What evidence do auditors commonly ask for on CPS 234 para 32 Internal audit review of control design and operation?

Internal audit plan showing information security audits and coverage over time; Internal audit reports on security control design and operating effectiveness; Audit coverage of third-party and related-party controls; Audit committee minutes receiving and discussing security audit findings; Issue tracking for internal audit findings to closure.

What is the most common gap auditors find on CPS 234 para 32?

Internal audit looks at policies and process but never tests operating effectiveness

APRA CPS 234 · Internal audit (paras 32 to 34)

`CPS 234 para 32` Internal audit review of control design and operation

Internal audit's work has to cover whether information security controls are well designed and whether they operate effectively, including controls run by related and third parties (this is information security control assurance).

Source: APRA CPS 234, CPS 234 para 32. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open APRA CPS 234 in the compliance library.

Applies to APRA-regulated entities.

artefacts

held by a system

at each review

hard

to go live

Policy repository / GRC workspace

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

Internal audit reports on security control design and operating effectiveness · Policy repository / GRC workspace
Audit committee minutes receiving and discussing security audit findings · Policy repository / GRC workspace

governing documentDocuments that govern the control

Internal audit plan showing information security audits and coverage over time · Policy repository / GRC workspace
Audit coverage of third-party and related-party controls · Vendor register / contract repository
Issue tracking for internal audit findings to closure · Policy repository / GRC workspace

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

Internal audit looks at policies and process but never tests operating effectiveness
Third-party-run controls excluded from internal audit scope
Security audits deferred year after year in the audit plan

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

Build my evidence sheet

CPS 234 para 31 Review the sufficiency of the testing program · CPS 234 para 33 Skilled personnel for control assurance