The Information Systems Audit and Control Association & Foundation www.isaca.org OUTSOURCING AUDIT PROGRAM & INTERNAL CONTROL QUESTIONNAIRE The Information Systems Audit and Control Association & Foundation With more than 22,000 members in more than 100 countries, the Information Systems Audit and Control Association® (ISACA™) is a recognized global leader in IT governance, control and assurance. Founded in 1969, ISACA sponsors international conferences, administers the globally respected CISA® (Certified Information Systems Auditor ™) designation attained by more than 23,000 professionals worldwide, and develops globally-applicable Information Systems (IS) Auditing and Control Standards. An affiliated Foundation undertakes the leading-edge research in support of the profession. The IT Governance Institute, an offshoot of the Association, sponsors a new web site dedicated to the theory and practice of IT governance for the purpose of ensuring that IT activities achieve business objectives. Purpose of These Audit Programs and Internal Control Questionnaires One of the goals of ISACA’s Education Board is to ensure that educational products developed by ISACA support member and industry information needs. Responding to member requests for useful audit programs, the Education Board has recently released audit programs and internal control questionnaires on outsourcing and various eBusiness topics for member use through the GIR. These products are intended to provide a basis for audit work. The Education Board cautions users not to consider these audit programs and internal control questionnaires to be all-inclusive or applicable to all organizations. They should be used as a starting point to build upon based on an organization’s constraints, policies, practices and operational environment. Control Objectives for Information and Related Technology COBIT® has been developed as a generally applicable and accepted standard for good Information Technology (IT) security and control practices that provides a reference framework for management, users, and IS audit, control and security practitioners. This program has been developed and reviewed using COBIT Third Edition as a model. Audit objectives and steps are included. Disclaimer The topics developed for these Audit Programs and Internal Control Questionnaires have been prepared for the professional development of ISACA members and others in the IS Audit and Control community. Although we trust that they will be useful for that purpose, ISACA cannot warrant that the use of this material would be adequate to discharge the legal or professional liability of members in the conduct of their practices. October 2000 Outsourcing Page ____ of ____ Introduction Outsourcing is the process by which an organization contracts services that augment functionality and/or operations. Reasons for outsourcing vary from downsizing to sharing expertise. In any event the result of sharing functionality is sharing assets in the form of information and data as well as any shared resources. The audit focus is on the agreement and it should be noted that without an agreement, the audit of an outsourced function/operation may not be possible. The agreement review must take place before the deal is consummated, and not after. This can mean the difference between a successful outsource venture and one which becomes a major aggravation from which the organization cannot easily remove itself. The work that needs to be performed with respect to outsourcing should be discussed up front, since the Audit Department would have a key role to play. This discussion should include: How to determine what should be outsourced The various alternatives with respect to outsourcing (outsource, cosource, application rental) Reasons for outsourcing Key aspects of the outsourcing project (communication, staff transfer, asset transfer, etc.) Key components of the contract What comprises the contract and what will be handled outside the contract. Contract cancellation issues as part of the up front agreement Performance – increasing improvement expectations, etc. The outsource contract is critical and if improperly prepared and structured, can hurt an organization or damage it so severely by putting it at a competitive disadvantage. It is for this reason that the Audit Department must be involved at the front end of the process and not serve as a reviewer after the fact. The Education Board cautions users not to consider these audit programs and internal control questionnaires to be all-inclusive or applicable to all organizations. They should be used as a starting point to build upon based on an organization’s constraints, policies, practices and operational environment. This program has been developed and reviewed using COBIT Third Edition as a model. Audit objectives and steps are included. For more information on COBIT Third Edition, including free downloads, please visit ISACA’s web site at http://www.isaca.org/cobit.htm Outsourcing Page ____ of ____ Audit Objectives COBIT Control Objective Control over the process of managing third-party services that satisfies the business requirement to ensure that roles and responsibilities of third parties are clearly defined, adhered to and continue to satisfy requirements is enabled by control measures aimed at the review and monitoring of existing contracts and procedures for their effectiveness and compliance with organization policy. Functional Objectives 1. Data integrity, availability, confidentiality in accordance with business needs are determined by senior management via policy and are maintained and contractually supported in any outsource arrangement. 2. Asset protection requirements are clearly defined and understood by the principals in any outsource agreement. Data and information custodial responsibilities are well defined and complied with. 3. Service levels are acceptable (When considering Outsourcing, COBIT’s process DS1 Define and Manage Service Levels is important. Therefore, reference and content should be included in the Internal Control Questionnaire) 4. Billings and invoices are accurate and costs are within budgeted amounts. Outsourcing Page ____ of ____ AUDIT PROGRAM Audit Step Completed Test Results, Remarks, By/Date W/P Ref. Auto. COBIT Tool Reference used A. Prior Audit/Examination Report Follow Up Review prior report and verify completion of any agreed-upon corrections. Note remaining deficiencies Perform benchmarking of third party services M1, M4 B. Preliminary Audit Steps DS2 Review outsourcing policies and contract requirements Obtain a list of all current third party contracts and compare to vendor list. Determine scope of your review and select contract(s) for testing Review organization-wide procedures relating to purchased services and third party vendor relationships C. Detailed Audit Steps Management and Planning For each contract selected: Review contract content for all requirements (see Internal Control Questionnaire ICQ) Review transition plans for completeness and involvement from all affected areas. Assure that a baseline analysis was performed to support the need for outsourcing Review organizational and vendor constraints Review any risk assessment methodology used in deciding to outsource Review the vendor selection process Review project plans for completeness against existing project management standards Review costing and payment processes Review technical support procedures DS1 DS2 DS2 Outsourcing Audit Step Security Review outsourcer’s contingency plans and back-up procedures for adequacy Review outsourcer’s access control practices as they relate to our information assets Review termination procedures for vendors, contractors and subcontractors. Determine access is cutoff when appropriate Review access control processes for applicable: - Operating System - Application System(s) - Networks - Remote Access Review assignment of technology inventory to contractors At the outsourcer location (s), review physical security controls including access issuance, administration and maintenance Administrative Review billings, payables and disbursements for accuracy and compare to budget noting significant variances Review internal procedures to monitor outsourcer’s performance Review outsourcer’s purchase options (if applicable) Page ____ of ____ Completed Test Results, Remarks, By/Date W/P Ref. Auto. COBIT Tool Reference used Outsourcing Page ____ of ____ INTERNAL CONTROL QUESTIONNAIRE Completed By: Question No. Question Description Management and Planning Date: Response YES NO N/A COBIT Reference DS2 Are management requirements and expectations clearly defined in the contract? Do policies regarding purchased services, and, in particular, third party vendor relationships exist? DS2 Do clearly defined benefits and business purposes exist to support the decision to outsource? DS2 Have prospective outsourcers been reviewed regarding: - R&D expenditures? - Ability to listen to need and not dictate direction? - Flexibility to need? - Support in worldwide endeavors? - Presence in applicable industry(ies)? - Sufficient technological expertise? - Ability to handle problems? - Current resource performance levels? Were vendor selection processes followed? DS2 Do contract reviews and approval processes exist and were they followed? DS2 Outsourcing Page ____ of ____ Completed By: Question No. Question Description Does the outsourcing contract contents include the following? Date: Response YES NO N/A COBIT Reference DS2 Formal management and legal approval? Legal entity providing services? Detail of services provided? Service level agreements : - Quantitative? - Qualitative? Costs of services? Payment requirements and frequencies? Problem resolution process? Penalties for non-performance? Dissolution process? Agreement modification process? Reporting procedures: - Content? - Frequency? - Distribution? Roles and responsibilities of principals? Business continuity processes? User/provider communications process and frequency? Duration of contract? Appropriate access levels defined and provided to vendor(s)? Security requirements? Non-disclosure guarantees? Right to access and right to audit? Are transition plan, with completed requirements from all affected Entities, completed? (baseline analysis) DS2 Outsourcing Page ____ of ____ Question No. Question Description Were existing contractual impacts considered? Response YES NO N/A COBIT Reference DS2 e.g. - labor - business partners - other _____________________________ Have all costs been identified? DS2 e.g. - transfer of objects - construction - indirect - cost shifting - other Have all technical expertise requirements been identified and obtained? DS2 For the operation/function to be outsourced, can the vendor support location dispersion where applicable? DS2 Are project plans used for the management of outsourcing transitions? Do they contain: DS2 Contingency plans? Training plans? Clear definition of: - HW requirements? - SW requirements? - Service levels? - Error handling procedures? - Legal issues? Are warranties provided or given? If yes, detail in Work Papers. DS2 Are we compliant to warranty requirements? DS2 Are customer service levels defined? DS2 Outsourcing Question No. Page ____ of ____ Question Description Does the service level agreement include: - Definition of service? Response YES NO N/A COBIT Reference DS1 - Cost of service? - Quantifiable minimum service level? - Level of support from information services function? - Availability, reliability, capacity for growth? - Disaster recovery/contingency planning? - Security requirements? - Change procedure for any portion of the agreement? - Written and formally approved agreement between provider and user of service? - Effective period and new period review/renewal/non renewal? - Content and frequency of performance reporting and payment for services? - Realistic charges compared to history, industry, best practices? - Calculation for charges? - Service improvement commitment? Are responsibilities of users and providers defined? DS1 Has outsourced function/operation allowed the customer service levels to be maintained or improved? DS2 Outsourcing Page ____ of ____ Question No. Question Description Has competitive advantage been achieved due to this outsourcing arrangement? (List all selected) ______________________________________________________ ______________________________________________________ ______________________________________________________ ______________________________________________________ Response COBIT YES NO N/A Reference DS2 Is costing flexible in the agreements? (i.e. if the term of the agreement is 10 years, are costs adjustable because the cost of technologies reduces quickly.) DS2 Have responsibilites for maintenance and technical support been clearly defined? DS2 Security DS2 Are security requirements clearly defined in the contract? Do clear practices exist for access elimination when terminations and/or transfers occur? DS2 Does the outsourcer have adequate back-up procedures? DS2 Does the outsourcer have adequate logical access control? DS2 Does the outsourcer have adequate physical access controls and administration and maintenance? DS2 Are technology resources properly assigned and recorded to vendors/contractors from inventory records sucha as on PCs, software and licenses. DS2 Does the outsourcer properly segregate access to our data from other clients? DS2 Outsourcing Page ____ of ____ Question No. Question Description Administrative Response YES NO N/A COBIT Reference DS2 Are billings and payables verified to the contract for validity? Is vendor performance monitored? DS2 Are technology purchase options monitored closely? DS2
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