The Role of Controls
One of the main reasons for a control is to mitigate some identified risk. The way to deal with an inherent risk that is at a level higher than what is acceptable is to implement an effectual control to mitigate that risk to an acceptable level.
That being said, there are some points to remember about controls and the role they play in IT auditing, or auditing in general. First, IT auditors need to be wary of false security by a control that is effective enough to mitigate the risk to an acceptable level. While experienced IT auditors are generally good at this exercise, management and others may not be as adept at understanding the reality of a control.
On the other hand, IT auditors should remember and keep in mind that controls introduce a cost and a benefit. The cost is almost always in real dollars—cost of identifying, designing, implementing and managing the control. The cost can also be an impact cost of inconvenience or operational efficiency in slowing down a process. Some of the latter is not so much a concrete observation as it is an understanding of, and taking into account, the impact of a control. A key for IT auditors has been seeking a balance between these costs (real/concrete and impact) and benefits. Benefits can also be real and concrete—understanding the relative difference in having the control operate effectively and doing without it. That balance is easier to describe than to discern effectually.
For instance, an organization wants to implement an effective password policy for the length of life for passwords. The common wisdom is that the life should be inversely correlated with the amount of risk associated with unauthorized access. That is, if there is a high risk associated with unauthorized access, the life should be short (e.g., 90 days for an online bank account). However, once that policy is implemented, there could be an unintended cost associated with forgotten passwords due to the frequency of changes in them. The result could be users frequently forgetting passwords and having to use entity resources for assistance in obtaining access—a cost that includes delays and frustration, among other results. Thus, the key is due diligence in assessing the real net benefit of a control.
Another consideration is that an entity has a business or purpose for which it is in operation. That purpose needs to be part of the consideration. It is easy to lose sight of the unintended impact on operations.
Generally speaking, the higher the inherent risk, the higher the interest should be in a control to mitigate that risk. IT auditors need to, therefore, consider the level of inherent and residual risk when conveying recommendations for controls.
Last, controls are often embedded in technologies or systems. That fact alone suggests that IT auditors need to be involved in assisting with the design where independence allows it. It also suggests a high importance for using IT auditors to assess the effectiveness of the internal control system. How can the control embedded in IT be properly assessed without an IT subject-matter expert providing assistance in understanding how effectively the control operates?
Understanding the Real Residual Risk
One of the issues with analyzing risk is that it is usually relative and subject to judgment. All constituents want controls to be “good enough” so that things will be “okay.” But, what is “good enough” and what is “okay”? Risk is not usually subject to an absolute measurement.
Bad managers have a tendency to misjudge or misapply controls and risk. Concerned with surviving and making a profit, they sometimes do not see the reality of residual risk and rush ahead only to encounter a bad result. Or, they get paranoid and avoid a perfectly acceptable risk and take no action to their detriment. Good managers, however, understand the reality of residual risk, and usually make the right decisions and often have a contingency plan should the risk come to the forefront. One of the challenges for IT auditors is to help managers be good or great managers by understanding the real residual risk and taking the appropriate action related to it.