Although I am not a formally qualified auditor, I have had a fair amount of experience of carrying out audits and risk assessments in met various roles towards becoming a CISO. I have also been able to present on the topic and have articulated many of the unique challenges faced by auditors and audits alike.
Reading about auditors on social media, articles and LinkedIn is never a pretty affair, and there is rarely any love lost between them and those posting about them. For instance, the QSA who asked for (amongst other things) a list of usernames and plain text passwords. This auditor then doubled down when pressed, accusing the auditee of ntrying to hide a poorly maintained system.
A similar thing happened to a (barely adequate) friend of mine recently, when his auditor reported a finding that “users have read access to the Windows System32 folder” flagging it as a high risk. Even Microsoft stated that this is how their operating system works, and under “normal operation” cannot be changed. My (barely adequate) friend does not run nuclear power stations, by the way.
Pushing back against these decisions in a formal manner is the only approach you can take; remove the emotion from the conversation and engage as soon as possible, even if it means potentially derailing the audit for an hour or so. If you are able to get team members to do research on the subject, or call in recognised SME’s, then all the better, but establishing the facts early is important. The longer the matter goes on though, the harder it is to resolve.
If that fails, wait until the report or draft comes in. This is an opportunity to formally respond and present evidence to the contrary. This response should be sent not just to the auditor, but also the company they work for (i.e. up the chain of command), as well as other stakeholders such as the clients that commissioned the audit. Their input is important as they are the ones both paying for the audit and with the most vested interest in its outcomes.
Finally, getting everyone involved around an actual table (difficult at the moment I know, but a videoconference will do the trick too) is the last course of action. Hopefully having line management, client/stakeholder, SME’s etc facing off will produce a more amenable result. Don’t expect it to disappear though, perhaps just be downgraded to medium or low.
Being an auditor has a complex dynamic. Third party auditors need to show value to whomever is paying the bills and can sometimes extend the scope or severity of issues to show “value for money”. They can also, ironically, be risk averse and not stand down for fear of being accused of wasting time and a subsequent law suit. An auditor is also trying to be an expert across multiple disciplines at once, as well the one of actually being an auditor, so there are always going to be knowledge gaps. Acknowledging that is a huge step to being a better auditor, and taking time to do independent research on topics you might have not understood as well as you have thought is vital.
For me, auditing/risk assessing was always an opportunity to help the people being assessed; this was a skill as well as a level of emotional intelligence that was shown to me by an ISO 27001 auditor in India, someone I remains friends with after over 12 years. That two-way engagement has been vital to establishing trust and subsequent transparency during audits, and has resulted in better quality findings and a willingness to address them.
Worst case, when it comes to an auditor that won’t back down, you can always just be Accepting the Risk and moving on with the day job.
(TL)2 Security has experience is risk assessment and audit across the security organisation. From a high level risk and gap assessment through to advisory and support services on meeting various certification audits, contact us to find out more.
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