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Although we found key components of an effective internal control framework, we identified other areas where key improvements in the internal control framework for IT security are needed Our comments and recommendations focus on: Formalizing and strengthening IT security policies and procedures into an overarching IT security program Establishing a security risk management process at an operational level Strengthening the IT security procedural framework between Security Services Unit, and Infrastructure Technology Services and other IM/IT groups Page 8 of 18 A CS IT Security Management Office of the Superintendent of Financial Institutions Canada Audit Consulting Services IT Security Access A CS Diagram 2 Page 9 of 18 A CS Internal Control Elements/Components Office of the Superintendent of Financial Institutions Canada Audit Consulting Services IT Security Access A CS Observations, Assessment and Recommendations Governance: Objective setting operating environment Oversight accountabilities exist Roles and responsibilities are defined, communicated and understood IT security access policy and practices are fully developed Recommendation Formalize and strengthen IT security policies and procedures into an overarching security program incorporating the Policy on Government Security with MITS standards, guidance and practice requirements The Security Services Unit (SSU) and Infrastructure Technology Services (ITS) groups manage and provide IT security services across the Office.. Page 16 of 18 Office of the Superintendent of Financial Institutions Canada A CS Audit Consulting Services IT Security Access A CS Appendix A - Internal Control Criteria Internal Control Criteria (used for audit evaluation purposes) Elements Governance: Objective setting operating environment Risk management Control Processes Components OSFI security governance, objectives, oversight accountabilities, and organization structures exist Roles and responsibilities consistent