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When deciding who should be monitoring internal controls, the person selected needs to be someone who is outside of the environment and is not responsible for the internal control. For example, if a network administrator is responsible for ensuring that an internal control over the network they created is functioning correctly, that network administrator could miss critical vulnerabilities because they are working closely with the network on a regular basis. Similarly, having the person who is responsible for the control also monitoring the internal control could pose a potential opportunity for an employee to commit fraudulent behavior.
During the SOC 2 audit process, an auditor will be verifying that the correct personnel are tasked with monitoring internal controls. Auditors will want to see that organizations are conducting valid, accurate, and above-board evaluations of internal control, and organizations can do this by tasking the correct personnel with oversight. Think of it this way: Why do organizations seek out third-party audit firms to conduct audits instead of solely relying on their internal audit team? For organizations who are serious about strengthening their security posture, using third-party audit firms helps them identify and mitigate vulnerabilities that otherwise may have been missed by their internal audit department. This is exactly what happens if a person who has created a network or system component is also responsible for monitoring it. To ensure the continuity of organizations’ security postures, it’s critical that the correct person is monitoring the internal controls.
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KirkpatrickPrice is a licensed CPA firm, PCI QSA, and a HITRUST CSF Assessor, registered with the PCAOB, providing assurance services to clients in more than 48 states, Canada, Asia, and Europe. The firm has over 13 years of experience in information security and compliance assurance by performing assessments, audits, and tests that strengthen information security and internal controls. KirkpatrickPrice most commonly provides advice on SOC 1, SOC 2, PCI DSS, HIPAA, HITRUST CSF, GDPR, ISO 27001, FISMA, and CFPB frameworks.
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