“Are Your Security or Operational Business Policies

Correct?”

Practitioner Discussant CommentsMalik Datardina CPA, CA, CISA

Disclaimer!!!Risk management applied:“The following views are my own and are not

of my employer, Deloitte.”

Conceptually

I Data

Lot of promise: Bring CAATs Audit Analytics into Security Makes it possible to automate access control

testing

The GoodMathematics in abstract can be difficult

to grasp.But paper made it digestible

Use of simple models Examples relevant to auditors, e.g. “a teller

may deposit a customer’s money into the customer’s account”

Brought together necessary concepts e.g. RBAC, REA,

AudienceUnderstood this was primarily for academic

audience; right? Who is the audience?

Consider multiple audiencesDon’t limit just to audit; beneficial from

operations, network, information security, etc.

Why is this necessary?Solution looking for a problem?

What is the current ‘state of the art’? Any pitfalls with respect to manual testing? What are the risks? How does this procedure address them?

Need to illustrate benefit or cost of this outweighs External audit: can this save time in audit costs? Internal audit: explain how this will help from a

compliance perspective – how does it address: PCI, ISO 27001/2, SOC2 (Trust Services/cloud)

Some feedbackWhy is this necessary? Solution looking for a

problem?Need to illustrate benefit or cost of this

outweighs External audit: can this save time in audit costs? Internal audit: explain how this will help from a

compliance perspective – how does it address: PCI, ISO 27001/2, SOC2 (Trust Services/cloud)

How does this work practically?Need to explain how this works in practice:

What are the practical steps you need to take to do this?How do you get access rules in an electronic

format?Can this be obtained from SAP, Oracle, etc?What is exactly required for the auditor to do

to actually create the list of “right rules” to audit the security rules obtained from the device.

Insights from other areas?Software testing: What can be learned

from static analysis (i.e. automated testing of software)?

Intrusion detection systems: Are there potential for false positives? Is there a tuning problem?

Data quality: Are there data quality issues when you get access controls “data dump” from the machine?