GTAG 17 Auditing IT Governance
GTAG 17 Auditing IT Governance
GTAG 17 Auditing IT Governance
Practice Guides
Practice Guides are a type of Supplemental
Guidance that provide detailed step-by-step
approaches, featuring processes, procedures,
tools, and programs, as well as examples of
deliverables.
Financial Services.
Public Sector.
Information Technology (GTAG®).
Introduction ..................................................................................................................................... 5
Acknowledgements .........................................................................................................................40
IT governance is directly related to organizational oversight of IT assets and risks, making it a shared
responsibility of senior management1 and the board. Senior management carries out the day-to-
day direction that tactically aligns with the overall strategic guidance of the board to ensure the
effective, efficient, and acceptable use of IT resources. The primary outcomes of effective IT
governance include:
Absent or poor IT governance can have significant negative impacts on an organization, both
financially and reputationally. Recovery from such impacts requires time, energy, and money. In
many organizations, there is a disconnect between senior management and IT due to the old belief
that IT exists solely to deliver day-to-day IT services. In reality IT is critical in the development of
competitive advantage and to support the achievement of the organization’s goals and strategic
objectives.
The internal audit activity is uniquely positioned and staffed within an organization to assess whether
the information technology governance of the organization supports the organization’s strategies
and objectives and to make recommendations as needed (Implementation Standard 2110.A2).
As the second edition of “Auditing IT Governance,” this GTAG has been updated to reflect the 2017
International Professional Practices Framework and to be more directly practical to internal auditors.
1Senior management usually includes the chief executive officer (CEO), chief financial officer (CFO), chief operations
officer (COO), chief marketing officer (CMO).
Organizational Governance
Corporate Business
IT Governance
Governance Governance
IT Governance
• Areas
• Structures
• Mechanisms
Adapted from: Institute de la Gouvernance des Systems d’Information, The place of IT Governance
in the Enterprise Governance, 2005.
This edition provides tools and techniques to help internal auditors build a work program and perform
engagements involving IT governance.
IT Governance Overview
Implementing IT governance is an imperative part of organizational strategies because it is
fundamentally concerned with goals that ensure that IT delivers value to the business in a
controlled and effective manner. A typical IT governance framework would focus on five key areas:
In the IT governance conceptual framework, senior management and the board are responsible for
establishing the organization’s IT objectives in alignment with the overall business strategy;
defining IT strategies to achieve business objectives; and establishing IT governance policies,
organizational structures, and processes to manage the risks to accomplishing those objectives.
The role of internal audit in IT governance has become increasingly important in the wake of global
financial crises and high-profile information security breaches. According to survey results
published in The IIA’s CBOK® report, Promoting and Supporting Effective Organizational
Governance, internal audit is well positioned to promote and support organizational governance
and thus help achieve a balance between value creation and value preservation.
Internal audit’s role includes the responsibility to assess and make recommendations to improve
the organization’s governance processes (Standard 2110 – Governance) to help prevent
governance failures and improve strategic performance as part of the third line of defense.
In the Three Lines of Defense model, operational management (including IT) represents the first
line of defense and is responsible for the implementation and maintenance of processes and
controls to manage risks. Compliance functions and risk management represent the second line of
defense and are responsible for monitoring risks across the organization. Internal audit represents
the third line of defense and is responsible for providing independent assurance that risk
management and controls are operating effectively, and advise senior management and the board
when deficiencies are identified.
IT Governance
IT Management
Source: The IIA. Position Paper: The Three Lines of Defense in Effective Risk Management and Control
(Altamonte Springs, Fla. USA: The Institute of Internal Auditors, 2013). Adapted from ECIIA/FERMA
Guidance on the 8th EU Company Law Directive, article 41.
There are many internationally recognized IT governance frameworks that can be used to
supplement this guidance. Frameworks such as ITIL®, COBIT®, ISO/IEC 38500, King III, and King IV
reports cover in more detail the processes and mechanisms needed to develop, implement, evaluate,
and improve an IT governance program. This guide is focused on the processes and mechanisms that
internal audit can use to assess whether the IT governance program supports the organization’s
strategies and objectives in conformance with Implementation Standard 2110.A2.
Business Significance
The information and technological components of an organization are among its most important
assets. A lack of appropriate governance over information stored, processed, or produced by IT
systems can have a significant negative impact on an organization, ranging from fines and penalties
to a damaged reputation that can take time, energy, and money to rebuild. Simply put, IT
governance can influence and impact the entire organization, not only IT.
Greater dependency on systems and information means that organizations have to invest greater
resources to improve and maintain their IT environments. These are expected to help manage risk,
improve operations, and create value by delivering services that help achieve financial and
nonfinancial organizational objectives.
2Selig, Grad J., Implementing IT Governance: A Practical Guide to Global Sect Practices in IT Management, Van Haren
Publishing, Zaltbommel, March 2008.
IT Governance Components
Implementation and maintenance of an IT governance program depends on components that can
help senior management and the board direct, monitor, and measure IT performance. As shown in
Figure 3, the key components of effective IT governance have been grouped into three categories:
IT
Governance
IT Framework IT
Governance Governance
Metrics Policies
Mechanisms
IT
IT
Operations Governance
Components CISO
Organizational
Process Areas
Structures
IT IT Steering
Infrastructure Committee
Information
CIO
Security IT Portfolio
Management
Technology council CIO, CTO, business unit owners Evaluate technology opportunities.
Cybersecurity and data CIO, CTO, CISO, CRO, CFO, COO, CAE* Evaluate organizational risk and
protection council business unit owners strategies to protect the organization’s
information assets.
* Note: The CAE participates in the governance board as a nonvoting advisor on risk and controls.
It is imperative that audits of IT governance be divided into both assurance and consulting activities
depending on the robustness of the IT governance system in place. Independence should not
inhibit provision of advice, so long as management takes full responsibility and accountability for
implementation and operation of controls.
Any type of audit can assess if business owners are following and policies and demonstrate
adequate protection of assets by working with IT to identify risk and controls.
Governance processes are considered during the internal audit activity’s risk assessment and audit
plan development. The CAE typically identifies the organization’s higher-risk governance processes,
which are addressed through assurance and consulting projects described in the final audit plan.
In addition, Implementation Guide 2110 specifically
identifies the internal audit activity’s responsibility for
assessing and making appropriate recommendations to Factors that can help strengthen IT
improve the organization’s governance processes for: governance:
Clear IT ownership and
Making strategic and operational decisions.
accountability.
Overseeing risk management and control.
CIO reporting line to senior
Promoting appropriate ethics and values within management.
the organization.
The innovation value that IT
Ensuring effective organizational performance can offer is recognized.
management and accountability.
IT performance is monitored
Communicating risk and control information to and measured.
appropriate areas of the organization.
Coordinating the activities of, and
communicating information among, the board, external and internal auditors, other
assurance providers, and management.
Assessing the degree to which governance activities and standards are consistent with
the internal audit activity’s understanding of the organization’s risk appetite.
Conducting consulting engagements as allowed by the audit charter and approved by the
board.
When reviewing governance, internal audit must do more than just identify problems. They need
to identify root causes and make constructive recommendations when weaknesses in IT controls
are identified; for example, poor or weak firewall configuration. In this particular case, a root cause
evaluation can include different layers of control to identify the source of the problem.
Figure 5 shows a root cause analysis framework showing three layers of control that can be used
for the evaluation of IT weaknesses. Starting at the technical layer, go up to the process layer and
ask if there were any process breakdowns that caused the weak firewall configuration (e.g., lack of
oversight or monitoring, or inadequate separation of duties).
From the process layer, go up one more layer to IT governance and ask if the organization has
effective IT governance practices such as risk assessment and policy development, maintenance,
and training regarding firewalls.
Risk
Sources
The internal audit activity adds value when it identifies root causes and ensures the creation of
constructive action plans in cooperation with management to address the issue.
Proficiency
As noted in Implementation Standard 2130.A1, While it might seem that auditing IT
assessing IT governance may involve assurance governance requires extensive IT
and/or consulting services to evaluate the adequacy experience, the strategic aspects of
and effectiveness of controls in responding to risks IT governance can be part of any
operational engagement.
Governance frameworks, models, and requirements vary according to organization type and
regulatory jurisdictions. How an organization designs and practices the principles of effective
Internal audit must first ask what framework the organization is using to drive IT governance. If the
organization has not implemented a framework, internal audit can offer to perform a consulting
engagement to help management map existing controls and practices to an agreed to framework.
Next, the CAE contemplates whether the current internal audit plan encompasses the
organization’s governance processes and addresses their associated risks. Governance does not
exist as a set of independent processes and structures. Rather, governance, risk management, and
control are interrelated. For example, effective governance activities consider risk when setting
strategy. Equally, risk management relies on effective governance (e.g., tone at the top; risk
appetite, tolerance, and culture; and the oversight of risk management). Likewise, effective
governance relies on internal controls and communication to the board about the effectiveness of
those controls.
Implementation Guide 2110 indicates that, usually, a single audit of governance is not attempted.
Rather, the internal audit activity’s assessment of governance processes is likely to be based on
information obtained from numerous audit assignments over time.
The results of internal audits of the specific governance processes identified above.
Governance issues arising from audits that are not specifically focused on governance, such
as:
o Strategic planning.
o Operational efficiency and effectiveness.
o Internal control over financial reporting.
o Risks associated with IT, fraud, and other areas.
o Compliance with applicable laws and regulations.
At a minimum, at the end of this step the engagement plan should contain:
Examples of documentation the internal auditor can request to plan the IT governance internal
audit engagement include:
Interviewing relevant stakeholders is a critical step that helps internal auditors better understand
the objectives, design, operations, and control environment of the area or process under review.
Often, organizational charts can assist internal auditors in identifying relevant stakeholders.
Interviews with departmental heads may reveal what processes led to strategic and operational
decisions, gauge whether the organization’s efforts result in sufficient awareness of its ethical
Does the board understand the organization’s dependency on IT? How is that
understanding reflected in the strategic plan?
Do you have a clear definition of your role in IT governance? How do you know that you
are meeting expectations?
What decision-making bodies do you consult when making IT-related decisions?
What policies exists and how are they disseminated by the different governance
committees and subcommittees?
How does the organization measure value?
In addition, internal auditors may brainstorm with individual personnel or in selected groups to
identify relevant risks. For this purpose, auditors may ask, “What would keep the business
objectives from being met?” Additionally, to identify inherent risks, internal auditors may ask,
“What could go wrong if no controls were in place?”
The organization does not include Projects can fail due to poor There is a process in place to assess,
risk management as part of project planning to address risks. address, and communicate IT risks
management practices. to key stakeholders and executive
management during the project,
change, and release management
processes.
Appendix D provides a risk and control matrix for IT governance. This matrix is provided as an
example and should be customized to meet the specific needs of the organization under review.
The engagement objectives for IT governance can be related to compliance with external and
internal IT governance requirements, or operational performance of the IT governance processes,
and can be defined in different ways. For example, the objectives can be defined as part of the
annual audit plan, or as a result of ERM results, past audit findings, regulatory requirements, or by
specific assurance needs from the board or audit committee.
Internal auditors must also identify adequate criteria to evaluate the governance, risk
management, and controls of the area or process under review and determine whether the
business objectives and goals have been accomplished. Identifying such criteria ensures that
assurance engagement objectives are measurable, practical, and aligned with the objectives of
both the organization and the area or process under review.
According to Standard 2210.A3, internal auditors must use the criteria already established by
management and/or the board, if such criteria exist. If no criteria are in place, internal auditors must
identify appropriate criteria through discussion with management and the board. Internal auditors
should also consider seeking input from subject matter experts to help develop relevant criteria.
The following are examples of how assurance engagement objectives could be formulated for the
IT governance engagement.
IT governance activities and standards are consistent with the internal audit activity’s
understanding of the organization’s risk appetite.
The IT governance body is addressing substantial organizational and risk changes in a
timely manner.
The linkage of IT metrics and objectives aligns with the organization’s goals.
Metrics are being properly implemented to provide realistic views of IT operations and
governance on a tactical and strategic basis.
Internal auditors can act in a number of different capacities to assess and recommend ways to
improve governance practices. They may provide independent, objective assessments of the
design and effectiveness of governance processes within the organization. In addition to — or
instead of — providing assurance, internal auditors may elect to provide consulting services.
This may be a preferred approach, particularly when known issues exist or the governance process is
immature. Whether providing assurance or consulting services, the CAE may decide to use continuous
monitoring methods, such as assigning internal auditors to observe meetings of governance-related
bodies and advise them on an ongoing basis, as indicated in Implementation Guide 2110.
Due to consulting services being advisory in nature, the expectations and objectives are
determined either by, or in conjunction with, the engagement client. Thus, consulting engagement
planning typically occurs after the engagement objectives and scope have already been
Additionally, internal auditors must address governance, risk management, and control processes
to the extent agreed upon with the consulting engagement client (Standard 2210.C1). Although
the consulting engagement purpose and expectations are directed by the engagement client,
internal auditors must ensure the engagement objectives are consistent with the organization’s
values, strategies, and strategic objectives (Standard 2210.C2).
A benchmarking engagement could provide an effective starting point in a multiyear audit plan
because it allows management time to address design gaps in the governance structure before
additional reviews are performed.
The internal audit activity will advise on the effectiveness of existing organizational
structures supporting IT governance core activities.
The internal audit activity will advise on the effectiveness of existing governance controls
over change and patch management.
The scope may define such elements as the specific processes and/or areas, geographic locations,
and time period (e.g., point in time, fiscal quarter, or calendar year) that will be covered by the
engagement, given the available resources. Internal auditors must carefully consider the breadth
of the scope to ensure it enables timely identification of reliable, relevant, and useful information
to accomplish the identified engagement objectives (Standard 2210 – Engagement Objectives and
Standard 2310 – Identifying Information).
In scoping and executing an IT governance engagement, the internal audit engagement team
should:
6. Allocate resources.
After establishing the engagement objectives and scope, internal auditors must determine
appropriate and sufficient resources to achieve the engagement objectives, as required by
Standard 2230 – Engagement Resource Allocation. The interpretation of Standard 2230 clarifies
that appropriate refers to the mix of knowledge, skills, and other competencies needed to perform
the engagement, and sufficient refers to the quantity of resources needed to accomplish the
engagement with due professional care.
The process of establishing the engagement objectives and scope may produce any or all of the
following workpapers:
Process map.
Summary of interviews and brainstorming sessions.
Preliminary risk assessment (e.g., risk and control matrix and heat map).
2000 — Managing the Internal Audit Activity IG2000 — Managing the Internal Audit Activity
Practice Guide, “Engagement Planning: Establishing Objectives and Scope,” The IIA, Aug. 2017
Practice Guide, “Engagement Planning: Assessing Fraud Risks,” The IIA, Oct. 2017.
Position Paper, “The Three Lines of Defense in Effective Risk Management and Control,” The IIA, Jan. 2013.
Board* – The highest level governing body (e.g., a board of directors, a supervisory board, or a
board of governors or trustees) charged with the responsibility to direct and/or oversee the
organization’s activities and hold senior management accountable. Although governance
arrangements vary among jurisdictions and sectors, typically the board includes members
who are not part of management. If a board does not exist, the word “board” in the Standards
refers to a group or person charged with governance of the organization. Furthermore,
“board” in the Standards may refer to a committee or another body to which the governing
body has delegated certain functions (e.g., an audit committee).
Chief Audit Executive* – Describes the role of a person in a senior position responsible for
effectively managing the internal audit activity in accordance with the internal audit charter
and the mandatory elements of the International Professional Practices Framework. The chief
audit executive or others reporting to the chief audit executive will have appropriate
professional certifications and qualifications. The specific job title and/or responsibilities of
the chief audit executive may vary across organizations.
Consulting Services* – Advisory and related client service activities, the nature and scope of which
are agreed with the client, are intended to add value and improve an organization’s
governance, risk management, and control processes without the internal auditor assuming
management responsibility. Examples include counsel, advice, facilitation, and training.
Control Processes* – The policies, procedures (both manual and automated), and activities that are
part of a control framework, designed and operated to ensure that risks are contained within
the level that an organization is willing to accept.
Management – To exercise control and supervision within the authority and accountability
established by governance. The term management is often used as a collective term for those
with responsibility for controlling an organization or parts of an organization.3
Risk* – The possibility of an event occurring that will have an impact on the achievement of
objectives. Risk is measured in terms of impact and likelihood.
Senior Management – Group of persons who have authority delegated from the governing body
for implementation of strategies and policies to fulfill the purpose of the organization. This
group can include roles which report to the governing body or the head of the organization
or have overall accountability for major reporting functions, for example Chief Executive
Officers (CEOs), Heads of Government Organizations, Chief Information Officers (CIOs), and
similar roles.4
Significance* – The relative importance of a matter within the context in which it is being
considered, including quantitative and qualitative factors, such as magnitude, nature, effect,
relevance, and impact. Professional judgment assists internal auditors when evaluating the
significance of matters within the context of the relevant objectives.
Question Assessment/Comments
Is there a CIO in place, and is this function a member of the senior management team?
Are the structure of the organization and its operational components clearly organized
such that the IT function can efficiently and effectively help enable the achievement of
the organization’s objectives?
Are decision-making bodies in place to enable alignment of organizational needs with IT
services and do they have adequate empowerment and accountability?
Are organizational needs and IT service requirements defined in strategic and tactical
plans, and monitored?
Do the CIO and senior management meet and discuss progress on plans on a
regular basis?
Are roles and responsibilities clearly defined and communicated, and are organization
leaders empowered and held accountable for results?
Question Assessment/Comments
Does senior management have clearly defined and communicated roles and
responsibilities for the IT function with respect to the organizational achievement of
strategic and tactical goals?
Are the roles and responsibilities of the CIO clearly defined and communicated?
Does the organization recognize in its strategy that the IT function is a significant
contributor in enabling the achievement of goals, as well as supporting the organization
on a day-to-day basis?
Does the CIO meet with the board and the senior management team on a regular basis to
discuss IT service delivery related to strategic and tactical plans?
Does IT have adequate funding to meet the organization’s needs?
Question Assessment/Comments
Do the board and senior management view IT as a strategic organizational partner?
Does the strategic plan of the organization include how IT is required to support and
enable value creation?
Is the strategic plan supported by individual tactical operating plans that take into account
IT requirements and deliverables?
Are key performance indicators (KPIs) used by senior management to measure and
monitor the effectiveness of the IT function?
Are strategic IT investment decisions based on accurate cost benefit analyses and
evaluated after implementation to determine whether the projected ROI has
been realized?
Are lessons learned factored into future IT investment decisions?
Question Assessment/Comments
Do the board and senior management have a clear understanding of IT costs and how
they contribute to the achievement of the organization’s strategic objectives?
Do leaders of the organization measure IT value and deliverables? If so, how?
Are there sourcing arrangements in place? If yes, are they measured and monitored?
Question Assessment/Comments
To what degree are organizational processes automated?
How complex is the IT infrastructure and how many applications are in use?
Are data standardized and easily shared across applications (and the IT infrastructure)?
Control Objective: Organizational structures should include clear lines of reporting and role responsibilities.
Risk Control
Accountability is not clearly defined, resulting in lack of The strategic goals and objectives of the organization
transparency of IT costs, processes, projects, and services. should drive operational objectives and targets, and
responsibility for objective achievement should be
placed on unit leaders to promote clear accountability.
Lack of empowerment or accountability resulting in IT and business unit leaders should be empowered to
potential lost opportunities for innovation and manage resources within their area of responsibility,
collaboration. enabling them to manage toward expected
performance targets.
Unclear strategic alignment and understanding between Creating multidisciplinary organizational structures
the organization and IT functions, resulting in reduced allows representation of the different interests within
contribution to stakeholder returns. the organization, including internal audit, which
represents the interests of the entire organization.
Senior management and the board do not understand Roles and responsibilities should provide mechanisms to
the basic relationship of IT and business objectives, link the use of IT to the overall strategies and goals of
which can result in ineffective allocation of resources to the organization.
strategic initiatives and/or poor understanding of overall
IT costs and their input to ROI cases.
Control Objective: Organizational structures include the operational nature of their components and communication
protocols.
Risk Control
Unclear communication channels between IT and To ensure consistency throughout the organization,
organizational unit leaders, resulting in an ineffective ongoing effective communication regarding IT
planning and monitoring system. governance should be maintained across all units and
functions.
A proper communication plan should include the aspect
and metrics to be informed, preparers and receivers,
frequency, and escalation procedures.
Control Objective: IT personnel is capable of allocating resources to meet business objectives.
Risk Control
Unclear IT roles and responsibilities resulting in Processes, roles, and responsibilities of IT personnel are
misalignment of resources and operational objectives. defined, documented, and communicated.
Irresponsible utilization of IT resources and assets due Processes are documented and evaluated periodically
to the absence of consistent and repeatable IT to ensure they are consistent and repeatable.
processes.
Control Objective: The organization and IT collaborate on resource priorities, initiatives, and overall investment
decisions.
Risk Control
IT senior management is not included in the decision Senior management and the board should engage IT in
process to align IT and the organization’s objectives, strategic decisions about governance, enabling IT to
resulting in IT’s inability to support decisions or adjust to add value in key decisions.
changing priorities in a timely manner.
Lack of or poor IT portfolio management processes may A strong portfolio management process exists, allowing
result in poor prioritization of IT investments. the organization and IT to collaborate on resource
priorities, initiatives, and overall investment decisions.
Misalignment between IT resources and operational Organization unit leaders meet with the CIO and other
objectives resulting in external and internal stakeholder IT function leaders to determine the most effective
dissatisfaction with the way the organization operates methods for supporting and further enabling the
and financial results (government, regulators, society in achievement of each unit leader’s objectives.
general, shareholders, board, business partners,
customers, suppliers, consultants, employees, and
external auditors).
Control Objective: The IT governance structure is defined in alignment with the IT architecture (for example, if the
strategic management is centralized within headquarters, the governance structure should be
centralized as well).
Risk Control
Inadequate enterprise architecture can result in The IT enterprise architecture should mirror the
unnecessary investment in redundant or incompatible organizational structure to enable better alignment and
technologies. meet the organization’s needs.
Misalignment between the IT governance structure and The development of the IT governance structure should
the IT architecture can result in processes that do not be based on current and anticipated IT architecture
support the organization’s needs and can be too costly designs.
to modify.
IT Infrastructure Library (ITIL) is a framework developed by the United Kingdom’s Cabinet Office
as a library of best practice processes for IT service management. https://www.itil-itsm-
world.com/index.htm.
The Institute of Directors in Southern Africa (IoDSA), King Report on Corporate Governance and
King Code of Corporate Governance (King III) was compiled by the King Committee in response to
the emergence of the South African companies Act 71 of 2008. A new King IV was published on
Nov. 1, 2016. http://www.iodsa.co.za/?kingIII.
NIST SP 800-39, Managing Information Security Risk: Organization, Mission, and Information
System View, NIST 2011.
The IIA would like to thank the following oversight bodies for their support: Information Technology
Guidance Committee, Professional Guidance Advisory Council, International Internal Audit
Standards Board, Professional Responsibility and Ethics Committee, and International Professional
Practices Framework Oversight Council.
DISCLAIMER
The IIA publishes this document for informational and educational purposes and, as such, is only intended to be used as a guide. This
guidance material is not intended to provide definitive answers to specific individual circumstances. The IIA recommends that you
always seek independent expert advice relating directly to any specific situation. The IIA accepts no responsibility for anyone placing
sole reliance on this guidance.
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guidance@theiia.org.
January 2018
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