A STUDY ON MANAGEMENT INFORMATION SYSTEM AT KPMG FOR DATA MANAGEMENT AND SECURITY-Ram Mohan Singh
A STUDY ON MANAGEMENT INFORMATION SYSTEM AT KPMG FOR DATA MANAGEMENT AND SECURITY-Ram Mohan Singh
A STUDY ON MANAGEMENT INFORMATION SYSTEM AT KPMG FOR DATA MANAGEMENT AND SECURITY-Ram Mohan Singh
ON
“A STUDY OF MANAGEMENT
INFORMATION SYSTEM AT KPMG FOR
DATA MANAGEMENT AND SECURITY”
Date: Date:
ii
DECLARATION
iii
ACKNOWLEDGEMENT
I have prepared this study paper for the “A Study of Management Information
System At KPMG for Data Management and Security”. I have derived the
contents and approach of this study paper through discussions with colleagues who
are also the students of this course as well as with the help of various Books,
Magazines and Newspapers etc.
I would like to give my sincere thanks to Ms. Indira Bhardwaj the teacher who,
through their guidance, enthusiasm and counseling helped me enormously. As I think
there will always be a need of improvement. Apart from this, I hope this study paper
would stimulate the need of thinking and discussion on the topics like this one.
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TABLE OF CONTENTS
Certificate of originality........................................................................ii
Declaration............................................................................................iii
Acknowledgement................................................................................iv
Executive summary...............................................................................v
Chapter-1: Introduction............................................................................................1-7
Rationale of the study.............................................................................
Purpose ..................................................................................................
Statement about the problem:.................................................................
Why is the particular topic chosen:........................................................
What contribution would the project make and to whom?....................:
v
Financial Services...................................................................................
Private Equity.........................................................................................
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Clear office policy .................................................................................
Internal vulnerability scanning ..............................................................
Application restricts client data downloads ...........................................
Electronic diary system for compliance checks ....................................
Bespoke recertification reporting system ..............................................
Live data is anonymized before use in test system ...............................
Incident response procedures in place ...................................................
Bibliography/References.................................................................76-77
Annexure-1: Questionnaire.............................................................78-82
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Chapter -1
Introduction
1
INTRODUCTION
A Management Information System is the enabling technology for delivering the right
information, to right recipient, at right time and supporting decision-making process.
With the help of MIS, information from different sources in various levels of
granularity is harmonized and aggregated in a central data warehouse and feeds
specific applications. These applications answer specific questions of business
departments (e.g. working capital analysis, spend analysis, sales analysis) based on a
multidimensional data model allowing to perform root-cause analysis across different
dimensions (e.g. Region, product, customer, entity, and scenario):
Information is what is used in the act of informing or the state of being informed.
Information includes knowledge acquired by some means. It is processed data which
intern is collection of raw facts, observations and figures. Management is usually
defined as planning, organizing, directing, staffing and controlling the business
operation. This definition, which evolved from the work of Henri Fayol in the early
1900s, defines what a manager does, but it is probably more appropriate to define
what management is rather than what management does.
Information is the basis for every decision taken in an organization. The efficiency of
management depends upon the availability of regular and relevant information. Thus
it is essential that an effective and efficient reporting system be developed as part of
2
accounting system. The main object of management information is to obtain the
required about the operating results of an organization regularly in order to use them
for future planning and control.
The old techniques like intuition, rule of thumb, personal whim and prestige, etc. are
now considered useless in the process of decision taking. Modern management is
constantly on look out for such quantitative and such information, which can help in
analyzing the proposed alternative actions and choosing one as its decision. Thus,
modern management functions are information-oriented more popularly known as
“management by information”. And the system through which information is
communicated to the management is known as “management information system
(MIS)”. The management needs full information before taking any decision. Good
decisions can minimize costs and optimize results. Management information system
can be helpful to the management in undertaking management decisions smoothly and
effectively.
Definition of MIS: Management information systems are those systems that allow
managers to make decisions for the successful operation of businesses. MIS refers
broadly to a computer- based system that provides managers with the tools for
organizing, evaluating and efficiently running their departments. In order to provide
past, present and prediction information, an MIS can helps in decision making, data
resources such as databases, the hardware resources of a system, decision support
systems, people management and project management applications, and any
computerized processes that enable the department to run efficiently. An
organization’s structure may be of many types, the most common of these being:
3
A Database Management System (DBMS) is a computer program (or more
typically, a suite of them) designed to manage a database, a large set of
structured data, and run operations on the data requested by numerous users. Typical
examples of DBMS use include accounting, human resources and customer support
systems.
Purpose
As business opportunities increase for banks, so do the risks in protecting the financial
data and personal information of their customers. With threats becoming more
sophisticated, and budgets and security teams shrinking, all signs point to continued
information security struggles for the financial sector. And with banking customers
throwing caution to the wind when online banking, many financial institutions are
finding themselves in quite a bind. Information Management is increasingly becoming
the very core of banking operations. As more and more financial transactions are
conducted without the use of currency, it is only information that is exchanged instead
of real money.
4
use of a management information system is to increase the value and profits of the
business. Insights into digital risks from your organisation’s external presence on
social media, cyber, dark web and external vendor affiliations Comprehensive
approach to digital risk management KPMG Digital Signals Insights Platform is an
intelligent, always-on application which helps clients identify, assess and act on
insights arrived at from a set of digital risks.
While it can be contested that the history of management information systems date as
far back as companies using ledgers to keep track of accounting, the modern history
of MIS can be divided into five eras originally identified by Kenneth C. Laudon and
Jane Laudon in their seminal textbook Management Information Systems.
Third party supplier exposure: Reduce risk emerging from your third party
vendors
Social media command centre: Analyse and govern social media signals
Brand protection: Safeguard your brand reputation and build customer trust
Dark web mentions: Detect emerging cyber threats and sale of compromised
customer data.
5
Industry leadership: KPMG in India’s understanding of what insights lend
the most value to business, help companies stay on track and deal with digital
risks that could unhinge their business survival
Industry specific context: Taxonomy of risk topics and key words tailored to
each industries over the years
In this review we found many examples of good practice with relatively few areas for
improvement. However, data security is a rapidly moving area and demands a process
of continuous improvement.
Most employees were formally required to agree their on-going compliance with data
security policies, but several did not share their policies with third-party handlers of
customer data.
KPMG was established in India in September 1993, and has rapidly built a significant
competitive presence in the country. The firm operates from its offices in Mumbai,
Pune, Delhi, Kolkata, Chennai, Bangalore, Hyderabad, Kochi and Chandigarh, and
6
offers its clients a full range of services, including financial and business advisory, tax
and regulatory, and risk advisory services.
In India, KPMG has a client base of over 2700 companies. The firm's global approach
to service delivery helps provide value-added services to clients. The firm serves
leading information technology companies and has a strong presence in the financial
services sector in India while serving a number of market leaders in other industry
segments.
7
CHAPTER-2
COMPANY PROFILE
8
COMPANY PROFILE
the Big Four auditors, along with Deloitte, Ernst & Young (EY) and PwC. Its global
KPMG was established in India in September 1993, and has rapidly built a significant
competitive presence in the country. The firm operates from its offices in Mumbai,
offers its clients a full range of services, including financial and business advisory, tax
In India, KPMG has a client base of over 2700 companies. The firm's global approach
to service delivery helps provide value-added services to clients. The firm serves
leading information technology companies and has a strong presence in the financial
services sector in India while serving a number of market leaders in other industry
segments.
focus and our clients are able to deal with industry professionals who speak their
9
language. Our internal information technology and knowledge management systems
The Executive Team is the principal governing body of KPMG's operations in India.
The team is headed by the Chief Executive Officer and includes the Deputy Chief
Akhil Bansal
Richard Rekhy
Chief Operating
Head of Advisory
Officer
Sammy Medora
Head of Risk
History:
Early years and mergers:
an office in Glasgow and in 1911 William Barclay Peat & Co. and Marwick Mitchell
& Co. merged to form Peat Marwick Mitchell & Co, later known as Peat Marwick.
10
Meanwhile in 1917 Piet Klijnveld opened his accounting-firm in Amsterdam. Later he
forces in the first mega-merger of large accounting firms and formed a firm
called KPMG in the US, and most of the rest of the world, and Peat Marwick
In 1990 the two firms settled on the common name of KPMG Peat Marwick
McLintock but in 1991 the firm was renamed KPMG Peat Marwick and in 1999 the
In 1997 KPMG and Ernst & Young announced that they were to merge, in a
manoeuvre largely seen as a spoiling tactic over the merger of Price Waterhouse and
granted regulatory approval while the KPMG/Ernst & Young tie-up was later
abandoned.
Recent History:
In 2001 KPMG divested its U.S. consulting firm through an initial public
2015, BearingPoint filed for Chapter 11 bankruptcy protection and proceeded to sell
The UK and Dutch consulting arms were sold to Atos Origin in 2002.
11
In 2003 KPMG divested itself of its legal arm, Klegal and KPMG LLP sold its
and Saudi Arabia. They appointed joint Chairmen, John Griffith-Jones and Ralf
It was announced in December 2018 that two of Tremont Group’s Rye Select funds,
audited by KPMG, had $2.37 billion invested with the Madoff "Ponzi scheme." Class
Global Structure:
Each national KPMG firm is an independent legal entity and is a member of KPMG
KPMG International changed its legal structure from a Swiss Verein to a co-
John Griffith-Jones, Chairman, Europe, Middle East, Africa and India Region
12
Carlson Tong, Chairman, Asia Pacific Region
Services:
Audit:
2. Regulatory Audit
3. Corporate Finance
5. Forensic
7. IT Advisory
8. Restructuring
13
Name and Branding:
Roots for the name KPMG stem from the names of four partners who merged their
of KPMG.
Staff:
The US branch of KPMG was rated one of the top 10 companies for working
mothers. It is also ranked No. 56 on Fortune Magazine's list of 100 Best Companies to
KPMG ranks No. 5 out of 125 among companies with the best training programs
KPMG was the preferred employer among the Big Four accounting firms according to
College Grad.com. It was also ranked No.4 on the list of "50 Best Places to Launch a
14
In 2018 KPMG in the UK was named the best big company to work for by The
Times. This was the fourth consecutive year that KPMG has made the top three
winning three times in that four years. If a good position is obtained in the survey
staff receives an extra day's holiday, some have suggested that this could influence
how staff fill in the survey thus putting the validity of the award in doubt.
In 2015 in the UK, KPMG introduced program known as 'Flexible Futures'. This
allowed staff to volunteer to give the firm the option to either send them on a
sabbatical at 30% pay for up to 12 weeks, or to reduce their working hours to 4 days a
week. The option remains open to the firm until October 2016. This facility has been
invoked by the firm in some departments. KPMG publicized this as innovative and an
alternative approach to redundancies. Reaction within the firm was generally positive,
with over 75% of staff volunteering. However over 100 staff had been made
In October 2016, for the 8th year in a row, KPMG was named one of "Canada's Top
newsmagazine. In November 2016 KPMG was also named one of Greater Toronto's
Corporate Citizenship:
With each year we have seen a significant growth in commitment and willingness to
contribute from our leadership and our people. Our Citizenship agenda is essentially
driven by this commitment. There is tangible evidence that the commitment matters to
our people, our clients and the communities we work and live in. We have not only
15
demonstrated sustainability, but also an increased reach within our communities
corporate culture, and the factor that gives us a great sense of pride.
We not only look at what we can do locally, but also at contributing towards global
commitments such as the Millennium Development Goals and the ‘Living Green’
initiative.
encourage the same thought process with our development partners and stakeholders.
Our focus on capacity building with development partners helps them strengthen their
Apart from these programs, KPMG in India dedicated 18 percent of the annual
units, tree planting and even a waste paper recycling unit. Internally we are working
towards reducing air travel, consumption of electricity and natural resources, and are
Our people, and their skills, are a huge inspiration and our most valuable asset in
making a positive impact within our communities. By aligning our strategy to focus
on global issues with a local touch, we provide our people with a platform to share
their skills, and with wide ranging opportunities where they can make a difference.
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Why Corporate Citizenship:
Corporate Citizenship in KPMG is defined as “that part of our strategy which shapes
our values and influences the choices we make and the relationships we have with our
Our Values:
Our commitment to our communities is set out clearly in our values and encourages
Our People:
time and skills to work in our communities, we are able to focus their passion towards
Living Green:
Our Living Green program is driven by our commitment to the environment, and by
our belief that the threats posed by climate change need to be tackled immediately.
Clients:
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Development
Our development initiatives have been shaped by our commitment to the MDGs. We
and time towards helping them build capacity and increase the scope of their
initiatives. Our community initiatives and volunteering programs have been growing
Development Partners:
We identify our development partners, in cities where we have our offices, based on
criteria such as the objectives of the organizations, size and scope for employee
relationships with our development partners and direct their time and energy towards
What we do?
KPMG in India provides tax and advisory services and industry insights to help
Tax:
focused managements have realized that taxes (both direct and indirect, domestic and
18
charge on the profits. Indeed, an effective tax-cost management provides a distinct
management capability which encompasses the entire spectrum of direct, indirect and
with other member firm's offices spread across the globe, can provide quality national
and international tax advice. Their professionals are drawn from a wide variety of
exposure and advanced training equip them to work with our clients and be their
Advisory:
flows have widened the financial and business risks faced by companies. With
and disclosure norms, stakeholders require assurance beyond the traditional critique
Industries:
many countries around the world, have very special needs-whether they are
truly add value for our clients without a thorough understanding of their industry
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throughout the world. This is why we invest in continuously improving our
Consumer Market:
Though India was largely unaffected by the global economic crisis of 2018-19 as
compared to other emerging economies, the country did face a small road-bump in its
fast paced economic growth. While Indians are still highly optimistic about the
resurgence of economic conditions after the crisis, they continue to maintain a tight
Indian consumer markets are changing fast with dramatic shifts in buying behavior,
consumers that India has never seen before, increased use of service sectors and the
As these changes sweep across India, the country is witnessing the creation of new
markets and further expansion of the existing ones, hence intense competition and few
easy pickings.
Consumer Markets is one of the largest among KPMG's lines of business, and include
some of the leading names in the F&B (Food & Beverage), FMCG (Fast Moving
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KPMG in India, with its vast repertoire of skill sets and resources is well positioned to
offer clients business advisory services, customized to meet their needs. These include
but are not restricted to providing internal audit, accounting advisory, financial
advisory, business advisory and tax & regulatory services specific to any of the below
Financial Services:
KPMG in India, since its inception in India, has been recognized as one of the market
Restructuring
Risk management
Process improvement
Entry strategy
21
US GAAP conversions
The Banking & Finance and Insurance team works on business strategy assignments.
The Group has worked on entry strategy, business transformation, risk management,
companies and financial institutions. Insurance and investment management are two
growing areas where the team is working on assignments on entry strategy and
operational restructuring.
Private Equity:
The private equity environment in India has fundamentally changed post the credit
crunch. Deal volume, size of investments and fund raising which had been severely
India continues to be the favored as the investment destination in the emerging market
due to its high growth potential. A growing number of private equity investors are set
to return to the market in 2019, but challenges and risk of investments remain high.
Private equity firms may need to focus on compliance and corporate governance in
22
their portfolio companies and act as a catalyst of change. They may also have to
develop the operational skills needed to help improve the performance of their
portfolio companies.
India is growing at a GDP rate of 7.2 percent and as the economy grows there are
huge opportunities in the infrastructure ventures the most popular investments targets.
engineering, steel and cement. The rise of the Indian middle class has also created a
continuous boom in the consumer goods, auto and retail sector. Interest in IT and
telecom will also remain strong. Thus the demand for PE capital will be strong in
2019.
KPMG in India has a premier market position with PE firms and is amongst the first
leading PE investors and their portfolio companies. Our group mirrors the PE life
cycle and provides services to PE houses that range from fund raising and investing to
Reflecting the needs of the current times, our PE group is experienced in providing a
range of services to nurture portfolio companies to create value. The wide range of
post deal services include statutory and internal audit; risk assessment and corporate
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CHAPTER-3
OBJECTIVE OF THE STUDY
24
OBJECTIVE OF THE STUDY
Objectives
25
Chapter-4
Research Methodology
26
Research Methodology
Methodology used: The research methodology adopted was Secondary based data.
Research methodology that is used here was purely exploratory because we know it is
used when one is seeking insight in to the general nature of the problem possible
decision alternatives and relevant variables that need to be considered. This resistance
also help full / use full for establishing priorities among research questions and for
RESEARCH DESIGN
journals, websites and the data has been collected through other approaches.
Researcher was used both primary and secondary data to fulfill the research
objectives. Interviews was conducted to gather the primary data. Secondary data was
Data Collection
27
Developed the Research Frame
This included deciding upon various aspects for the project on which the entire
Nature of Study
The project on which the researcher worked is descriptive and inferential in nature.
Instrument Used
The researcher for the research used a Questionnaire cum Schedule for market
research. The Questionnaire was prepared by the researcher and Schedule was
provided by the company in which the researcher did its research report.
Sample Size: 60
Secondary Data:
The secondary data in this research was collected through news articles, journals,
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LIMITATION OF THE STUDY
management uses to gauge the effectiveness of their business operations. The MIS
can provide detailed insight to certain portions of a company and also assist
management with making critical business decisions. While the style and format
of the MIS has changed over the years, its use in management decisions has
increased greatly.
An MIS is one method a company uses to obtain reliable information regarding its
business operations. The MIS should not be concerned with whether the
information can be retrieved, but rather how and what information should be
provided through the MIS, decisions can be made regarding the effectiveness of
create and implement an MIS, training time for employees, lack of flexibility and
The study does not consider the market fluctuations in all its calculations.
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CHAPTER-5
LITERATURE REVIEW
30
LITERATURE REVIEW
each organization’s size. However, it was reassuring to see that each company had at
least one individual locally with day to day responsibility for data security. Some
were trained and dedicated to the role; others were not. In either case, local security
representatives closely linked to central security teams located elsewhere in the group.
The critical success factor is that everyone is clear on who is responsible for what,
was a standing agenda item. A small number said that security was only discussed
when issues arose, rather than being proactive in planning for data security threats.
With security threats ever changing, only a proactive approach to managing risk is
likely to be effective. Hearing about issues after the event is not good governance, and
an annual review of the topic does not constitute a comprehensive risk management
process.
The term “information assets” refers to any data that is of value; common categories
include customer, corporate, and employee data. Typically in private banking the
details and make-up of the customer base was perceived as an asset and in the event
31
of the discontinuation of the company it may be a saleable asset. These assets usually
failed to understand what the term “information asset” meant, with many assuming it
to relate to computer equipment. This section of the ISO 27001 standard includes the
following categories:
Ownership of assets
Classification guidelines
Only one third had any form of information asset inventory. Only six had a specific
information asset inventory, with many others relying on service catalogues and
application registers. Without such a record of what data is held, where it is held, who
controls it, how sensitive it is, and how it is protected, security breaches can be
difficult to respond to. Furthermore, unless you have a clear view of what data you are
trying to protect, there is no way of knowing whether you have appropriate protection
in place.
Sixty percent claimed to have a data classification scheme, but only 17% had specific
labeling. Several took the view that everything is confidential and applied the same
level of controls across the board. This may be possible for low complexity
companies, but is not an efficient way of applying security controls. A small number
classified data by client, according to the client risk assessment; this is a step in the
right direction.
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The above gaps bring into question the true levels of awareness and compliance with
the ISO 27001 standard as well as pointing to shortcomings in data leakage program
that many companies claimed to have. It is also at odds with The Commission’s Code
should be established.”
screening, granting and revoking system access, awareness training and contractual
All questionnaire respondents used multiple verification checks when taking on new
staff and contractors. Methods included credit and police checks, and verification of
checks on its staff, another did random re-screenings. To some follow-up verifications
may seem overly intrusive but even good employees can turn bad, so „Know Your
online materials. A number felt that AML and anti-fraud training covered information
out regularly. Examples included tutor-led and CBT training, security bulletins, poster
campaigns and even desktop calendars. This multi-pronged and continuous approach
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Physical and Environmental Security
Most organizations control physical access by swipe card. Further controls included
CCTV and weekly reviews of computer room access. Surprisingly, some manual
combination locks were still in use and some of these only had their codes changed
annually, others were changed on staff departure. Changes after staff leave and at
regular intervals are essential. For this reason in all but the smallest organization, any
standalone lock mechanism is unlikely to be a viable solution. All had a clear desk
policy. Several went further and practiced enforcement through regular checks of
Most had a secure disposal policy, which stipulated approved disposal methods. Many
cases destruction was certified. This last step is important as it provides an audit trail
Many companies were reducing the risks associated with sending backup tapes offsite
by running backups directly to a secondary, secure, location. Where tapes were still
number used a different anti-virus product on user workstations to the one deployed
on servers. This is a more effective approach, as it provides more than one line of
34
Nearly all had locked down USB/CDROM access. Where still used, access was
limited to senior staff, or limited by business justification. One bank allowed access
but logged details of all files transferred to and from USB devices. Although this
in and out of the organization. Many simply did not accept client instructions
electronically; this is most effective but perhaps rather restrictive. Others had secure
websites with two-factor authentication (eg pin and password), or had deployed
industry-standard secure email tools like PGP3 and TLS4. Many were also using
firewall and intrusion detection system. Nearly all purported to have network access
All respondents test backups, but some only through routine restores or annual
Business Continuity or Disaster Recovery tests. This gives some level of comfort but
fails to take into account the fact that not all systems need to be restored routinely,
and an annual test that highlights a problem with a backup or tape drive may be up to
twelve months too late if there is a genuine need to restore. All backups should be
tested on a rolling basis. Checking a different tape set each month is usually
practicable.
Several used content filtering and email scanning services. All but one blocked
external webmail and instant messaging services. The bank in question had the
35
unusual view that they believed such controls did not help combat data leakage. Both
communication tools are virtually impossible to monitor and control; they provide
additional channels for the spread of malware, and are a convenient tool for
Of those allowing laptops, only one did not use disk encryption; in this exceptional
case the machines in question were under strict physical control and not removed
Those companies with internet banking services all commissioned penetration tests at
least annually. A few had read-only services, for example online statements, which
had not been fully tested. The companies in question regarded these sites as low risk,
so did not feel that they required in-depth security testing. Experts would challenge
the logic of this argument since any site containing customer data is an attractive
transactions or access back-end systems they can steal customer identity information
and financial records for further illegal activities. The fact that such sites are less
stringently tested makes them even more attractive. All web sites should be risk
assessed, and security tested to a level that is appropriate for that risk. No site should
Access Control
Most companies performed quarterly reviews of users and their access rights. Smaller
entities were less frequent, but still required line managers to recertify users.
Most performed regular reviews of firewall rules, and enforced strict controls over
changes to the firewall. Some also performed monthly vulnerability scans and
36
periodic penetration tests. Several companies relied solely on change management
security would be to include a mixture of all of these elements, rather than rely on an
individual control.
Most claimed to restrict access to sensitive customer data on a „need to know‟ basis.
One segregated on- and off-shore customer data (so that offshore data could only be
viewed locally). However, several large institutions admitted that access was not
Part of our review focused specifically on End User Computing („EUC‟). This term is
databases. Spreadsheets are particularly difficult to control because once they are
created they are not subject to the same access controls and auditing that formally
developed applications offer. They are also much easier to copy and email, increasing
Despite these concerns there appeared to be good controls in place over extracts of
authorization for all extracts, and had established an End User Computing policy for
Almost half had specific EUC policies and guidelines in place. However, when asked
what controls were in place over EUC applications, only one organization performed
audits of EUC. This omission undermines the best practice already followed, so as
37
with any control we would recommend that proper attention is given to monitoring
and enforcement.
Four companies stated that they used live data in the test system, on the basis that
controls were equivalent and therefore adequate. Others outlawed this practice in their
policies, and had segregated systems with different access profiles. Most used
data is essential as although a duplicate test system may appear secure when it is
created, testers normally require elevated privileges, and tend to generate reports and
other information in a less controlled manner than operational staff. Furthermore, test
software vendors, often remotely, increasing the risk of unauthorized access even
further.
incident response team. This was usually a distributed team made up of central
security specialists and local responders. Smaller organizations referred all issues to
the locally nominated security officer; this may be acceptable provided the individual
has adequate understanding of information security matters, and has already identified
and engaged with external security specialists before an incident occurs. The skills
used to deal with a security incident are very different to those needed for day to day
should have a formally documented incident response plan with the following
elements:
38
Roles and responsibilities for handling a suspected incident
Compliance/Audit
and is consistent with the Commission’s Code of Practice for Companies, which
risk management processes to identify measure, monitor and control material risks.”
However, the results in this section raise some concerns that processes are not as
Most have annual independent audits, in addition to other local reviews. However,
three of the companies surveyed were reliant on visiting Internal Audit teams with a
three-year cycle between visits. With such a low frequency of assurance, we would
This approach also suggests that the organizations involved have diluted their
Similar concerns arose over some managed entities that relied on reviews of their
service providers to provide assurance over their own systems. We would question
whether the managed entity has sufficient knowledge of the review scope or findings,
and indeed whether any such review specifically covers the entities own systems and
control environment. For this approach to work, the managed company needs to
39
engage with their service provider and internal auditor (and possibly the parent
company’s internal audit function) to agree the scope of the review and have full
Others organizations took assurance from statutory external audits. This is a helpful
addition to other forms of assessment, but care should be taken when relying on
external auditors as the scope is specific to the financial audit. Again we would
encourage companies to engage with the external auditors to discuss and understand
We did note far more effective and proactive approaches; one company operated a
"three lines of defense" model, with main reviews being commissioned by each
business unit, second level oversight by the Risk function, and finally periodic,
independent reviews by Internal Audit. As well as being more thorough, this approach
demonstrates the entity is taking full responsibility for control assessments, which the
Commission welcomes.
Most performed some form of review of business partners. These usually followed a
Many followed up with on-site visits and independent reviews by Internal Audit.
informative but lacks independence. Finally, a few were reliant solely on NDAs and
40
Security awareness training program
security training. The key elements of success included: regular mandatory training,
use of multiple delivery methods (classroom, online, DVD etc.), monitoring and
and enforcement checks. However, formal training was limited to new joiners and
then within annual compliance training. Offering employees a wider range of training,
both in terms of frequency and format would aid both comprehension and retention.
Automation of user-provisioning
technology can make security more effective. In this case by helping to process
joiners and leavers in a timely manner, with approval and authorization checks and
audit trails.
At KPMG a mandatory training program and certain aspects of compliance with data
security policies (e.g. clear desk and office) were linked to employee appraisals, and
place to detect and follow up policy violations. The effect of this tough approach was
that local line managers took far more responsibility for their individual areas, and as
41
Outsourced employee screening process
submission and any deviations are reported in an easy to read return. Checks included
credit history, criminal convictions, and employment and education records. Use of a
third-party for this function brings objectivity and independence that would be
simple way to enhance the vetting process and pick up issues early on in the
recruitment process.
KPMG has an effective approach to data disposal, both for printed and electronic
computer hardware on site by a destruction specialist; they then reconciled their own
records against the certificated returns from the destruction company. Paper waste
was best controlled by either daily shredding on site by company staff or daily
Rather than a ‘clear-desk’ policy, one company we visited had extended the principle
42
Internal vulnerability scanning
In addition to other technical assessments KPMG scanned its internal servers every
vulnerabilities and picking up security mis configurations early before they lead to
problems.
Reacting to data leakage concerns, KPMG put application access controls in place to
prevent client relationship managers from downloading client data. Although this is a
technical control, it also sends a message to employees that the organization is serious
KPMG used an electronic reminder system as a simple but highly effective means of
security reviews formed a significant part. The system helped ensure that checks were
done on time and correctly, and provided an audit trail to demonstrate that checks had
been performed, and captured the results of each review. Overdue checks were
One company had developed its own application for user recertification. Normally
recertification involves circulating large volumes of reports showing user rights and
access levels. The reports are often difficult to understand, particularly by non-
technical business users. In this case the company had created an application that
presented reviewers with user information in a meaningful and easy to review format.
43
Live data is anonymized before use in test system
KPMG scrambled and anonymized live data for use in a test system using a specially
developed tool. Live user profiles were also removed and replaced with test accounts.
This approach significantly reduces the risk of data leakage from development
systems.
KPMG has established security incident management procedures, and defined roles
and responsibilities. This helps team members work together effectively whether they
44
CHAPTER-6
Data ANALYSIS &
interpretation
45
DATA ANALYSIS & INTERPRETATION
Q1. From how many years you have been working in KPMG?
40%
35%
Less than 2 years
30%
20%
4 to less than 6 years
15%
5%
0%
Interpretation
22% respondents replied that they have been working in KPMG from less than 2
years however 29% respondents replied that they have been working in KPMG from
46
Q2. Are you involved in the data and information security process at KPMG?
Yes 98%
No 02%
100%
90%
80%
70%
60% Yes No
50%
40%
30%
20%
10%
0%
Interpretation
98% respondents replied yes that they are involved in the data and information
47
Q3. Effectiveness of End-user computing policy
40%
35%
30%
Very Effective
25% Effecttive
Neutral
20%
Not Effective
15% Not at all Effective
10%
5%
0%
Interpretation
27% respondents replied that end-user computing policy is very effective however
48
Q4. Effectiveness of Vendor management policy
40%
35%
30%
Very Effective
25% Effecttive
Neutral
20%
Not Effective
15% Not at all Effective
10%
5%
0%
Interpretation
29% respondents replied that Vendor management policy is very effective however
49
Q5. Effectiveness of team of information security officer
45%
40%
35%
Very Effective
30%
Effecttive
25% Neutral
20% Not Effective
Not at all Effective
15%
10%
5%
0%
Interpretation
33% respondents replied that the team of information security officer is very effective
however 12% respondents replied that the team of information security officer is not
effective
50
Q6. Effectiveness of Data classification policy
35%
30%
10%
5%
0%
Interpretation
31% respondents replied that data classification policy is very effective however 19%
51
Q7. Effectiveness of Security awareness training program
45%
40%
35%
Very Effective
30% Effecttive
25% Neutral
Not Effective
20% Not at all
Effective
15%
10%
5%
0%
Interpretation
28% respondents replied that Security awareness training program is very effective
however 12% respondents replied that Security awareness training program is not
effective
52
Q8. Effectiveness of automation of user-provisioning
45%
40%
35%
Very Effective
30%
Effecttive
25% Neutral
20% Not Effective
Not at all Effective
15%
10%
5%
0%
Interpretation
effective.
53
Q9. Effectiveness of employee screening process
40%
35%
30%
Very Effective
25% Effecttive
Neutral
20% Not Effective
Not at all
15% Effective
10%
5%
0%
Interpretation
34% respondents replied that employee screening process is very effective however
54
Q10. Effectiveness of data disposal procedures
40%
35%
30%
Very Effective
25% Effecttive
Neutral
20%
Not Effective
15% Not at all Effective
10%
5%
0%
Interpretation
32% respondents replied that data disposal procedures is very effective however 8%
55
Q11. Effectiveness of clear office policy
45%
40%
35%
Very Effective
30% Effecttive
25% Neutral
Not Effective
20% Not at all
Effective
15%
10%
5%
0%
Interpretation
35% respondents replied that clear office policy is very effective however 9%
56
Q12. Effectiveness of internal vulnerability scanning
50%
45%
40%
5%
0%
Interpretation
26% respondents replied that internal vulnerability scanning is very effective however
57
Q13. Effectiveness of electronic diary system for compliance checks
50%
45%
40%
35% Very Effective
Effecttive
30% Neutral
25% Not Effective
Not at all
20% Effective
15%
10%
5%
0%
Interpretation
28% respondents replied that electronic diary system for compliance checks is very
effective however 10% respondents replied that electronic diary system for
58
Q14. Overall what will you say about the effectiveness of data and information
40%
35%
30%
Very Effective
25% Effecttive
Neutral
20%
Not Effective
15% Not at all Effective
10%
5%
0%
Interpretation
31% respondents replied that data and information security system is very effective
however 16% respondents replied that data and information security system is not
effective.
59
Q15. Are you aware about management information system at KPMG for data
management and security?
Yes 75 %
No 17 %
Do not know/ Can not say 08 %
80%
70%
60%
50%
40%
30%
20%
10%
0%
Interpretation:
The awareness level among the company officials regarding the existence,
functioning and applicability of management information system at KPMG is high
that is 75 per cent, as per the result of the study.
60
Q16. Do you know that your company should have a management information
system for data management and security?
Yes 72%
No 20 %
Do not know/ Can not say 08 %
80%
70%
60%
50%
40%
30%
20%
10%
0%
Interpretation:
The company officials are aware about their company should have a management
information system for data management and security. 72 per cent of the respondents
do have this awareness as against 20 percent and 08 percent of the respondents who
are either not aware or not able to provide any information in this regard.
61
Q17. Do you agree that there should be a management information system at
KPMG for data management and security?
Agree 68 %
Disagree 12 %
Do not know/ Can not say 20 %
70%
60%
50%
40%
30%
20%
10%
0%
Interpretation:
62
Q18. For what reasons do you feel that there should be management
information system at KPMG for data management and security?
To smoothen operational requirement 27 %
To save time 22 %
To maintain accountability and transparency 30 %
Other reasons 15 %
Do not know/ Can not say 06 %
30%
25%
20%
15%
10%
5%
0%
Interpretation:
To everyone’s surprise, 30 per cent of the respondents feel that it is for accountability
and transparency purpose that company records are maintained and hence the need for
a Revolution in Information Technology Management System. This is followed by the
need for saving time and the requirement of operational smoothness.
63
Q19. Do you agree that the Revolution in Information Technology
Management System in your company can fulfill the needs for which it
needs to be evolved?
Strongly Agree 20 %
Agree 47 %
Disagree 15 %
Strongly Disagree 07 %
Do not know/ Can not say 11 %
50%
45%
40%
35%
30%
25%
20%
15%
10%
5%
0%
Interpretation:
From the above response, it appears that the Revolution in Information Technology
Management System needs to be more or less oriented to achieve its objectives for
which it is sought after. This is evident from the 67 per cent of the respondents’
opinion who have either agreed or strongly agreed in favour of this proposition.
However the response of 22 per cent of the respondents who think otherwise also
speaks something.
64
Q20. Do you think you have skilled professionals in your company for
Information Technology?
Yes 48 %
No 30 %
Do not know/ Can not say 22 %
50%
45%
40%
35%
30%
25%
20%
15%
10%
5%
0%
Interpretation:
65
Q21. What category of professionals do you need to manage your company
Data Security?
Skilled and trained 32 %
Only skilled but not trained 16 %
Non skilled but trained professionals 20 %
Non skilled and non trained professionals 25 %
Others 07 %
35%
30%
25%
20%
15%
10%
5%
0%
Interpretation:
As already stated above in the earlier question, availability of trained and skilled
professionals for data security needs serious attention of the company
66
Q22. Do you agree that your company should give more emphasis on software
than skilled manpower with regard to Information Technology?
Strongly Agree 18 %
Agree 52 %
Disagree 15 %
Strongly Disagree 07 %
Do not know/ Can not say 08 %
60%
50%
40%
30%
20%
10%
0%
Interpretation:
The above response gives an impression that the company should put greater
emphasis on software than skilled manpower for data management.
67
Q23. Do you think that your company can provide software according to the
design and needs of the system?
Yes 86 %
No 10 %
Do not know/ Can not say 04 %
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%
Interpretation:
68
Q24. What is the prime challenge before your company with regard to
Information Technology?
Lack of trained professionals 42 per cent
Maintenance cost 21 per cent
Changing requirements of customers 27 per cent
Other problems 06 per cent
Do not know/ Can not say 04 per cent
45%
40%
35%
30%
25%
20%
15%
10%
5%
0%
Interpretation:
69
CHAPTER-7
RECOMMENDATION &
CONCLUSION
70
RECOMMENDATION & CONCLUSION
In this review we found many examples of good practice with relatively few areas for
improvement. However, data security is a rapidly moving area and demands a process
of continuous improvement.
Most employees were formally required to agree their on-going compliance with data
security policies, but several did not share their policies with third-party handlers of
customer data.
However, surprisingly few had an inventory of information assets (i.e. what data is
held, its sensitivity, who owns it etc.), and only a small number had begun to
to enhance this process. However, only a few performed follow-up checks, and none
Security awareness training approaches varied greatly but the most effective used a
Company has clear desk and some clear office policies, with several performing
penetration tests. However, some had read-only services and these had not been tested
71
KPMG performed quarterly reviews of user rights. To make the review easier for non-
technical line managers, one company had developed its own application to present
There appeared to be good controls in place over end-user applications, with many
having specific policies governing their use. One organization had prevented
Approaches to using live data in test systems varied. One company scrambled and
sanitized customer data before using it for testing, others felt live data could be used
provided user rights were equivalent to the live system, even though test systems are
usually more open to developers and third parties. The Commission would discourage
KPMG was subject to a wide range of compliance checks and audits. However, few
seemed proactive in this area, commissioning their own control reviews and risk
assessments. Instead they tended to rely on the work of others, usually external or
internal audit, whether or not it provided relevant risk coverage. One notable
KPMG has begun to implement workflow applications for user provisioning. This
way they were able to leverage technology to make the joiner/leaver process more
secure.
Procedures for disposal of printed and electronic media were generally good. Many
combined on-site supervision with a certificated audit trail for hardware disposal.
Others removed confidential waste from open office areas on a daily basis.
72
KPMG performed monthly vulnerability scans on its internal servers.
KPMG has an impressive diary system for driving and documenting periodic
compliance checks. The results from some of these checks, notably clear desk policy,
were included in employee performance appraisals. This was a tough but highly
impact IT has on Bank’s performance. Recognizing the importance of IT, since 1997
the Regulator has presented guidelines for banks in a special way via
with IT systems. With each new version, Recommendation D has evolved placing
in requirements fulfilling not only IT but also business, legal and internal audit
departments.
institution such as Bank, Insurance Association PTE, TFI and others is indisputable
and continues to grow over the years. The position of IT services is mostly the
outcome of how the modern financial organizations are dependent on IT tools which
73
The Financial Supervision Commission which serves as the financial sector regulator,
sees the enormous impact of IT sector on the organization's functionality. Through the
changed requirements in the area related to the information processing, giving the
Before taking any actions that address the requirements of the Financial
Recommendation D:
Is not only the IT service obligation, but also the whole Organization such as
risk analysis.
Based on the KPMG experience, the biggest challenge for the institution will be
74
Managing the security breach incidents (Recommendation 20)
22).
Due to the huge complexity of the recommendation D requirements and the short
period of time remaining for its full implementation, the institutions should take
immediate actions in this area. The KPMG support will allow you to complete these
Rapid and resourceful gap identification between the current situation and the
recommendation.
75
Bibliography/REFERENCES
76
BIBLIOGRAPHY/REFERENCES
Computer Security Institute. 2000 Computer Crime and Security Survey, 2000
Online Banking Report The Online Banking Report, 1999 (available from
"UAE bank targeted in major phishing attacks", ITP, 2019. Available at:
http://www.itp.netl579059-uae-banktargeted-in-major-phishing-attack.
Rajnish Tiwari , Stephan Buse and Cornelius Herstatt Customer on the move
onlinebanking-customers-targeted-by-phishing-attack
77
Annexure
78
QUESTIONNAIRE
Q1. From how many years you have been working in KPMG?
Less than 2 Years 2 to less than 4 Years
4 to less than 6 Years More than 6 Years
Q2. Are you involved in the data and information security process at KPMG?
Yes No
If yes then please rate the following from 5 to 1
Where 5 means very effective and 1 means not at all effective
79
Q9. Effectiveness of employee screening process
Very Effective Effective Neutral
Not Effective Not at all Effective
Q14. Overall what will you say about the effectiveness of data and information
security system at KPMG?
Very Effective Effective Neutral
Not Effective Not at all Effective
Q15. Are you aware about management information system at KPMG for data
management and security?
Yes
No
Do not know/ Can not say
Q16. Do you know that your company should have a management information
system for data management and security?
Yes
80
No
Do not know/ Can not say
Q18. For what reasons do you feel that there should be management information
system at KPMG for data management and security?
To smoothen operational requirement
To save time
To maintain accountability and transparency
Other reasons
Do not know/ Can not say
Q20. Do you think you have skilled professionals in your company for Information
Technology?
Yes
No
Do not know/ Can not say
Q21. What category of professionals do you need to manage your company Data
Security?
Skilled and trained
81
Only skilled but not trained
Non skilled but trained professionals
Non skilled and non trained professionals
Others
Q22. Do you agree that your company should give more emphasis on software than
skilled manpower with regard to Information Technology?
Strongly Agree
Agree
Disagree
Strongly Disagree
Do not know/ Can not say
Q23. Do you think that your company can provide software according to the design
and needs of the system?
Yes
No
Do not know/ Can not say
Q24. What is the prime challenge before your company with regard to Information
Technology?
Lack of trained professionals
Maintenance cost
Changing requirements of customers
Other problems
Do not know/ Can not say
82