POL00029713 - Post Office Limited Assurance Review Report AR12/050 for December 2012

Evidence on official site

POL00029713
POL00029713

Follow Up Review of Key
System Controls in Horizon

Horizon
System

Controls Post Office Limited

Assurance Review

Report: AR12/050 December 2012

TSS Internal Audit & Risk Management aT EEE
POL00029713
POL00029713

Context and Objectives

The Post Office Limited (POL) network of some 11,000 branches processes client and business transactions in excess of £100 billion annually. The majority
of transactions are conducted on behalf of other parties, for example, receiving payment for domestic utility bills and paying out National Savings.
Customer transactions are captured through the Horizon electronic point of sale system in branches and transmitted to central systems (utility payment,
external banking and POL finance systems) throughout the day.

The overall objective of the review was to assess the degree to which the issues raised in the 2011/12 Ernst & Young (E&Y) Management Letter regarding
the Horizon control environment have been addressed by management. Where actions have not been completed, or were completed part way through
the financial year 2012/13 any existing compensating controls were also assessed.

Key Findings

The 2011/12 E&Y Management Letter identified a number of areas for improving Horizon system controls. This Internal Audit & Risk Management
(IA&RM) review assessed the degree to which management action plans have progressed to address the issues which related to Horizon only. Overall,
the majority of the areas for improvement identified by E&Y have been completed by POL and third party supplier management. There remain a few
items that require further input from management to ensure that all controls have either been designed and implemented or that the risks have been
accepted by POL, specifically:

1. Generic privileged accounts: Generic privileged accounts remain in use on Horizon by Fujitsu. A paper was presented to the November POL Risk and
Compliance Committee where any residual business risks associated with this control were accepted by IT and Change on behalf of the business.

Implication: Accountability in the application may not be fully controlled, leading to a risk of inappropriate activities being undertaken within the system.

2. Password parameters: E&Y recommended that POL operate a single Information Security Policy, however POL management use two separate policies,
one for Horizon and one for POLSAP respectively. Any residual business risks associated with this control were accepted by IT and Change on behalf of the
business at the November POL Risk and Compliance Committee meeting.

In addition, POL management have not completed the E&Y recommendation to review key password parameters, as these have not been defined.
Testing also identified two password parameters configured in the Horizon application that did not comply with the Horizon Security Policy.

Implication: Unauthorised access may occur, leading to a risk of inappropriate activities being undertaken within the system.

5 SSE SESE ESS TSS EERE Internal Audit & Risk Management
Confidential Page 2 of 11
POL00029713
POL00029713

ee

Conclusion: POL management have made progress against the areas for improvement identified by E&Y. Where areas that have been improved had not
been addressed from the beginning of the year testing has demonstrated that compensating controls have been in operation for the financial year
starting in April 2012. There remain, as noted above, some areas where POL management should either accept the risk of not implementing the E&Y
recommendations in full, or where further work is required to strengthen the control environment. The findings, summarised on pages 4 — 8 have been
shared with E&Y and reflect the IA&RM assessment as at the end of November 2012.

Control Environment Rating: Recommended Actions Partially Implemented.

Management Comment

We agree with this report and its findings, and we have already begun to progress the agreed action plan within the agreed timescales — Lesley J Sewell

5 SSE SESE ESS TSS EERE Internal Audit & Risk Management
Confidential Page 3 of 11
POL00029713
POL00029713

IT Manageme

Disciplines and Transaction C

The summary findings from the review are noted below and represent the status of controls at 30" November 2012. Testing has been performed from
the control remediation date. Where actions have not been completed, or were completed part way through the financial year 2012/13 any existing
compensating controls have been assessed from 1* April 2012.

Remediation

E&Y Recommendation Summary date What was done What was found

Change management - Retain
documentation to show the . Documentation for the change
. Inspected the testing and release .

evidence that POL has been st . management procedure was in place for
. . cogs , 1* April management processes and performed st .

1 I involved in authorisation, testing . a sample of changes tested from 1* April

2012 walkthroughs and sample testing of h

and approval of changes. In completed changes on Horizon to 30" November 2012. Controls were

particular document evidence P e . found to be operating effectively.

from 3rd party suppliers.

Through consultation with Fujitsu, POL
management have confirmed that
privileged generic accounts are
controlled and will not be replaced with
individual accounts.

Generic privileged accounts -
Consider a review of generic

2 I privileged accounts to determine I Nov2012 I Inspected the review of generic The residual business risk associated

if these accounts can be replaced ivi

' individual P privileged accounts performed by POL with this control was accepted by IT and

by individual user accounts. management for both POL and third Change at the November POL Risk &
party users.

Compliance Committee on behalf of the
business.

Due to the completion of this
recommendation part way through the I A review of generic privileged accounts
year, inspected the review of privileged I On a monthly basis, including those

Generic privileged accounts - Horizon activity at the Information I operated by third parties, commenced in
Consider monitoring controls to Security Management Forum (ISMF) I November 2012 at the ISMF. Accounts
3 help ensure robust — security Nov 2012 I from 1* April to 2" November 2012. with privileged access in the application
practices are in place, particularly have been reviewed at the ISMF since
those operated by third party April 2012 and consequently mitigating
service providers. controls were found to have been
operating effectively since the start of

the financial year.

5 SSE SESE ESS TSS EERE Internal Audit & Risk Management

Confidential Page 4 of 11
POL00029713
POL00029713

ZY R alae
&Y Recommendatio at was done a ound
date
Logical security settings — Set an All Oracle databases — supporting
encrypted assword. for the 4st April Inspected the password policy for the I Horizon were upgraded to Oracle
4 IiSTPNER ORD file on all Oracle so LISTENER.ORA file and reviewed the I version 10gR2 prior to April 2012. This
databases supporting Horizon recommendation status. upgrade enabled the encryption of
PP 8 . passwords on this file.
POL management confirmed that key
password parameters will be reviewed
Logical Security Settings - Inspected the review of privileged er he annual basis. Presently, a the
Consider monitoring controls to Horizon activity at the ISMF from 1* horisan = heaton has not been
help ensure robust — security April to 2"? November 2012. Pp
5 . : . N/A performed. Password parameters on
settings are in place, particularly Windows Active Directory were mainl
those operated by third party Tested the recommendation status ry . . y
. - ae found to meet those defined in the
service providers. with POL and Fujitsu management. . . .
Horizon Security Policy. However two
exceptions were noted and are listed in
Appendix A.
POL management have presented a
d . requirement to have one security
Passwor ‘ ores f Review policy covering Horizon and another
an up' ate ne nrormation covering another application, POLSAP.
Security Policy’ to meet the . . Security policies are maintained and
recommended generally-accepted Inspected the password policy covering reviewed through periodic reviews and
6 practice password settings N/A Horizon used by POL users and third POL management confirmed the
outlined below. Management party users and reviewed the appropriateness of the security policies
should also consider having only recommendation status. during this review
one policy document outlining the . : . .
password guidelines that apply to The residual business risk associated
both Horizon and POLSAP. with this control was accepted by IT
, and Change at the November POL Risk
& Compliance Committee.

Confidential

Internal Audit & Risk Management

Page 5 of 11
E&Y Recommendation Summary

Remediation
date

POL00029713

POL00029713

action Controls Summary Findings (cont)

What was done

What was found

Password Parameters - Configure
all network, application and
supporting infrastructure
components in line with the policy
requirements. For infrastructure
supporting the applications in
scope, where the critical
7 I authentication level is at the
POLSAP application layer or Active
Directory, management should
consider the risk of unauthorised
access to the financial data by
privileged accounts on the Oracle
database and Linux operating
system.

N/A

Inspected password parameters for the
Oracle, Linux and Windows
environments supporting the Horizon
application used by POL and third party
users and reviewed the E&Y
recommendation status.

Password parameters are set in the
Windows Active Directory Group
Policy. The Group Policy overrides
password configurations on the local
Oracle and Linux systems that make up
the Horizon environment. Password
parameters on Windows Active
Directory were mainly found to meet
those defined in the Horizon Security
Policy. However two exceptions were
noted and are listed in Appendix A.

Passwords for privileged accounts on
the Oracle database and Linux
operating systems conform with the
Horizon Security Policy and are
restricted to a small number of system
administrators in Belfast. Passwords
are enforced manually in line with the
Horizon Security Policy. However the
process for manually changing
privileged passwords on the Oracle and
Linux operating systems needs to be
documented within the policy.

Confidential

Internal Audit & Risk Management

Page 6 of 11
POL00029713
POL00029713

E&Y Recommendation Summary

Password Parameters -
Management should consider
implementing monitoring controls

Remediation

date

What was done

Inspected the review of privileged
Horizon activity at the ISMF from 1*

What was found

POL management confirmed that key
password parameters will be reviewed
on an annual basis. Presently, a review
of key password parameters on the
Horizon application has not been

8 I to help ensure robust security N/A April to 2° November 2012 and I performed. Password parameters on
settings are in place, particularly reviewed the recommendation status I Windows Active Directory were mainly
those operated by third party with POL and Fujitsu management. found to meet those defined in the
service providers. Horizon Security Policy. However two

exceptions were noted and are listed in
Appendix A.
Periodic User Access Reviews and
Monitoring Controls - Consider a A review of privileged and generic user
POL owned periodic review of . accounts on the Horizon application
. : Inspected the review of user access . .
appropriateness of access to in- was carried out in October 2012 and
ge . performed by management for both , th
scope applications and their POL and third party users on Horizon was signed off on 8" November at the
supporting infrastructure. The Party . ISMF as completed. Accounts with

9 implementation of this review will Nov 2012 Due to the completion of this privileged access in the application
assist in the identification of . have been reviewed at the ISMF since
inappropriate access and potential recommendation during the year, April 2012 and consequently mitigatin

Pprop e IA&RM_ inspected the review of PI q y gating

segregation of duties conflicts. In
addition, this will act as an
additional control to help detect
users that no longer require access
to the financial applications.

privileged Horizon activity at the ISMF
from 1* April to 2"4 November 2012.

controls were found to have been
operating effectively since the start of
the financial year.

Confidential

Internal Audit & Risk Management

Page 7 of 11
agement Disciplines and T

E&Y Recommendation Summary

Remediation

What was done

POL00029713

POL00029713

What was found

User Administration - Strengthen
the existing user administration

date

Documentation for the user
administration procedure for new and
modified access on the Horizon

processes within Fujitsu so that st . Inspected user administration ae °
10 . . 1* April age application was in place for a sample of
documentation supporting the arrangements for new and modified i" :
request, approval and set-up of 2012 Fujitsu technical support staff. Fujitsu technical support staff tested
quest, app . po PP . from 1* April to 30° November 2012.
access to the Horizon estate is a
. Controls were found to be operating
retained.
effectively.
User Administration Process -
Strengthen the revocation of
access process such that IT is
notified in a timely manner when Documentation for the user
a terminated employee no longer administration procedure for leavers
requires access to the Horizon on the Horizon application was in place
estate. Consideration should be for a sample of Fujitsu technical
given to the HR department 1 April Inspected user administration I support staff tested from 1* April to
11) sending a list of terminated soln arrangements for Fujitsu technical I 30° November 2012. Fujitsu
employees to the IT department support staff. administrators were notified on a

on a periodic basis, e.g. weekly or
fortnightly. This is in addition to
the line manager notifying the IT
department of the terminated
employee. All documentation
supporting this process should be
retained.

timely basis and user accounts were
removed on or before the leave date
on the request. Controls were found to
be operating effectively.

Confidential

Internal Audit & Risk Management

Page 8 of 11
POL00029713
POL00029713

What is Being

The following actions have been agreed with management against the observations made in this report.
Generic privileged accounts

1. Management should set out the reasons for having generic privileged accounts on Horizon and present this to the Risk & Compliance
Committee for review. Priority 2 (Andy Jones - Completed)

Password parameters

2. Management should set out the reasons for operating two Information Security Policies, covering Horizon and POLSAP, and present this to
the Risk & Compliance Committee for review. Priority 2 (Andy Jones - Completed)

3. Ensure that the Horizon Security Policy is reviewed and changed to reflect the configuration of the password parameters detailed within
Appendix A. Priority 2 (Mark Pearce — January 2013)

4. Ensure that the process for manually changing privileged account passwords on the Oracle databases and Linux operating systems is
documented within the Horizon Security Policy. Priority 2 (Mark Pearce — January 2013)

5. Define key password parameters to be reviewed on a periodic basis. Once defined, management should perform a review of key password
parameters to ensure that the third party supplier is implementing the Horizon Security Policy. Priority 2 (Mark Pearce — January 2013)

No of Implementation
Importance actions Completed by Mar 13
Priority 1 - - -
Priority 2 5 2 3
5 SSE SESE ESS TSS EERE Internal Audit & Risk Management

Confidential Page 9 of 11
POL00029713
POL00029713

Appendix A — Windows A\ Directory — Password Parameters

The following password parameters in the Windows Active Directory Group Policy were observed to not meet the requirements set out in the

Horizon Security Policy.

Password parameter

Horizon Security Policy Requireme:

ws Active Directory Group P.

Setting
1 Number of failed login attempts before After 3 to 5 failed attempts After 6 failed attempts
account lockout
2 Account lockout counter Reset by an Administrator 30 minutes

Fujitsu have stated that they do not have the resource available to have the account lockout counter reset by an administrator, which is why it
automatically resets after 30 minutes. The Horizon Security Policy should be reviewed and changed to reflect the configuration of the password

parameters detailed above.

SE ES ER TES EEE
Confidential

Internal Audit & Risk Management

Page 10 of 11
POL00029713

POL00029713
Susan Barton, Strategy Director Derek K Foster, Internal Audit & Risk Management Director
Susan Crichton, Legal and Compliance Director Justin Thornton, Head of Risk and Assurance
Christopher Day, Chief Financial Officer Ernst & Young, External Auditors

Kevin Gilliand, Network and Sales Director
Andy J Jones, Quality and Standards Manager
Mark R Pearce, Head of Information Security
Lesley J Sewell, Chief Information Officer
Paula Vennells, Chief Executive

Malcolm Zack, Head of Internal Audit

5 SSE SESE ESS TSS EERE Internal Audit & Risk Management TT AEE,
Confidential Page 11 of 11