The document is a system audit report for the period from April 1, 2012 to March 31, 2013. It contains an annexure with several sections assessing organization policies and procedures, perimeter and environmental security, access control, systems and system security, network and network security, and database and database security. Each section lists key control areas and whether they were found to comply with auditing standards. The report findings provide observations to support compliance or non-compliance.
The document is a system audit report for the period from April 1, 2012 to March 31, 2013. It contains an annexure with several sections assessing organization policies and procedures, perimeter and environmental security, access control, systems and system security, network and network security, and database and database security. Each section lists key control areas and whether they were found to comply with auditing standards. The report findings provide observations to support compliance or non-compliance.
The document is a system audit report for the period from April 1, 2012 to March 31, 2013. It contains an annexure with several sections assessing organization policies and procedures, perimeter and environmental security, access control, systems and system security, network and network security, and database and database security. Each section lists key control areas and whether they were found to comply with auditing standards. The report findings provide observations to support compliance or non-compliance.
The document is a system audit report for the period from April 1, 2012 to March 31, 2013. It contains an annexure with several sections assessing organization policies and procedures, perimeter and environmental security, access control, systems and system security, network and network security, and database and database security. Each section lists key control areas and whether they were found to comply with auditing standards. The report findings provide observations to support compliance or non-compliance.
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Author: Devendra Kulkarni
Format of System Audit Report
(To be on the letter head of the System Auditor) System Audit Report for the period from April 1, 2012 to March 31, 2013 Date: Annexure A Areas of Audit Auditors Remars (Supporting Observations, Findings, References & Substantiation) 1 !r"ani#ation $olicies % $rocedures Description &es ' (o Are olicies related to !nformation Technology & !nformation Security are available, approved by management and complied
!s organi"ation structure & roles and responsibilities defined for !T
Are assets (li#e application, database, servers, net$or#s etc) identified and o$nership assigned to$ards complete lifecycle of these assets by management%
Are operators certified for operating the trading systems &o incident response procedures e'ists Are incidents reported, resolved ( closed and analy"ed for root cause !s escalation of incidents done to management and government organi"ation as applicable, based on criticality, impact and type of incidents
&o lans related to business continuity and disaster recovery e'ist
Are plans related to business continuity and disaster recovery tested and records related to test available
2 $erimeter % )n*ironmental Security Description &es ' (o Member Name: BSE Clearing Number Page 1 of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni Are e)uipment and resources (people, systems, database, net$or# and application) are sited in a manner to protect and prevent ris#s from environmental threats & ha"ards, and opportunities for unauthori"ed access%
hysical Access to the area is controlled by reliable controls and only authori"ed users have access to these areas and to prevent misuse of facility by unauthori"ed persons
*ogs of access to these areas maintained and revie$ed !s storage of bac#up secured commensurate to the ris#s involved and bac#up stored at a geographically separate location from primary
+ontact list for emergency ( crisis e'ists and updated
3 Access +ontrol Representation A+,ro- Access +ontrol rocedure ( rocess A+,Auth- Access +ontrol Authentication A+,$d- Access +ontrol ass$ord .ach of the above have specific attributes specified in number% Description &es ' (o A+,ro/ !s approval and authori"ation a re)uired process for creating user and providing access (physical, system, database, application)
A+,ro0 Are users created by authori"ed personnel A+,ro1 !s there trac# of user id2s created, disabled, enabled, deleted, unloc#ed, log of all such events maintained
A+ ro3 Are pass$ords (of systems ( database ( application) changed in event of employee ( vendor staff leaving the company ( transfers%
A+ ro4 !n case of ne$ user ( pass$ord resets5 is pass$ord communicated to user securely
A+ ro6 A process e'ists to bloc# ( suspend the user (id) on Member Name: BSE Clearing Number Page 2 of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni re)uest from user (case of loss of device ( malicious activity) A+,Auth/ &oes the system (Application ( System ( &atabase) challenges (prompts) all user for authentication
A+,Auth0 !s the mechanism for authentication strong enough so as to control the threats that may be applicable
A+,Auth1 Are users uni)uely identifiable $ith a uni)ue user id A+,Auth3 Are there generic ids e'isting for access A+,Auth4 Are t$o factor authentication for login session implemented for all orders emanating using internet protocol% A+,Auth6 !s ublic 7ey !nfrastructure (7!) based implementation using digital signatures deployed for authentication, supported by one of the agencies certified by government of !ndia% A+,Auth8 Are the t$o factors in the t$o factor authentication frame$or# different A+,$d/ &oes System re)uires changing of pass$ord $hen the user logs in for the first time%
A+,$d0 Are users automatically disabled (*oc#ed) on entering erroneous pass$ord on three consecutive occasions
A+,$d1 &oes system disable (bloc#(loc#) user automatically on e'piry of pass$ord%
A+,$d 3 Are controls implemented to ensure that pass$ord is alphanumeric (preferably $ith one special character), instead of 9ust being alphabets or 9ust numerical%
A+,$d4 Are controls e'isting to ensure that the changed pass$ord cannot be the same as of the last pass$ord
A+,$d6 Are controls e'isting to ensure that the *ogin id of the user and pass$ord should not be the same%
A+,$d8 Are controls e'isting to ensure that the ass$ord should be of minimum si' characters and not more than t$elve characters%
Member Name: BSE Clearing Number Page $ of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni A+,$d: Are controls e'isting to ensure that all pass$ord are secured by encryption mechanism and that encryption mechanism is ade)uate enough to provide safety from applicable ris#s
A+,;&< System ensures that pass$ord is mas#ed at time of entry% A+,SS &oes the system allo$ only authori"ed administrative users to terminate a user2s session%
, -. Systems and System Security
Description &es ' (o Are systems ade)uately managed, controlled and secured &o systems provide security to applications, database and data stored (data at rest) ade)uately using mechanism such as encryption
File system- All volumes of the server hosting the database and ( application has file system that offers enhanced security = For .'- .FS ( >TFS for $indo$s, ?'fs@ for A Bni', e't1 for *inu' etc% &irectory ( File Sharing- &efault file &directory shares and simple file sharing if offered by the operating system are disabled% Sharing if any is authori"ed Are guest accounts disabled ( hashed out ( deleted atches, hot fi'es and service pac#s are updated after appropriate testing
Auditing is enabled for events li#e Account logon events, Account Canagement, Ob9ect access, olicy change, privilege use, system events
&o all users adhere to Access +ontrols li#e described in (Section 1 of Anne'ure A)
A+,ro- Access +ontrol rocedure ( rocess Member Name: BSE Clearing Number Page % of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni / A+,ro/ 0 A+,ro0 1 A+,ro1 3 A+,ro3 3 A+,ro4 4 A+,ro6 A+,Auth- Access +ontrol Authentication / A+,Auth/ 0 A+,Auth0 1 A+,Auth1 A+,$d- Access +ontrol ass$ord / A+,$d/ 0 A+,$d0 1 A+,$d1 3 A+,$d3 4 A+,$d4 6 A+,$d6 8 A+,$d8 : A+,$d: < A+,SS Are system cloc#s synchroni"ed to atomic cloc# to ensure synchroni"ation%
Are critical systems located behind fire$all $ith default rules to deny all traffic and only identified specific application, database and system protocols are allo$ed%
The system is ade)uately protected from mal$are (such as viruses, spy$are %%etc) $ith controls such as antimal$are (
Member Name: BSE Clearing Number Page & of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni antivirus system and that rules ( definitions are updated The entire system is scanned periodically to ensure protection%
/ (et0or and (et0or Security
Description &es ' (o Are net$or#s ade)uately managed, controlled and monitored &oes net$or# provide security to the data, systems and applications in the net$or#%
The net$or# security protocols and interface standards deployed are as per prevalent industry standards
&o all users adhere to Access +ontrols li#e described in (Section 1 of Anne'ure A)
!s information travelling over net$or# (;ired & ( $ireless) ade)uately protected $ith mechanism such as ?>, T*S (SS* ( % ;A0%
!s bac#up net$or# lin# available in case of failure of the primary lin# to the DS.
!s bac#up net$or# lin# available in case of failure of the primary lin# connecting the customers
&oes alternate communications path bet$een employees and the firm e'ists
&oes alternate communications path $ith critical business constituents, ban#s and regulators e'ists
E ?erify location(s) of nodes in the net$or# E ?erify number of nodes in diagram $ith actual E &ate of submission to DS.% Are parameters identified and logged to enable traceability and non@repudiation of orders ( actions performed $ith relevant details li#e ! address, CA+ address, time and other data Member Name: BSE Clearing Number Page ' of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni Are net$or# device cloc#s synchroni"ed to atomic cloc# Are net$or# segments used to segregate critical, non critical and user systems
Are net$or# devices appropriately patched ( upgraded $ith latest firm$are
*og events are identified, monitored, revie$ed and escalated 1 Data2ase and Data2ase Security
Description &es ' (o &o all users adhere to Access +ontrols li#e described in (Section 1 of Anne'ure A)
A+3$ro: Access +ontrol $rocedure ' $rocess / A+,ro/ 0 A+,ro0 1 A+,ro1 3 A+,ro3 3 A+,ro4 4 A+,ro6 A+3Auth: Access +ontrol Authentication / A+,Auth/ 0 A+,Auth0 1 A+,Auth1 A+3$0d: Access +ontrol $ass0ord / A+,$d/ 0 A+,$d0 1 A+,$d1 3 A+,$d3 4 A+,$d4 6 A+,$d6 Member Name: BSE Clearing Number Page ( of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni 8 A+,$d8 : A+,$d: < A+,SS &atabase = Fire$all &D F;/ @ !s the database server located behind a fire$all $ith default rules to deny all traffic% &D F;0 @ !s the database server fire$all is opened only to specific application or $eb servers, and fire$all rules do not allo$ direct client access% &D F;1 @ Fire$all rule change control procedures are in place and notification of rule changes are distributed to System Administrators (SAs) and &atabase Administrators (&DAs)% &D F;3 @ Are fire$all rules for database servers maintained and revie$ed on a regular basis by SAs and &DAs% Secured .nvironment &D,S./ @ !s the database soft$are installed by e'clusive user% !s this user, super user ( Administrator &D,S.0 @!s the database soft$are o$ner account granted the minimum set of operating system rights necessary for database operation% &D,S.1 @!S the database soft$are version is currently supported by the vendor or open source pro9ect% &D,S.3 @Are all unused or unnecessary services or functions of the database are removed or turned off% &D,S.4 @Are unneeded default accounts are removed, or else pass$ords are changed from defaults% &D,S.6 @Are >ull pass$ords used, and have the temporary files from the install process that may contain pass$ords are removed% &D,S.8 @&atabase soft$are is patched to include all current security patches% rovisions are made to maintain security patch levels in a timely fashion% Member Name: BSE Clearing Number Page ) of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni &D,S. : Are all old setup files ( test databases ( sample databases deleted ( secured ( access removed &D,S. < log events are identified audit trails enabled, revie$ed and monitored &D S. /F the cloc# of the system hosting the database is synchroni"ed $ith atomic cloc# &atabase = !C* &D,!C*/@ &o all users of system adhere to Access +ontrols li#e described in Section 3 Anne'ure A &D,!C*0@ The !C* database is hosted on a secure platform and adheres controls li#e mentioned in Section 3 Anne'ure A%% &D,!C*1@ The information in the database used to store( retrieve transaction information is secured $ith controls Are system cloc#s of system hosting the database synchroni"ed to atomic cloc#%
4 )ncryption Description &es ' (o !s all data transmission bet$een the client & bro#er ( member secured through end to end encryption through a secure standardi"ed protocolG
&oes the #ey si"e used for encryption adhere to the policies & ( guidelines mandated by relevant authoritiesG
7ey management procedures for decrypting are documented, available to more than one (authori"ed) person2s, approved by the data proprietor and procedures for secure #ey management follo$ed%
Are the encryption #eys stored in secure location and access procedures documented%
SS* ( T*S used by $eb based application Are certificates issued to the member ( bro#er organi"ation Are the certificates used on the server facilitating confidential information = li#e trade data
Member Name: BSE Clearing Number Page of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni !s the login page and all subse)uent authenticated pages e'clusively accessed over T*S(SS*
rovide the follo$ing details +ertificate !ssuer- (>ame) ?alidity >ot Defore- (&ate) ?alidity >ot After- (&ate) !n case of +lient Server application model (Thic# +lient) &oes the application architecture ade)uately ensure security of information sent over internal ( e'ternal net$or#
!s the information transmitted in encrypted form lease provide supporting letter from vendor on his letterhead% &o the encryption deployed and procedures related to it align to policies and regulations of &oT (&epartment of Telecom) & ( !nformation Technology Act 0FFF
5 Audit 6o" % Monitorin" Description &es ' (o A*C/ @ Are audit logs for systems, databases, net$or#s and applications appropriately identified and enabled for recording of relevant actions and events%
A*C0 @ All session initiation and termination events are logged and audited%
A*C1 @ Are logs revie$ed and e'ceptions ( findings if any escalated%
A*C3 @ Are systems ade)uately capable of noting all transactions conducted $ith sound audit trails available for all transactions
7 +apacity Mana"ement Description &es ' (o +C/ @ Are the resources monitored, tuned and calculations made for future capacity re)uirements to ensure the re)uired performance%
Member Name: BSE Clearing Number Page 1* of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni +C0 @ Are data storage, bac#up systems, system capacities ade)uately available for handling data transfer, and arranged for alternative means of communications in case of !nternet lin# failure%
+C1 @ &o systems have built@in high system availability to address any single point of failure
+C3 @ Are bac#up resources available to ensure that all essential information and soft$are can be bac#ed up and tested for restoration
10 $re8.rade Ris +ontrol: 9alue 6imit per !rder etc: Are the follo$ing S.D! and DS. *imited circulars complied to / @ S.D! circular +!R(CR&(&(13(0F/0 dated &ecember /1, 0F/0 0 = DS. *imited circular no% 0F/0/0/3@/3 dated &ecember /3, 0F/0 1 @ DS. *imited circular no% 0F/1F/F:@0F dated F: Han 0F/1 11 !nline Ris Mana"ement .ools % !rder )ntry Description: &es ' (o
;hether .'change circular 0F/0//F/@/6 dated >ovember /, 0F/0 has been complied $ith I The Ris# Canagement Tool has provisions for setting parameters such as Trading *imits .'posure *imits Order Juantity *imits Order ?alue *imits rice range chec#s >et osition *imits The ris# management tool ensures the follo$ing for all orders, before being placed Online ris# assessment of the orders to be placed% Online ris# monitoring of the orders being placed% Online ris# management of the orders being placed% Member Name: BSE Clearing Number Page 11 of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni &oes system allo$ only authori"ed administrative user to alter the ris# parameters of users &oes system allo$ manual placement (through approved mechanism) for allo$ing orders that do not fit the system based ris# control parameter%
Are orders successful ( unsuccessful or valid ( invalid are logged, revie$ed and auditedby the ris# management system
Appropriate validation of all ris# parameters is done before placing the order
Order .ntry &escription Kes ( >o Only duly authori"ed client2s orders are allo$ed to be placed% Order entry for ro types of orders is e'ecuted through specific user ids%
The system does not have an order matching system and all orders are passed on to the e'change trading system for matching% on the basis of priority of receipt of the orders from the clients
12 Features of System Scope- Application Description &es ' (o Are all servers used for routing orders to DS. *td trading system are hosted (geographically located) in !ndia%
&oes system allo$s only authori"ed and validated users to establish a session $ith the system%
&oes system allo$ only authori"ed administrative users to terminate a users session%
System deployed routes the orders in neutral manner Member Name: BSE Clearing Number Page 12 of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni Features of system have been submitted to DS. *td% &oes system have uni)ue identification numbering system for all orders to identify trades uni)uely and all orders $ith time stamp are available $ith reference to the uni)ue identification number
!n case no activity by the client, does the system provide automatic trading session logout
!n case of failure of service ( system ( facility (for e' @ net$or#, application) , alternative modes of communications for placing orders are available
rice Droadcast &oes system allo$s order entry and confirmation of order is provided to the user on submission of the order%
&oes system provide order modification ( cancellation facilities%
&oes system have capability to provide trade confirmation to the user, along $ith history of trades for the day%
Allo$ for chec#ing the pending orders i%e% the orders that have not yet traded or partially traded%
rovides feature of reporting the trades happened Allo$s for the reporting of client $ise ( user $ise margin re)uirements as $ell as payment and delivery obligations%
;hether the System uses authentication measures li#e smart cards, biometric authentication etc%
;hether the system has a second level of pass$ord control for critical features
!s periodic verification of B++ & location details of data done ;herever applicable session login credential details are not stored on the devices used for trading
Are features available in the system to identify !C*@!DT( ST;T (Cobile) ( SOR ( &CA orders, trades and related data%
Member Name: BSE Clearing Number Page 1$ of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni Reporting R/- Are there features ( facilities available to generate C!S reports for reporting to e'change, S.D! or other relevant regulators% R0- Are procedures ( processes set for reporting and lists ( chec#list used for such purposes% 13 -M6 ;-<. =-nternet <ased .radin"> =!rder Routin" System> Scope- Application, &atabase, System & >et$or# as applicable Description &es ' (o Organi"ational policies & procedures e'ists and are follo$ed for !C* ( !DT (Ref Section / of Anne'ure A)
erimeter & .nvironmental Security controls e'ists and are follo$ed (Ref Section 0 of Anne'ure A)
+ontrols related to access e'ists (Ref Section 1 of Anne'ure A) !T Systems and System Security +ontrols e'ists and are adhered to (Ref Section 3 of Anne'ure A)
>et$or# and >et$or# Security controls e'ists and are adhered to (Ref Section 4 of Anne'ure A)
&atabase deployed adhere to database and database security controls (Ref Section 6 of Anne'ure A)
.ncryption controls are deployed and applicable procedures are adhered to (Ref Section 8 of Anne'ure A)
Audit logs for activities are registered and monitoring controls e'ist (Ref Section : of Anne'ure A)
+apacity related procedures, processes and controls are deployed and monitored (Ref Section < of Anne'ure A)
Online Ris# Canagement Tools and Order .ntry controls as applicable are follo$ed for all orders placed (Ref Section /F of Anne'ure A)
Are features of system ade)uately available, controlled as applicable (Ref Section // of Anne'ure A)
Member Name: BSE Clearing Number Page 1% of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni rovide !nstallation &etails (!C*) Total number of !C* !&s !C* version (!C* Trading Soft$are ?ersion Ris# Administration ( Canager ?ersion Front .nd ( Order lacement ?ersion >umber of Bsers *ogged !n ( hoo#ed on to the net$or# incl% privileges of each >umber of authori"ed users on the system >umber of active clients Activity & System *ogs
Are processes & procedures implemented to ensure that norms mentioned in S.D! +ircular ( &irectives regarding to !nternet Dased Trading adhered to (refer / @ SC&R(O*!+K(+!R@F6 (0FFF &ated Hanuary 1/, 0FFF 0 @ +!R(CR&(&(:(0F// &ated Hune 1F, 0F//) Are they complied
;ith reference to DS. *imited notice = notice no @ 0F/1F/0:@ 05 dated 0: Han 0F/1 ;ith the implementation of T$o@factor authentication, is the automatic e'piry of pass$ord revised % 1, Securities .radin" ?sin" @ireless .echnolo"y AMo2ile .radin"B Scope- Application, &atabase, System & >et$or# as applicable Description &es ' (o Are all relevant re)uirements as applicable to internet based trading being adhered to securities trading using $ireless technology
!s ST;T order routing is available to all clients and they are communicated all features, possible ris#s, rights, responsibilities and liabilities associated $ith the ST;T facility% &oes the client desirous of availing such (ST;T) facility has to do so by entering into a bro#er@client agreement, as applicable% For the e'isting clients, is the same implemented through an addendum to the e'isting bro#er@client agreement, as Member Name: BSE Clearing Number Page 1& of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni applicable% !n case of issues due to form factor, has it been ensured that minimum information has been given $ith addresses of the internet $eb site ($eb page $here detailed information $ould be available% The application used for mobile trading is / = 1 rd party solution from empanelled vendor $ith DS. 0 = in house developed mobile trading solution approved by DS.% lease provide references for the above applicable cases% !s mobile trading an e'tension of internet based trading (Thin +lient)
!n case it is a thic# client provide the details of the architecture Order Status information is ade)uately informed to the user through appropriate mechanism
Appropriate validation of all ris# parameters before placing the order is done prior to placing order in Cobile Trading
Organi"ational policies & procedures e'ists and are follo$ed for ST;T (Ref Section / of Anne'ure A)
erimeter & .nvironmental Security controls e'ists and are follo$ed (Ref Section 0 of Anne'ure A)
+ontrols related to access e'ists (Ref Section 1 of Anne'ure A) !T Systems and System Security +ontrols e'ists and are adhered to (Ref Section 3 of Anne'ure A)
>et$or# and >et$or# Security controls e'ists and are adhered to (Ref Section 4 of Anne'ure A)
&atabase deployed adhere to database and database security controls (Ref Section 6 of Anne'ure A)
.ncryption controls are deployed and applicable procedures are adhered to (Ref Section 8 of Anne'ure A)
Member Name: BSE Clearing Number Page 1' of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni Audit logs for activities are registered and monitoring controls e'ist (Ref Section : of Anne'ure A)
+apacity related procedures, processes and controls are deployed and monitored (Ref Section < of Anne'ure A)
Online Ris# Canagement Tools and Order .ntry controls as applicable are follo$ed (Ref Section /F of Anne'ure A)
Are features of system ade)uately available, controlled as applicable (Ref Section // of Anne'ure A)
Are processes & procedures implemented to ensure that norms mentioned in S.D! +ircular ( &irectives regarding to ST;T adhered to (refer @ / @ +!R(CR&(&(04(0F/F &ated August 08,0F/F 0 @ +!R(CR&(&(:(0F// &ated Hune 1F, 0F//) Are they complied
;ith reference to DS. *imited notice = notice no @ 0F/1F/0:@ 05 dated 0: Han 0F/1 ;ith the implementation of T$o@factor authentication, is the automatic e'piry of pass$ord revised% 1/ Smart !rder Routin" =S!R> Scope- Application, &atabase, System Description Details !s smart order routing is available to all clients and they are communicated all features, possible ris#s, rights, responsibilities and liabilities associated $ith the smart order routing facility%
&oes the client desirous of availing such (SOR) facility has to do so by entering into a bro#er@client agreement, as applicable% For the e'isting clients, is the same implemented through an addendum to the e'isting bro#er@client agreement, as applicable% Member Name: BSE Clearing Number Page 1( of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni Are all type of trades ( orders e'ecutable as chosen by the user and user re)uests for specific orders not to be used under SOR facility recorded and documented
!s SOR permitted for all orders $ithout restricting any specific type of order, and that choice of orders is left to client%
Organi"ational policies & procedures e'ists and are follo$ed for SOR (Ref Section / of Anne'ure A)
erimeter & .nvironmental Security controls e'ists and are follo$ed (Ref Section 0 of Anne'ure A) +ontrols related to access e'ists (Ref Section 1 of Anne'ure A) !T Systems and System Security +ontrols e'ists and are adhered to (Ref Section 3 of Anne'ure A) >et$or# and >et$or# Security controls e'ists and are adhered to (Ref Section 4 of Anne'ure A) &atabase deployed adhere to database and database security controls (Ref Section 6 of Anne'ure A) .ncryption controls are deployed and applicable procedures are adhered to (Ref Section 8 of Anne'ure A) Audit logs for activities are registered and monitoring controls e'ist (Ref Section : of Anne'ure A) +apacity related procedures, processes and controls are deployed and monitored (Ref Section < of Anne'ure A) Online Ris# Canagement Tools and Order .ntry controls as applicable are follo$ed for all orders placed (Ref Section /F of Anne'ure A) Are features of system ade)uately available, controlled as applicable (Ref Section // of Anne'ure A) Order &ecision O&/- Are all activities related to orders and trade logged to facilitate audit trail and records maintained along $ith the details such as orders, trades and data points for the basis of decision Member Name: BSE Clearing Number Page 1) of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni O&0- is there facility for logging data related to orders ( trades (on random sampling ( continuous basis) used to support the decision of trade ( order% !s it being used, revie$ed and audited% &oes the application monitors best bids and offers and updates instantly as the mar#et moves-
&oes the application provide transparency in terms of time delays
Are controls available and implemented to ensure that orders thorough SOR are placed at recogni"ed stoc# e'changes only% &oes functionality e'ists to specify for individual orders for $hich they do not $ant to route the order using SOR
Are $ell documented records available to support of not using SOR for particular order by client ($ho has availed SOR facility) Are processes & procedures implemented to ensure that norms mentioned in S.D! +ircular ( &irectives regarding to ST;T adhered to (for .' / @ +!R(CR&(&(06(0F/F &ated August 08, 0F/F 0 @ +!R(CR&(&(16(0F/F &ated &ecember F<, 0F/F) Are they complied
11 Direct Maret Access Scope- Application, &atabase, System Description &es ' (o +lients having access to &CA have been provided access after e'ecution of agreement $ith conditions as prescribed in the LCodel AgreementM by DS. and such agreement is valid currently%
Organi"ational policies & procedures e'ists and are follo$ed for SOR (Ref Section / of Anne'ure A)
erimeter & .nvironmental Security controls e'ists and are follo$ed (Ref Section 0 of Anne'ure A)
Member Name: BSE Clearing Number Page 1 of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni +ontrols related to access e'ists (Ref Section 1 of Anne'ure A) !T Systems and System Security +ontrols e'ists and are adhered to (Ref Section 3 of Anne'ure A) >et$or# and >et$or# Security controls e'ists and are adhered to (Ref Section 4 of Anne'ure A) &atabase deployed adhere to database and database security controls (Ref Section 6 of Anne'ure A) .ncryption controls are deployed and applicable procedures are adhered to (Ref Section 8 of Anne'ure A) Audit logs for activities are registered and monitoring controls e'ist (Ref Section : of Anne'ure A) +apacity related procedures, processes and controls are deployed and monitored (Ref Section < of Anne'ure A) Online Ris# Canagement Tools and Order .ntry controls as applicable are follo$ed for all orders placed (Ref Section /F of Anne'ure A) Are features of system ade)uately available, controlled as applicable (Ref Section // of Anne'ure A) Are uni)ue identification numbers given as in case of internet based trading, to identify trades and orders done using &CA and log of events $ith timestamp are available $ith reference to the uni)ue identification number and such records are available for minimum of 4 years Are there controls available and implemented in the system for &CA order mas#ing to prevent front running of the orders%
Appropriate validation of all ris# parameters is done to ensure that trading limits( e'posure limits( position limits are set for all &CA clients
Details of the -M6 -DCs used 2y the tradin" mem2ers: Member Name: BSE Clearing Number Page 2* of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni +learin" (o: 33333333333333333 -M6 -D Soft0are Details=-nhouse' 9endor (ame> $urpose of procurement -M6 6ocation =Address> Date of acti*ation: /% ;hether the re)uired details of all the !ds created in the !C* server of the trading member, for any purpose (vi"% administration, branch administration, surveillance, ris# management, trading, testing, etc) and any changes therein, have been uploaded to the .'changeI !f no, please give details K.S(>O 0% ;hether all the !C* user ids created in the !C* server of the trading member has been mapped to /6 digits *O+AT!O> !& on one@to@one basis and a record of the same is maintainedI K.S(>O Member Name: BSE Clearing Number Page 21 of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni Annexure < =!ptional> Areas of Audit Auditors Remars (Supporting Observations, Findings, References & Substantiation) 14 $olicies, $rocedures and Documents A*aila2ility Description &es ' (o !nformation Security olicy ass$ord olicy Bser Canagement and Access +ontrol olicy >et$or# Security olicy Application Soft$are olicy Dac#up olicy +hange Canagement olicy D+ and Response Canagement olicy Audit Trail olicy Other policies follo$ed if any and its reference 15 Appro*als, undertain", a"reements, policies: Description &es ' (o / @ !nternet Trading 0 @ SOR 1 @ ;ireless (Cobile Trading) 3 @ &CA For the above segments are the follo$ing documents available +opy of application to e'change Approval ( +opy of approval from e'change Bnderta#ing(s) provided as per relevant circulars as re)uired by e'change ( S.D! Bnderta#ing provided regarding the !C* system as per relevant circulars ;hether the !nsurance policy of the Cember covers the additional ris# of usage of !C* and or !nternet Trading 17 +han"e Mana"ement Description &es ' (o +hanges to the system supporting trading are made in a planned manner +hanges are made by duly authori"ed personnel Ris# involved in the implementation of the changes duly factored in Member Name: BSE Clearing Number Page 22 of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni The implemented change duly approved and process documented The change re)uest process documented +hange implementation process supervised to ensure system integrity and continuity Bser acceptance of the change documented Bnplanned changes duly authori"ed and the manner of change documented later S&*+ documentation and procedures if the installed !C* system is developed in@house
20 ?ser Mana"ement Description &es ' (o >o% of user !ds created All users are uni)uely identified through issue of uni)ue !C* ids% >o% of Bsers are deleted and logs are maintained >o% of Bsers are disabled and logs are maintained >o% of users reissued and logs are maintained >o% of users $hose accounts are loc#ed $ith logs The users in the system are created by authori"ed personnel at server level 21 Redundancy % <acup in case of System Failure Description &es ' (o <acups for the critical system components Nate$ay ( &atabase Server Audit Trails !C* router >et$or# S$itch +ommunication lines -nfrastructure 2reado0n 2acup .lectricity ;ater Air +onditioning Alternate physical location of employees been made in case of non availability of the primary site rovisions for Doo#s and records bac#up and recovery (hard copy and electronic)% Cission@critical systems been identified and provision for bac#up for such systems been made Are bac#up and recovery procedures defined, approved and documented Are bac#up and restoration records and logs maintained% Member Name: BSE Clearing Number Page 2$ of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni Are bac#up media stored safely in line $ith ris#s 22 Daily !perational Acti*ities Description &es ' (o rovision for Degin of day activity Audit Trails Access *ogs Transaction *ogs Dac#up *ogs Alert *ogs Activity *ogs Cisc (lease specify)- rovision for .nd of day activity System for log monitoring, escalation & corrective measures ta#en, if any% The !C* solution should not in any manner suggest to the user by default the name of .'change, scrip and segment etc% !t is the user $ho should have the option to select the same% 23 Response $rocedures Description Access +ontrol failure Deginning of &ay failure .nd of &ay failure Other system rocesses failure 2,:!ther information Description Date0ay $arameters E Trader !& +ash Se"ment E !C* !& E ! Address E (DS. >et$or#) E ?SAT !& E *eased *ine !& F%! Se"ment E &!C* !& E ! Address E (DS. >et$or#) E ?SAT !& E *eased *ine !& Member Name: BSE Clearing Number Page 2% of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni 2/: Auditor comments to0ards data and information related to trade and orders +onfidentiality: -nte"rity: A*aila2ility: (on8Repudiation: Member Name: BSE Clearing Number Page 2& of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni Annexure + =Mandatory> !>FORCAT!O> SKST.C AB&!T OF,,,,,,,,,,,,,,,,,,,,,,,,,,,,,, Sr (o Area of Audit +lassification of +ontrols in Annexure A S ' A ' - +lassification of +ontrols in Annexure < S ' A ' - / Organi"ation structure e'ists and supports governance through policies, procedures, proceses and guidelines% >A 0 Systems & processes related to perimeter and environmental security controls e'ists >A 1 Access, Authentication and Authori"ation to systems (systems, database, os, net$or#s etc) is commiserate $ith the importance of the systems >A 3 Systems follo$ policies & procedures to protect from threats that might e'ploit the system% >A 4 >et$or# & >et$or# Security follo$ policies & procedures to protect from threats that might e'ploit the system% >A 6 &atabase systems follo$ policies & procedures to protect from threats that might e'ploit the system% >A 8 rocesses and procedures for encryption deployed for protection of data is established >A : Audit logging and monitoring are established to identify and determine accountability of actions performed% >A < rocesses and procedures follo$ed for capacity management are established% >A /F re@Trade ris# control- ?alue limit per order etc% are implemented and adhere to all applicable circulars from S.D! & DS. *imited >A // Online ris# management tool and order entry are supported% >A /0 Features of system are established and implemented >A /1 !C* ( !DT systems are controlled and adhere to all applicable circulars from S.D! & DS. *imited >A Member Name: BSE Clearing Number Page 2' of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni /3 Securities Trading using ;ireless Technology (Cobile Trading) systems are controlled and adhere to all applicable circulars from S.D! & DS. *imited >A /4 Smart Order Routing systems are controlled and adhere to all applicable circulars from S.D! & DS. *imited >A /6 &irect Car#et Access systems are controlled and adhere to all applicable circulars from S.D! & DS. *imited >A /8 Are policies available, implemented and revie$ed for implementation% >A /: Are communication documents vi" application, approval, & underta#ing available, valid and secured% >A /< !s change management an established process and procedures for change are implemented in controlled manner% >A 0F !s user management done according to policy defined and procedures adhere to the policy, records for implementation and adherence are available% >A 0/ !s redundancy and bac#up available and tested in case of system failure% >A 00 Are daily operational activities controlled and logged to demonstrate control >A 01 Are response procedures available and records of use indicate established procedure% >A 03 !s information related to parameters available and updated periodically >A 04 Any other comment by auditor to$ards data and information related to trade and orders >A Member Name: BSE Clearing Number Page 2( of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni Declaration: Mem2er Summary Sr O Trading Facilities Trading Facility OfferedI (Kes ( >o) Trading Facility AuditedI (Kes ( >o) / !C* = !DT Trading (!nternet Dased Trading) 0 ST;T (Securities Trading Bsing ;ireless Technology) 1 SOR (Smart Order Routing) 3 &CA (&irect Car#et Access) All the branches $here !C*@!DT ( ST;T( &CA facility is provided, have been audited and consolidated report has been submitted% ! undersigned assure of circulars issued by S.D! an DS. *imited have been referenced for chec#ing the compliances and that the contents of the report as per audit performed by me and declare there is no conflict of interest $ith respect to the member being audited% Audit recommendations (if any) in relation to System Audit report for the year ended Carch 1/, 0F/0 that have been duly implemented ( not implemented are mentioned separately as anne'ure (as a part of System Audit report)% !n case you have been rated as LCedium(;ea#M in any areas by System auditor bet$een April /, 0F/0 to Carch 1/, 0F/1 (prior to granting approval for !nternet based Trading( &irect Car#et Access( SOR( ;ireless securities trading e'cept for Algorithmic Trading) please submit LAction Ta#en ReportM duly certified by your system auditor detailing the actions ta#en by you on various individual LCedium( ;ea# areas% ,,,,,,,,,,,, Signature (Full >ame of the Auditor & Auditing firm) +!SA Registration >umber- &ate- lace- Member Name: BSE Clearing Number Page 2) of 2 Auditor Name C!SA "egi#tration No: Author: Devendra Kulkarni (ote: +riteria for )*aluation of +ontrols are indicated 2elo0, 2ased on these EArea of AuditF as mentioned in Annexure A % < are to 2e rated: .valuation of +ontrols &escription Strong +ontrols are said to be Strong if ob9ectives are fully complied $ith and no material $ea#nesses are found% Ade)uate +ontrols are said to be Ade)uate if ob9ectives are substantially complied $ith and no material $ea#ness result in substantial ris# e'posure due to non@compliance +ompensatory controls e'ist $hich reduce the ris# e'posure to ma#e it immaterial vis =a@vis the non@compliance $ith the criteria% !nade)uate +ontrols are said to be !nade)uate if ob9ectives are not complied $ith% +ompensatory controls fail to reduce the ris# so as to ma#e it immaterial vis@P@vis the non@ compliance $ith the compliance criteria% Member Name: BSE Clearing Number Page 2 of 2 Auditor Name C!SA "egi#tration No: