Page 13 - Internal Auditor M.E. (English) - June 2018
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information Security





          •  Sign-off of user acceptance policy, including all information   Auditing ISR version 2
           security policies.
                                                            ISR is a regulatory document which defines information
          These steps are a prelude to the requirements to involve   security law in the UAEs. This means planning ISR auditing
          management and enforcement of policies and procedures for   needs to consider:
          all domains. Hence, ISR version 2 governance requirements
          provide that Director-General or CEO, together with   •  Law and regulations (Reference: ISR version 2 Section 11.1
          divisional managers or heads, be involved in the ISSC   Compliance with Federal and Local Government Legal
          as participants. The idea is to actively involve them in   Requirements).
          ISR implementation activities. This requires effort in the   • Internal DGE policies and procedures.
          following spheres.
                                                            • Other information security standards implemented.
                                                            These additional considerations add a burden on audit
           Booking time   Defining   Keeping   Ensuring   Documenting   planning, with the auditor needing to cross-match these
           of Director-  specific   the ISSC   informed   meeting results   inputs to develop an audit plan incorporating regulatory
           General and   items in   members   and timely   and decisions
           department   the ISSC   updated on   decision-  to make sure   requirements.
            heads on a   agenda   issues to be   making   actions are
           regular basis  to be   discussed  occurs   implemented in   ISR audit in action
                      discussed         at ISSC   a timely way
                                        meetings            A specific approach to ISR audit planning is required to
                                                            ensure the audit does not miss any vital part of related
          Governance                                        legislation. The audit approach has to factor in specifics of the
                                                            DGE being audited. Audit clients tend to be critical of auditor
          Good governance requires performance measures (KPIs) to   approach and lack of subject matter knowledge. A cyclical
          be identified that link desired outputs and outcomes. For   audit approach such as shown in the following diagram can be
          example, Directors-General may not know intimately capacity   useful to ensure focus on the audit objectives.
          management, but if a KPI figure is 80% and this is exceeded,
          then early warning is achieved.                                Allocate tasks   Build asset
                                                                         as per action   register with
                                                                          plan and
                                                                                          the active
          Another change is Chief Information Security Officer (CISO)   identify points   involvement
          reporting to the Director-General or ISSC, which represents    to proceed      of information
          a change from ISR version 1 to ISR version 2. This is aimed    for next audit   system users
          at providing a CISO with direct access to decision-making        cycle
          senior management. ISR version 2 provides “A capable   Prepare                             Conduct risk
          and independent position should take the responsibility of   comprehensive                  assessment
                                                                                                      with actual
                                                             audits reports
          managing information security”. On a practical front, this   (ISSC, IS, IT,                 examples
          change may bring challenges on how to enforce it, which   and Action                        information
          could be in the form of:                             Plan)                                  system users
          • Redesign of information security policies and procedures.            Cyclical
                                                                                  Audit
          • Modification of CISO job description.                               Approach
          •  Adjustment of job descriptions for information security   Conduct Audit                  Ensure users
           department staff                                  and capture                             participation
                                                             specific users                          in information
                                                                                                       security
                                                             concerns in
          • Addition of ISSC tasks.                          information                              awareness
          •  Formulating report templates and formalizing periodic and   security                      training
                                                              controls
                                                                                                       sessions
           routine tasks.
                                                                         Prepare audit   Ensure users
                                                                                          sign off on
          Risk assessment                                                questionnaire   information
                                                                         specifically      security
          As a vital part of ISR governance aspect, risk assessment is   design for each   policies
          required for two main objectives. The first is to refine existing   department of
                                                                          the DGE
          policies and procedures on a regular basis. The second is
          define how to cap effort in the internal audit plan for audit of
          high-risk areas that require considerable audit effort.  Planning for an ISR audit
          Cloud computing introduces a new set of risk and control   ISR version 2 implementation comes with laws and
          implications. ISR version 2 has added a new domain to cater   regulations to consider. For this reason, planning an ISR
          for cloud security. For security reasons, cloud services are to   audit can involve numerous sources which are shown in the
          be provided only though local UAE companies with no data   diagram below. Auditors will use a risk assessment to help
          stored offshore. While cloud security may not apply to some   plan their audit. They also need to consider laws that apply to
          DGEs, the requirement is to have cloud services contracted to   every department at the DGE. SUCH AS? To do that, auditors
          service providers operating in the UAE. This means if there   have to prioritize their inputs to develop a workable audit
          are pre-existing contracts with offshore companies, the DGE   work plan. The diagram below illustrates some of the sources
          will need to revise their existing contract arrangements.  that ISR auditors may consider in planning an ISR audit.
          JUNE 2018                                                           INTERNAL AUDITOR - MIDDLE EAST     11
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