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THE RELEVANCE OF THE COMMON CRITERIA TO SARBANES-OXLEY AND CORPORATE GOVERNANCE

 

David Brewer

William List

Gamma Secure Systems Limited

Diamond House, 149 Frimley Rd

Camberley, Surrey GU15 2PS, UK

William List & Co.

46 Snakes Lane
Woodford Green, Essex 1G8 0DF, UK

* PUBLISHED AT THE 5th INTERNATIONAL COMMON CRITERIA CONFERENCE, 28-30 SEPTEMBER 2004, BERLIN, GERMANY © 2004 GAMMA & WmLIST&CO. Personal use of this material is permitted. However, permission to reprint/republish this material for advertising or promotional purposes or for creating new collective works for resale or redistribution to servers or lists, or to reuse any copyrighted component of this work in other works must be obtained from both Gamma and WmLIST&CO.

 

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.

The objective of our presentation:  "For many chief executives, concerned with meeting their organisation's business objetives whilst complying with new legislation such as Sarbanes-Oxley, the utility of the Common Criteria must seem an irrelevance.  Yet there is an important link.  What is it?"

Click here for our paper in pdf format. 
Click here for our 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.

             
             
             
 
Gamma is an ISO/IEC 27001:2005 and BS EN ISO 9001: 2000 registered company, certified for the provision of information security consultancy.  BSI certificate numbers IS 85916 and FS  30710.  Please send comments to webmaster@gammassl.co.uk or complete our Visitors'Book. Gamma Secure Systems, Diamond House, Frimley Road, Camberley, Surrey, GU15 2PS, UK Tel: +44 1276 702500 - Fax: +44 1276 692903Copyright © Gamma Secure Systems Limited 2003-2004
 
 
Page last updated: 2 October, 2004