactive way. IT security is reaccredited in a timely manner to ensure that the approved enterprise information security baseline is maintained. A logging and monitoring function enables the early prevention and/or detection and subsequent timely reporting of unusual and/or abnormal activities that may need to be addressed. 3.3.1 Testing Control: Routine testing of information-security-related controls is performed in accordance with regulatory requirements and risk assessments that have identified high risk or vulnerable assets. 3.3.1.1 Determine whether security baselines exist for all IT resources utilized by the organization. 3.3.1.2 Determine whether the baselines are based upon best practices (COBIT, ISO27001/2 and/or ITIL). If not, determine the rationale for in-house-developed baselines. 3.3.1.3 Determine whether appropriate testing is performed to validate adherence to minimum baselines. 3.3.1.4 Determine whether testing of information security assets are in conformance with compliance requirements. 3.3.1.4.1 Determine whether the regulatory compliance requirements have been documented. 3.3.1.4.2 Assess the completeness of the regulatory compliance. 3.3.1.4.3 Evaluate whether additional testing is required to be in compliance with regulatory requirements. 3.3.2 Monitoring Control: Key information security controls are monitored on a regular and timely basis. © 2010 ISACA. All rights reserved. Page 24 DS5.5 PO9.4 PO9.5 ME4 PO8 DS5.5 ME1 ME2 x x x x x x Reference Issue HyperCross- Comments link reference x x x DS5.6 DS8 ME2 ME3 x x x Crossreference Monitoring Information and Communication DS5.6 DS8 ME4 COBIT Audit/Assurance Program Step Control Environment Risk Assessment Control Activities COSO 3.3.2.1 Determine whether all organization-critical, higher-risk network assets are routinely monitored for security events. 3.3.2.2 Determine whether the IT security management function has been integrated within the organization’s project management initiatives to ensure that security is considered in all IT projects. 3.4 Security Incident Management Audit/Assurance Objective: The security incident management process is defined and monitored by the information security function, and an incident response team has been established and is operationally effective. 3.4.1 Incident Management Definition Control: An incident management policy has been established that defines the classification of information security incidents and the actions to be executed when an information security incident is identified, and the process has been communicated to units who are first responders. 3.4.1.1 Determine whether the security incident management process appropriately interfaces with key organization functions, including the help desk, external service providers and network management. 3.4.1.2 Evaluate whether the security incident management process includes the following key elements: Event detection and classification Correlation of events and evaluation of threat/incident Resolution of threat, or creation and escalation work order Criteria for initiating the organization’s incident response process Who has authority to declare an incident Escalation procedures Verification and required levels of documentation of the resolution Postremediation analysis Work order/incident closure 3.4.2 Incident Management Response Team Control: A CIRT has been established; manages emergencies; and reports the existence, cause and effect, damage assessment, and closure to the information security function. © 2010 ISACA. All rights reserved. Page 25 Reference Issue HyperCross- Comments link reference 3.4.3.1 Obtain the incident logs for a representative period of time. 3.4.3.2 Trace a representative sample of incidents per the incident/problem reporting system to the CIRT management documentation to determine that all security-related incidents have been reported to the CIRT. © 2010 ISACA. All rights reserved. Page 26 PO8 DS5.6 ME1 ME2 x x Monitoring Information and Communication 3.4.2.1 Determine whether a CIRT exists to recognize and effectively manage security incidents. The following areas should exist as part of an effective CIRT process: Incident handling—General and specific procedures and other requirements to ensure effective handling of incidents and reported vulnerabilities Vendor relations—The role and responsibilities of vendors in incident prevention and follow-up, software flaw correction, and other areas Communications—Requirements, implementation and operation of emergency and routine communications channels among key members of management Legal and criminal investigative issues—Issues driven by legal considerations and the requirements or constraints resulting from the involvement of criminal investigative organizations during an incident Constituency relations—Response center support services and methods of interaction with constituents, including training and awareness, configuration management, and authentication Research agenda and interaction—Identification of existing research activities and requirements and rationale for needed research relating to response center activities Model of the threat—Development of a basic model that characterizes potential threats and risks to help focus risk reduction activities and progress in those activities External issues—Factors that are outside the direct control of the enterprise (e.g., legislation, policy, procedural requirements), but that could affect the operation and effectiveness of enterprise activities Postincident evaluation—CIRT assessment of incident response and recommended changes to the CIRT process 3.4.3 Incident Management Response Team Monitoring Control: The information security function actively monitors CIRT activities and reports incidents and appropriate analyzes direct reports. Crossreference Control Activities COBIT Audit/Assurance Program Step Control Environment Risk Assessment COSO x Reference Issue HyperCross- Comments link reference 3.4.3.3 Review the CIRTs for a representative period. Determine that: The response was timely The incident severity met the conditions for the response The remediation process closed the issue A risk assessment was performed, and a reasonable remediation process was executed An impact assessment was completed Escalation procedures, including the notification of affected parties, management and legal authorities were completed in conformance with the escalation policy The summary of activities was reported to the appropriate governance committees 3.4.4 Incident Management Assessment Control: Perform an assurance assessment of the security incident management processes. PO8 DS5.6 ME1 x 3.4.4.1 Determine whether a previous audit/assurance assessment of the incident management process has been performed. 3.4.4.1.1 If an assessment has been performed recently, as defined by internal audit procedures, review the findings of that review and determine whether additional findings, including failure to complete previous open recommendations are appropriate. 3.4.4.1.2 If an assessment has not been performed, consider using the ISACA Incident Management Audit/Assurance Program to complete a detailed review. 3.4.4.1.3 If an assessment has been performed, but within the internal audit definition of “recent” consider reperforming key control process to update the assessment and provide current findings. 4. INFORMATION SECURITY TECHNOLOGY MANAGEMENT 4.1 Protection of Security Technology Audit/Assurance Objective: The information security processes ensure that security-related technology is resistant to tampering, and that documentation is only accessible to authorized individuals. 4.1.1 Security Technology Policy Control: The information security function has defined the policies governing specific access control processes. © 2010 ISACA. All rights reserved. Page 27 DS5.7 DS9 DS11.2 DS12 x x Monitoring Information and Communication Crossreference Control Activities COBIT Audit/Assurance Program Step Control Environment Risk Assessment COSO x Reference Issue HyperCross- Comments link reference Monitoring Information and Communication Crossreference Control Activities COBIT Audit/Assurance Program Step Control Environment Risk Assessment COSO ME4 4.1.1.1 Inquire whether and confirm that policies and procedures have been established to address security breach consequences (specifically to address controls to configuration management, application access, data security and physical security requirements). 4.1.1.2 Obtain the policies concerning security breaches. 4.1.1.3 Determine whether appropriate disciplinary measures have been defined. 4.1.1.4 Inquire whether and confirm that the policies require annual management reviews of security features for physical and logical access to files and data. 4.1.1.5 Obtain the policies documentation. 4.1.1.6 Determine whether the policies require management reviews of security features. 4.1.1.7 Determine how the management review is documented and reported. 4.1.1.8 Determine how follow-up activities are addressed. 4.1.1.9 Inquire whether and confirm that the policies require security design features that facilitate password rules (e.g., maximum length, characters, expiration, reuse). 4.1.1.10 Obtain the policies for password rules. 4.1.1.11 Determine whether the policies are appropriate. 4.1.1.12 Determine whether data classification and job function sensitivity are a component of and affect the security design process. 4.1.2 Security Technology Monitoring Control: Information security monitors the security technology processes to ensure adherence. 4.1.2.1 Inspect security reports generated from system tools preventing network penetration vulnerability attacks. 4.1.2.2 Verify that information security monitors information security processes that report access authorization and approvals. 4.1.2.3 Verify that information security policy monitors the regular management reviews of security features for physical and logical access to files and data. 4.1.2.4 Verify that information security receives summary reports of the activities controlling granting and approving access and logging unsuccessful attempts, lockouts, authorized © 2010 ISACA. All rights reserved. Page 28 DS5.7 ME1 ME2 x x x Reference Issue HyperCross- Comments link reference access to sensitive files and/or data, and physical access to facilities. Verify that the information security function investigates repeat offenders and high-risk situations. 4.2 Cryptographic Key Management Audit/Assurance Objective: Policies and procedures are in place to organize the generation, change, revocation, destruction, distribution, certification, storage, entry, use and archiving of cryptographic keys to ensure the protection of keys against modification and unauthorized disclosure. 4.2.1 Key Management Control: Key management systems are implemented to protect sensitive information and to implement mutual authentication. 4.2.1.1 Determine whether an encryption key management role has been established to manage the process of reviewing, distributing and disposing of keys. 4.2.1.1.1 Determine whether this role is segregated from other responsibilities and has a trained backup. 4.2.1.2 Assess whether controls over private keys exist to enforce their confidentiality and integrity. Consideration should be given to the following: Storage of private signing keys within secure cryptographic devices Private keys not exported from a secure cryptographic module Private keys backed up, stored and recovered only by authorized personnel using dual control in a physically secured environment 4.2.1.3 Determine whether a defined key life cycle management process exists. The process should include: Minimum key sizes required for the generation of strong keys Use of required key generation algorithms Identification of required standards for the generation of keys Purposes for which keys should be used and restricted Allowable usage periods or active lifetimes for keys Acceptable methods of key distribution Key backup, archival and destruction 4.3 Malicious Software Prevention, Detection and Correction Audit/Assurance Objective: Preventive, detective and corrective measures are in place (especially up-to-date security patches and virus control) across the organization to protect information © 2010 ISACA. All rights reserved. Page 29 DS5.8 x Monitoring Information and Communication Crossreference Control Activities COBIT Audit/Assurance Program Step Control Environment Risk Assessment COSO Reference Issue HyperCross- Comments link reference Monitoring Information and Communication Crossreference Control Activities COBIT Audit/Assurance Program Step Control Environment Risk Assessment COSO Reference Issue HyperCross- Comments link reference systems and technology from malware (e.g., viruses, worms, spyware, spam). 4.3.1 Malicious Software Prevention, Detection and Correction Policy Control: Policies have been implemented to prevent, detect and remove malicious software. 4.3.1.1 Inquire whether and confirm that a malicious software prevention policy is established, documented and communicated throughout the organization. 4.3.1.2 Ensure that policies address the implementation of automated controls to provide virus protection and that violations are appropriately communicated. 4.3.1.3 Inquire whether and confirm that policies require that protection software be centrally distributed (version and patch-level) using a centralized configuration and change management process. 4.3.1.4 Determine whether information security patch management implementation adheres to manufacturer and external/outsourced provider requirements/recommendations. 4.3.2 Malicious Software Prevention, Detection and Correction Operating Effectiveness Control: Monitoring processes have been established to report the effectiveness of and incidents occurring from malicious software. 4.3.2.1 Inquire whether key staff members are aware of the malicious software prevention policy and their responsibility for ensuring compliance. 4.3.2.2 From a sample of user workstations, observe whether a virus protection tool has been installed and includes virus definition files and the last time the definitions were updated. 4.3.2.3 Review the distribution process against a known, up-to-date inventory to determine the operating effectiveness. 4.3.2.4 Determine the review and evaluation process by information security to monitor the operating effectiveness of the malicious software filtering process. 4.3.2.4.1 Verify whether there are processes in place for the information security function to assess the competency and training of the malware team to ensure that current threats are addressed. © 2010 ISACA. All rights reserved. Page 30 PO6 DS2 DS5.9 ME1 ME2 PO6 DS5.9 ME1 ME2 x x x x x x x 4.3.2.4.2 4.3.2.4.8 4.3.2.4.3 4.3.2.4.4 4.3.2.4.5 4.3.2.4.6 4.3.2.4.7 4.3.2.4.9 4.3.2.5 Review the filtering process to determine operating effectiveness, or review the automated process established for filtering purposes. 4.3.2.6 Determine whether routine internal/external vulnerability scans are performed. 4.3.2.6.1 Review the evaluation/assessment process of the scan results. 4.3.2.7.1 Review the evaluation/assessment process of the penetration testing results. 4.4.1.1 Inquire whether and confirm that network security policies (e.g., provided services, allowed traffic, types of connections permitted) have been established with the approval of and monitored by the information security function. 4.4.1.2 Determine whether a previous audit/assurance assessment of the network perimeter process has been performed. 4.4.1.2.1 If an assessment has been performed recently, as defined by internal audit procedures, review the findings of that review, and determine if additional findings, including failure to complete previous open recommendations, are appropriate. 4.4.1.2.2 If an assessment has not been performed, consider using the ISACA Network Perimeter Audit/Assurance Program to complete a detailed review. 4.4.1.2.3 If an assessment has been performed, but not within the internal audit definition of “recent,” consider reperforming key control process to update the assessment and provide current findings. © 2010 ISACA. All rights reserved. Page 31 Monitoring Reference Issue HyperCross- Comments link reference 4.3.2.6.2 4.3.2.7 Determine whether penetration testing is performed. 4.4 Network Security Audit/Assurance Objective: Information security management is included in the selection, implementation and approval of security techniques and related management procedures (e.g., firewalls, security appliances, network segmentation, intrusion detection) to authorize access and control information flows from and to networks. 4.4.1 Network Security Control: Information security management is actively involved and approves network security policies. Information and Communication Crossreference Control Activities COBIT Audit/Assurance Program Step Control Environment Risk Assessment COSO DS1 DS5.10 DS9 ME2 ME3 ME4 4.3.2.6.8 4.3.2.6.3 4.3.2.6.4 4.3.2.6.5 4.3.2.6.6 4.3.2.6.7 4.3.2.6.9 4.3.2.8 4.3.2.9 4.3.2.10 4.3.2.11 4.3.2.12 4.3.2.13 4.3.2.14 4.3.2.15 4.3.2.1 4.3.2.17 4.3.2.18 4.3.2.19 4.3.2.20 4.3.2.21 4.3.2.22 4.3.2.23 4.3.2.24 4.3.2.2 x x x Monitoring Information and Communication Crossreference Control Activities COBIT Audit/Assurance Program Step Control Environment Risk Assessment COSO 4.4.1.3 Inquire whether and confirm that information security policies have been implemented such that corporate data is classified according to exposure level and classification scheme (e.g., confidential, sensitive). 4.4.1.4 Determine that sensitive data incidents have been reported to information security management. 4.4.1.4.1 Scan the problem log, identifying sensitive data incidents. 4.4.1.4.2 Trace the incident through the CIRT process to management reports. 4.5 Exchange of Sensitive Data Audit/Assurance Objective: Information security has approved policies concerning exchange of sensitive transaction data through a trusted path or medium with controls to provide authenticity of content, proof of submission, proof of receipt and nonrepudiation of origin. All incidents involving the exchange of sensitive data are reported through the incident reporting system and are directed to the CIRT team. 4.5.1 Exchange of Sensitive Data Control: Information security management is actively involved and approves exchange of sensitive data policies. 4.5.1.1 Inquire whether and confirm that policies addressing data transmissions outside the organization require an encrypted format prior to transmission. 4.5.1.2 Inquire whether and confirm that information security policies have been implemented such that corporate data are classified according to exposure level and classification scheme (e.g., confidential, sensitive). 4.5.1.3 Determine that sensitive data incidents have been reported to information security management. 4.5.1.4 Scan the problem log, identifying sensitive data incidents. 4.5.1.5 Trace the incident through the CIRT process to management reports. © 2010 ISACA. All rights reserved. Page 32 DS5.11 x x x Reference Issue HyperCross- Comments link reference VII. Maturity Assessment The maturity assessment is an opportunity for the reviewer to assess the maturity of the processes reviewed. Based on the results of audit/assurance review, and the reviewer’s observations, assign a maturity level to each of the following COBIT control practices. Assessed Maturity COBIT Control Practice DS5.1 Management of IT Security 1.Define a charter for IT security, defining for the security management function: Scope and objectives for the security management function Responsibilities Drivers (e.g., compliance, risk, performance) 2. Confirm that the board, executive management and line management direct the policy development process to ensure that the IT security policy reflects the requirements of the business 3. Set up an adequate organisational structure and reporting line for information security, ensuring that the security management and administration functions have sufficient authority. Define the interaction with enterprise functions, particularly the control functions such as risk management, compliance and audit. 4. Implement an IT security management reporting mechanism, regularly informing the board and business and IT management of the status of IT security so that appropriate management actions can be taken. DS5.2 IT Security Plan 1. Define and maintain an overall IT security plan that includes: A complete set of security policies and standards in line with the established information security policy framework Procedures to implement and enforce the policies and standards Roles and responsibilities Staffing requirements Security awareness and training Enforcement practices Investments in required security resources 2. Collect information security requirements from IT tactical plans (PO1), data classification (PO2), technology standards (PO3), security and control policies (PO6), risk management (PO9), and external compliance requirements (ME3) for integration into the overall IT security plan. 3. Translate the overall IT security plan into enterprise information security baselines for all major platforms and integrate it into the configuration baseline (DS9). © 2010 ISACA. All rights reserved. Page 33 Reference Target HyperComments Maturity link COBIT Control Practice 4. Provide information security requirements and implementation advice to other processes, including the development of SLAs and OLAs (DS1 and DS2), automated solution requirements (AI1), application software (AI2), and IT infrastructure components (AI3). 5. Communicate to all stakeholders and users in a timely and regular fashion on updates of the information security strategy, plans, policies and procedures. Assessed Maturity DS5.3 Identity Management 1. Establish and communicate policies and procedures to uniquely identify, authenticate and authorise access mechanisms and access rights for all users on a need-to-know/need-to-have basis, based on predetermined and preapproved roles. Clearly state accountability of any user for any action on any of the systems and/or applications involved. 2. Ensure that roles and access authorisation criteria for assigning user access rights take into account: Sensitivity of information and applications involved (data classification) Policies for information protection and dissemination (legal, regulatory, internal policies and contractual requirements) Roles and responsibilities as defined within the enterprise The need-to-have access rights associated with the function Standard but individual user access profiles for common job roles in the organisation Requirements to guarantee appropriate segregation of duties 3. Establish a method for authenticating and authorising users to establish responsibility and enforce access rights in line with sensitivity of information and functional application requirements and infrastructure components, and in compliance with applicable laws, regulations, internal policies and contractual agreements. 4. Define and implement a procedure for identifying new users and recording, approving and maintaining access rights. This needs to be requested by user management, approved by the system owner and implemented by the responsible security person. 5. Ensure that a timely information flow is in place that reports changes in jobs (i.e., people in, people out, people change). Grant, revoke and adapt user access rights in co-ordination with human resources and user departments for users who are new, who have left the organisation, or who have changed roles or jobs. DS5.4 User Account Management 1. Ensure that access control procedures include but are not limited to: Using unique user IDs to enable users to be linked to and held accountable for their actions Awareness that the use of group IDs results in the loss of individual accountability and are permitted only when justified for business or operational reasons and compensated by mitigating controls. Group IDs must be approved and documented © 2010 ISACA. All rights reserved. Page 34 Reference Target HyperComments Maturity link COBIT Control Practice Checking that the user has authorisation from the system owner for the use of the information system or service, and the level of access granted is appropriate to the business purpose and consistent with the organisational security policy A procedure to require users to understand and acknowledge their access rights and the conditions of such access Ensuring that internal and external service providers do not provide access until authorisation procedures have been completed Maintaining a formal record, including access levels, of all persons registered to use the service A timely and regular review of user IDs and access rights 2. Ensure that management reviews or reallocates user access rights at regular intervals using a formal process. User access rights should be reviewed or reallocated after any job changes, such as transfer, promotion, demotion or termination of employment. Authorisations for special privileged access rights should be reviewed independently at more frequent intervals. Assessed Maturity DS5.5 Security Testing, Surveillance And Monitoring 1. Implement monitoring, testing, reviews and other controls to: Promptly prevent/detect errors in the results of processing Promptly identify attempted, successful and unsuccessful security breaches and incidents Detect security events and thereby prevent security incidents by using detection and prevention technologies Determine whether the actions taken to resolve a breach of security are effective 2. Conduct effective and efficient security testing procedures at regular intervals to: Verify that identity management procedures are effective Verify that user account management is effective Validate that security-relevant system parameter settings are defined correctly and are in compliance with the information security baseline Validate that network security controls/settings are configured properly and are in compliance with the information security baseline Validate that security monitoring procedures are working properly Consider, where necessary, obtaining expert reviews of the security perimeter DS5.6 Security Incident Definition 1. Describe what a security incident is considered to be. Document within the characteristics a limited number of impact levels to allow commensurate response. Communicate and distribute this information, or relevant parts thereof, to identified people who need to be © 2010 ISACA. All rights reserved. Page 35 Reference Target HyperComments Maturity link COBIT Control Practice notified. 2. Ensure that security incidents and appropriate follow-up actions, including root cause analysis, follow the existing incident and problem management processes. 3. Define measures to protect confidentiality of information related to security incidents. Assessed Maturity DS5.7 Protection Of Security Technology 1. Ensure that all hardware, software and facilities related to the security function and controls, e.g., security tokens and encryptors, are tamperproof. 2. Secure security documentation and specifications to prevent unauthorised access. However, do not make security of systems reliant solely on secrecy of security specifications. 3. Make the security design of dedicated security technology (e.g., encryption algorithms) strong enough to resist exposure, even if the security design is made available to unauthorised individuals. 4. Evaluate the protection mechanisms on a regular basis (at least annually) and perform updates to the protection of the security technology, if necessary. DS5.8 Cryptographic Key Management 1. Ensure that there are appropriate procedures and practices in place for the generation, storage and renewal of the root key, including dual custody and observation by witnesses. 2. Make sure that procedures are in place to determine when a root key renewal is required (e.g., the root key is compromised or expired). 3. Create and maintain a written certification practice statement that describes the practices that have been implemented in the certification authority, registration authority and directory when using a public-key-based encryption system. 4. Create cryptographic keys in a secure manner. When possible, enable only individuals not involved with the operational use of the keys to create the keys. Verify the credentials of key requestors (e.g., registration authority). 5. Ensure that cryptographic keys are distributed in a secure manner (e.g., offline mechanisms) and stored securely, that is: In an encrypted form regardless of the storage media used (e.g., write-once disk with encryption) With adequate physical protection (e.g., sealed, dual custody vault) if stored on paper 6. Create a process that identifies and revokes compromised keys. Notify all stakeholders as soon as possible of the compromised key. 7. Verify the authenticity of the counterparty before establishing a trusted path. DS5.9 Malicious Software Prevention, Detection And Correction 1. Establish, document, communicate and enforce a malicious software prevention policy in the organisation. Ensure that people in the organisation are aware of the need for protection © 2010 ISACA. All rights reserved. Page 36 Reference Target HyperComments Maturity link COBIT Control Practice against malicious software, and their responsibilities relative to same. 2. Install and activate malicious software protection tools on all processing facilities, with malicious software definition files that are updated as required (automatically or semiautomatically). 3. Distribute all protection software centrally (version and patch-level) using centralised configuration and change management. 4. Regularly review and evaluate information on new potential threats. 5. Filter incoming traffic, such as e-mail and downloads, to protect against unsolicited information (e.g., spyware, phishing e-mails). Assessed Maturity DS5.10 Network Security 1. Establish, maintain, communicate and enforce a network security policy (e.g., provided services, allowed traffic, types of connections permitted) that is reviewed and updated on a regular basis (at least annually). 2. Establish and regularly update the standards and procedures for administering all networking components (e.g., core routers, DMZ, VPN switches, wireless). 3. Properly secure network devices with special mechanisms and tools (e.g., authentication for device management, secure communications, strong authentication mechanisms). Implement active monitoring and pattern recognition to protect devices from attack. 4. Configure operating systems with minimal features enabled (e.g., features that are necessary for functionality and are hardened for security applications). Remove all unnecessary services, functionalities and interfaces (e.g., graphical user interface [GUI]). Apply all relevant security patches and major updates to the system in a timely manner. 5. Plan the network security architecture (e.g., DMZ architectures, internal and external network, IDS placement and wireless) to address processing and security requirements. Ensure that documentation contains information on how traffic is exchanged through systems and how the structure of the organisation’s internal network is hidden from the outside world. 6. Subject devices to reviews by experts who are independent of the implementation or maintenance of the devices. DS5.11 Exchange Of Sensitive Data 1. Determine by using the established information classification scheme how the data should be protected when exchanged. 2. Apply appropriate application controls to protect the data exchange. 3. Apply appropriate infrastructure controls, based on information classification and technology in use, to protect the data exchange. © 2010 ISACA. All rights reserved. Page 37 Reference Target HyperComments Maturity link VIII. Assessment Maturity vs. Target Maturity This spider graph is an example of the assessment results and maturity target for a specific company. DS5.1 Management of IT Security 5 DS5.11 Exchange of Sensitive Data DS5.2 IT Security Plan 4 3 DS5.10 Network Security DS5.3 Identity Management 2 1 0 DS5.9 Malicious Software Management DS5.4 User Account Management DS5.8 Cryptographic Key Management DS5.5 Security Testing and Monitoring DS5.7 Protection of Security Technology DS5.6 Security Incident Definition Assessment Target © 2010 ISACA. All rights reserved. Page 38