Several of our Clients have been asking about whether they should allow their auditors to have remote access to their systems. That’s an awkward question to have to ask your auditor, so we thought we’d post a quick summary of our response.
Start by asking questions. This is your opportunity to audit them! Why do they want remote access in the first place? (It does save a lot of time and you should see that reflected on your audit bill!)
Who will be remotely accessing our system, and how do we know?
When will they be accessing the system?
We find that, from a technical perspective, using a “webex” or “gotomeeting” option would be safe. That way your technical controls are:
- It’s on-demand access that is only enabled when necessary.
- You can monitor in real-time what the auditors are doing or looking at.
If you have a decent Event Log Management system in place, you may also want to consider logging when the auditors are accessing your systems and make sure it lines up with their invoices. The infotex ELM system, for example, could send your accounts payable department a monthly e-mail with each login and logout by your auditors.
Do they have audit reports you can see? Once your auditor has remote access to your system, they then become a “high risk vendor.” You want to know, how are they controlling the risk of unauthorized access, breaches on their system, poor incident response, etc?
Do they conduct annual and on-demand risk assessments? What are their top risks? What risk monitoring do they perform? Do they provide awareness training to their employees? Are they audited?
A quicker question: Do they have a due diligence packet?
Meanwhile, your engagement letter (contract) with them may have to change. Be sure it makes the four promises:
- Provider promises not to share information or access with third parties without prior permission from Client.
- Provider promises to disclose, in a reasonable amount of time, any time promise #1 may have been purposefully or accidentally broken.
- Provider promises to maintain controls to ensure that promises #1 and #2 are possible.
- Provider promises to provide due diligence materials, as requested, to Client that provides appropriate assurance that promises #1, 2, and 3 are being kept.
Whatever they can not provide to you . . . . rank the risk and determine if it is acceptable. If not, you’ll need to apply some new controls.
Lastly, do NOT accept “we’re CPAs and abide by a higher professional ethic.” Well, maybe you can accept that, if they would accept “we’re a financial institution, and thus subscribe to a higher professional standard as it pertains to loan risk (or whatever they are auditing.)”
Dan Hadaway CRISC, CISA, CISM
Founder and Managing Partner, Infotex
“Dan’s New Leaf” is a “fun blog to inspire thought in the area of IT Governance.”