In the wake of recent scandals, the US passed the
Sarbanes-Oxley Act and the European Commission issued a proposal for a
new EC Directive on the statutory audit of annual accounts. Corporate
governance guidelines and regulations specify the imperative for an
organisation to achieve its business objectives whilst looking after
its stakeholders. Part of the requirement is the need for
organisations to have an internal control system, which is the means
by which an organisation achieves its business objectives and manages
its business risks. What then is the relevance of the Common Criteria
to corporate governance?
The vast majority of internal controls
concern information in one form or another, and in this modern age,
much of that involves IT. Common Criteria evaluation inspires
confidence that the functionality of IT products will do what it is
supposed to do and not do what it is not supposed to do. This is a
unique proposition and provides a solid platform with which to build a
robust system of internal control. |
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paper in pdf format.
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presentation. |
Unfortunately, it is axiomatic that this
will go wrong (Murphy's Law) and therefore there is a need for an
appropriate mixture of preventive, detective and reactive controls.
Their effectiveness can be judged on the ability to detect an event in
sufficient time for management to take appropriate action before the
onset of some adverse impact.
In developing an internal control system,
the Board will first consider the business processes that are key to
the success of the business mission and ultimately those that concern
the business infrastructure, such as IT and other supporting services.
The principles of time to detect and react, and the need to determine
an appropriate mix of controls must also be taken into account.
One of the strengths of the Common Criteria
is the richness of the Part 2 vocabulary in expressing internal
control functionality. It does this particularly well for individual
IT components, but how well does it do it:
-
In terms of the overall preventive,
detective and reactive mix at the IT infrastructure level (e.g.
firewall, antivirus, intrusion detection, backup and recovery)?
-
In terms of business process applications
(e.g. financial reporting and process control)?
This paper addresses these questions and
shows the relationship between the Common Criteria, the various
corporate governance laws and regulations and other standards, drawn
from the fields of accounting, quality assurance and information
security management. |