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IT Best Practice CHERRY BEKAERF& HOLLAND CERTIFlEI,II:HIIC ACCOI:N IAS'IS h CON SCIIIA N TS Mr. Danny L. Kolhage Clerk of the Court 500 Whitehead Street Key West, FL 33040 Dear Danny: In planning and performing our audit of the financial statements of the governmental activities, the business-type activities, each major fund, and the aggregate remaining fund information of Monroe County Florida (the "County"), as of and for the year ended September 30, 2009, we considered the County's internal controls in order to determine our auditing procedures for the purpose of expressing our opinion on the financial statements and not to provide assurance on the internal controls. Our assessment of the internal controls was limited to obtaining an understanding of the internal controls sufficient to plan our audit and did not include tests of control policies and procedures. As part of our normal audit process we have identified certain matters that came to our attention that we would like to communicate to you because we feel these items are opportunities for strengthening internal controls and operating efficiency. INTERNAL CONTROL AND OPERATING EFFICIENCY ISSUES IT BEST PRACTICE RECOMMENDATONS A formal Information Security Policy and Procedure has not been developed and implemented by the Finance Department. A procedure should be established to define requirements to requesting and granting access, terminating access, and periodically reviewing access. Additionally procedures should be implemented to define minimum requirements for password security, confidentiality of information, and segregation of duties guidelines within the application. Access privileges to the Financial and Court Applications should be periodically reviewed by the users' management to verify that the level of access still accurately reflects the minimum level required for the user to perform their job function and accurately reflects an appropriate level of segregation of duties within logical access. Passwords for the Court and Financial Applications should be set to reflect best practices for password security. Best practices require that passwords consist of a minimum of 8 characters, expire every 90 days, maintain 5 password histories, and lock after 3 unsuccessful log in attempts. The local network is protected by a Cisco PIX 515 Fire wall; however, there is not an effective mechanism in place to monitor the firewall logs for potential threats. A risk assessment has not been performed and documented. A risk assessment is an assessment of the risk faced by information technologies. This document should identify and classify potential risks to the central IT infrastructure and resources, document obstacles precluding elimination of these identified risks and then recognize the Clerk's acceptance of those risks. A risk assessment should be updated with the results of audits, inspections, and identified incidents. The scope should include risks related to the confidentiality, availability, and integrity of critical data and resources. LAN data provides Disaster Recovery services for the Court and Financial Applications at their facility in San Antonio, Texas. While data is sent off-site to this location and recoverability infrastructure is in place, a formal test of the Disaster Recovery Plan has not been performed. The Clerk IT should visit the Disaster Recovery location and perform a recovery exercise. A formal change control policy and procedure has not been established for the Court and Financial Applications. This procedure should outline steps and documentation required to authorize, test, approve, and implement changes into production for the Court and Financial Applications. Formal test plans should be created and maintained for each major change including version upgrades to the Financial Application. The plan should include key functions of the application for each department and/or module of the system. If you have any questions or would like to have further discussions on any of the matters discussed above, feel free to give Eddie Burke a call at 919-782-1040. CHERRY, BEKAERT& HOLLAND, L.L.P. u .mot. Orlando, Florida March 31, 2010 VA? ?Ao CC Lance agr,_ /ane% fha /011