Requests confidential treatment under the Freedom of Information Act or similar laws and regulations, States that if any copies are to be provided, they will be identified as Confidential Treatment Requested by (, Public Company Accounting Oversight Board (, Standards and Emerging Issues Advisory Group, Technology Innovation Alliance Working Group, Standard-Setting, Research, and Rulemaking Projects, Implementation Resources for PCAOB Standards and Rules, Inspections-Related Board Reports and Statements, Updated PCAOB Staff Considerations on Recommending the Identification of Issuers and/or Broker-Dealers in Settled Enforcement Orders, PCAOB Cooperative Arrangements with Non-U.S. Regulators, Board Determinations Under the Holding Foreign Companies Accountable Act, The International Forum of Independent Audit Regulators and Other International Organizations, Information for Auditors of Broker-Dealers, Conference on Auditing and Capital Markets, PCAOB International Institute on Audit Regulation, PCAOB Auditing Standard No. V, No. Furthermore, upon request, we may provide copies of selected audit documentation to (name of regulator). Another exemption that may cover the factual portions of an internal audit report is exemption six. More subjective evaluation of the audit evidence is often Internal auditors are expected to apply and uphold the following principles: 1.1. Internal audit independence and objectivity: emerging research opportunities, Internal Audit Independence and Objectivity: Emerging Research Opportunities. Internal audit confidentiality also prevents the auditor to use the clients confidential interest to gain personal benefit. AU 9339 Audit Documentation: Auditing Interpretations of Section 339 Policy Steward chaged to the Vice President for Administration. I, No. INTERNAL AUDIT REPORT . Is Huntington Bank Offering Cashiers Checks? QuestionSection 339, Audit Documentation, paragraph .11, states that the auditor has an ethical, and in some situations a legal, obligation to maintain the confidentiality of client informationBecause audit documentation often contains confidential client information, the auditor should adopt reasonable procedures to maintain the confidentiality of that information. However, auditors are sometimes required by law, regulation or audit contract, fn3 to provide a regulator, or a duly appointed representative, access to audit documentation. Addition of policy steward information, in the event that there are questions or requests for changes to the policy. PDF Confidentiality Agreement - Deloitte US than information obtained indirectly.5. see paragraphs .09 through .11) and supervise,8 review, evaluate, and test the work performed by internal auditors to the extent appropriate in the circumstances. The auditor also considers the need to test the effectiveness of the factors described in paragraphs .09 and .10. for the internal audit function. According to ISACA, there are three types: an examination, a review and an agreed-upon procedure. The fact that particular conduct is not mentioned in the Rules of Conduct does not prevent it from being unacceptable or discreditable, and therefore, the member, certification holder, or candidate can be liable for disciplinary action. To fulfill this responsibility, internal auditors maintain objectivity with respect to the activity being audited. 24 Simple Confidentiality Statement & Agreement Templates 1.4. level. The Attorney General's "Blue Book" on the 1974 FOI Amendments discussed this question in the context of exemption 7(C) and suggested that privacy is involved in "information about an individual which he could reasonably assert an option to withhold from the public at large because of its intimacy or its possible adverse effects upon himself or his family."(4). The auditor may find the results of Sample language that may be used follows: "The audit documentation for this engagement is the property of (name of auditor) and constitutes confidential information. See. Even when a record contains exempt information, the other portions of the record must usually be released. Having the Board's approval of its charter provides the internal audit activity with the authority it needs to access records and documentation . In addition, an audit does not address the possibility that material errors or fraud may occur in the future. 1, p. 3 Business Confidentiality After Chrysler: Vol. Analyzed the financial statements by line-item for significant outliers. PDF Reporting on Controls at a Service Organization - AICPA In fulfilling this responsibility, the auditor maintains independence from the entity.2. Letter . The seventh exemption, which was amended in 1974, is designed to protect "investigatory records compiled for law enforcement purposes" if their disclosure would result in a type of harm specified in clauses (A) through (F) of the exemption. Audit working papers are the documents which record all audit evidence obtained during financial statements auditing, internal management auditing, information systems auditing, and investigations. Following is an example of language that may be used in the written communication to the client: The audit documentation for this engagement is the property of (name of auditor) and constitutes confidential information. .15At the financial-statement level, the auditor makes an overall assessment of the risk of material misstatement. For example, an internal audit report might contain information about lunch hour arrangements, parking rules, methods of collecting attendance and leave information, filing procedures, time needed to go to the copying machine, etc., to which exemption two might apply. In general, they are likely to be withholdable under exemption two only to the extent that disclosure would materially prejudice auditing when it is conducted for law enforcement. The entity's internal audit function may influence this overall assessment auditors' procedures to evaluate the efficiency of certain management decision-making processes are ordinarily not relevant to a financial statement audit. The following information from personnel records is public information and may be included in the working papers or written communications. If the auditor determines that the internal auditors are sufficiently competent and objective, the auditor should then consider how the internal auditors' work may affect the BELL HARBOR INTERNATIONAL CONFERENCE CENTER (BHICC) / WORLD TRADE CENTER (WTC) JANUARY 1, 2015 - DECEMBER 31, 2016 . To avoid any misunderstanding, prior to allowing a regulator access to the audit documentation, the auditor should consider submitting a letter to the regulator that: The auditor may wish to obtain a signed acknowledgment copy of the letter as evidence of the regulators receipt of the letter. For example, commercial information like the new produce lunch next week could be very sensitive. Audit plan, including the nature, timing, and extent of audit work. Principles that are relevant to the profession and practice of internal auditing. Global Internal Auditing Code of Ethics | The IIA That Act generally applies only to records that are part of "systems" of records within the meaning of that Act, while the Freedom of Information Act applies to all agency records. fn3 For situations in which the auditor is not required by law, regulation or audit contract to provide a regulator access to the audit documentation, reference should be made to the guidance in paragraphs .11.15 of this Interpretation. I, No. and transaction classes and therefore can affect many assertions. sufficient, appropriate evidential matter to support the auditor's report. We should handle these items in the same manner as confidential information. Rules of Conduct that describe behavior norms expected of internal auditors. 2022-002, SEC Release No. Confidential information includes, but is not limited to: We should never include social security numbers in our working papers. Summaries of New Decisions -- February 2009 As announced previously by OIP, we are now posting up-to-date summaries of new court decisions. Shall be prudent in the use and protection of information acquired in the course of their duties. Thus, our audit, based on the concept of selective testing, is subject to the inherent risk that material errors or fraud, if they exist, would not be detected. Maintain control over the audit documentation, and. Furthermore, the auditor should take appropriate steps to maintain control of the audit documentation. All rights reserved. The second exemption is for matters "related solely to the internal personnel rules and practices of an agency." 41. PDF Code of Ethics Implementation Guides - The Institute of Internal Chrysalis shall cause any accountants selected by it to enter into a confidentiality agreement acceptable to Discovery obligating such accountants to retain all such information in confidence pursuant to such confidentiality agreement. 4Standards have been developed for the professional practice of internal auditing by The Institute of Internal Auditors and the General Accounting Office. Confidentiality is one of the most important of internal audits code of ethics that required the internal auditors to keep information that they obtain from clients during their audit confidential. |Privacy Policy and Terms of Use| Sitemap. An amendment to paragraph .19 has been adopted by the PCAOB and approved by the U.S. Securities and Exchange Commission. In a "reverse" FOIA suit brought by a water supply corporation trying to protect internal audit reports submitted by it in application for a Farmers Home Administration loan, the U.S. Court of Appeals for the Fifth Circuit affirmed the district court's refusal to enjoin disclosure, holding that the reports FOIA Update Vol. appropriate evidential matter to provide a reasonable basis for the opinion on the entity's financial statements. In addition, any notations, comments, and individual conclusions appearing on any of the audit documents do not stand alone, and should not be read as an opinion on any individual amounts, accounts, balances or transactions. Recalculated the Incentive Management Fees and the Base . factors decrease, the need for the auditor to perform his or her own tests of the assertions decreases. See PCAOB Release No. To facilitate their review, the cases are broken down by FOIA Exemption or procedural element and internal citations and quotations have been omitted. Shall observe the law and make disclosures expected by the law and the profession. The auditor's assessment of risk at the financial-statement level often affects the overall audit strategy. are not relevant to the financial statement audit, the auditor does not have to give further consideration to the internal audit function unless the auditor requests direct assistance from the internal auditors as described in paragraph .27. However, if the second person is situated similarly to the first one, denying access on the second request would be unfair, discriminatory, or an abuse of discretion. .26In making the evaluation, the auditor should test some of the internal auditors' work related to the significant financial Examples include records relating to research in process, contract negotiations, employee benefits, or past-due accounts. This policy applies to all University academic and administrative units and locations. SAMPLE "Internal Audit Report" for Quality Management Systems against ISO 9001:2015 10 OF 34 There are court decisions going in both directions on the question whether certain manuals for the guidance of auditors in IRS, DOD, and other agencies are covered. .18Even though the internal auditors' work may affect the auditor's procedures, the auditor should perform procedures to obtain Audit Documentation: Auditing Interpretations of Section 339. Audit policies, programs, and procedures. This concept of independence is different from the independence the auditor maintains under the Agency personnel often conduct both internal and external audits. Internal Audit Shall perform their work with honesty, diligence, and responsibility. ii. 1, p. 3 Business about FOIA Update: Significant New Decisions, about FOIA Update: Index to FOIA Update (1979-1983), about FOIA Post (2009): Summaries of New Decisions -- February 2009, about FOIA Update: Index to FOIA Update, Volumes I-X, 1979-1989, Virtual Exemption 1 and Exemption 7 Training, Sobre la Oficina de Politicas Informacion, FOIA Update: Index to FOIA Update (1979-1983), FOIA Post (2009): Summaries of New Decisions -- February 2009, FOIA Update: Index to FOIA Update, Volumes I-X, 1979-1989. Procedures the auditor performs when obtaining an understanding of the entity's internal control (paragraph .13). Office of Information Policy This means that the seventh exemption would usually not cover reports of internal audits. entity's management and board of directors or to others with equivalent authority and responsibility. Tips and Guidance, Review Engagement (Limited Assurance): Definition and Example, 5 Types of Due Diligence Services, Benefits, And Limitations, What is Internal Audit Department? Assertions about the existence of cash, prepaid assets, Auditing would also increase the integrity and credibility of an entity. August 20, 2012 - Editorial change in paragraphs 1 and 2 of the "Policy" section, changing the reference to "the Chair of the Subcommittee on Audit of the University's Board of Trustees" to "the Chair of the Committee on Audit and Risk of the University's Board of Trustees." of physical inventories to be observed. .04An important responsibility of the internal audit function is to monitor the performance of an entity's controls. The audit documentation may be made available to a regulator at the offices of the client, the auditor, or a mutually agreed-upon location, so long as the auditor maintains control. Confidentiality of Information General The nature of internal audit work requires that, to the extent permitted by law, we have unrestricted access to all sources of information, property, and personnel at the University. Handling and Distributing Confidential Internal Audit Reports and Other InterpretationThe auditor should be satisfied that the party engaged by the regulator is subject to the same confidentiality restrictions as the regulatory agency itself. 1. Step 9: Follow-up - Approximately 6-9 months after the audit report is issued, the Office of Audit Services will perform a follow -up review. .11In assessing competence and objectivity, the auditor usually considers information obtained from previous experience with the 3, Audit Documentation, Appendix A: Background and Basis for Conclusions, Appendix A: Illustrative Reports on Whether a Previously Reported Material Weakness Continues to Exist, Appendix B: Background and Basis for Conclusions, Appendix B: Consideration of Manual and Automated Systems and Controls, Appendix B: Qualitative Factors Related to the Evaluation of the Materiality of Uncorrected Misstatements, Appendix C: Matters That Might Affect the Assessment of Fraud Risks, Appendix B: Communications with Audit Committees Required by Other PCAOB Rules and Standards, Appendix C: Matters Included in the Audit Engagement Letter, Appendix A: Examples of Information and Sources of Information That May be Gathered During the Audit That Could Indicate That Related Parties or Relationships or Transactions with Related Parties Previously Undisclosed to the Auditor Might Exist, AU Section 110 - Responsibilities and Functions of the Independent Auditor, AU Section 150 - Generally Accepted Auditing Standards, AU Section 161 - The Relationship of Generally Accepted Auditing Standards to Quality Control Standards, AU Section 201 - Nature of the General Standards, AU Section 210 - Training and Proficiency of the Independent Auditor, AU Section 230 - Due Professional Care in the Performance of Work, AU Section 315 - Communications Between Predecessor and Successor Auditors, AU Section 316 - Consideration of Fraud in a Financial Statement Audit, AU Section 9317 - Illegal Acts by Clients: Auditing Interpretations of Section 317, AU Section 322 - The Auditor's Consideration of the Internal Audit Function in an Audit of Financial Statements, AU Section 9324 - Service Organizations: Auditing Interpretations of Section 324, AU Section 325 - Communications About Control Deficiencies in an Audit of Financial Statements, AU Section 9325 - Communication of Internal Control Related Matters Noted in an Audit: Auditing Interpretations of Section 325, AU Section 9326 - Evidential Matter: Auditing Interpretations of Section 326, AU Section 328 - Auditing Fair Value Measurements and Disclosures, AU Section 329 - Substantive Analytical Procedures, AU Section 330 - The Confirmation Process, AU Section 332 - Auditing Derivative Instruments, Hedging Activities, and Investments in Securities, AU Section 333 - Management Representations, AU Section 9333 - Management Representations: Auditing Interpretations of Section 333, AU Section 336 - Using the Work of a Specialist, AU Section 9336 - Using the Work of a Specialist: Auditing Interpretations of Section 336, AU Section 337 - Inquiry of a Client's Lawyer Concerning Litigation, Claims, and Assessments, AU Section 9337 - Inquiry of a Client's Lawyer Concerning Litigation, Claims, and Assessments: Auditing Interpretations of Section 337, AU Section 341 - The Auditor's Consideration of an Entity's Ability to Continue as a Going Concern, AU Section 9341 - The Auditor's Consideration of an Entity's Ability to Continue as a Going Concern: Auditing Interpretations of Section 341, AU Section 342 - Auditing Accounting Estimates, AU Section 9342 - Auditing Accounting Estimates: Auditing Interpretations of Section 342, AU Section 390 - Consideration of Omitted Procedures After the Report Date, AU Section 410 - Adherence to Generally Accepted Accounting Principles, AU Section 9410 - Adherence to Generally Accepted Accounting Principles: Auditing Interpretations of Section 410, AU Section 411 - The Meaning of Present Fairly in Conformity With Generally Accepted Accounting Principles, AU Section 504 - Association With Financial Statements, AU Section 9504 - Association With Financial Statements: Auditing Interpretations of Section 504, AU Section 508 - Reports on Audited Financial Statements, AU Section 9508 - Reports on Audited Financial Statements: Auditing Interpretations of Section 508, AU Section 530 - Dating of the Independent Auditor's Report, AU Section 532 - Restricting the Use of an Auditor's Report, AU Section 534 - Reporting on Financial Statements Prepared for Use in Other Countries, AU Section 9534 - Reporting on Financial Statements Prepared for Use in Other Countries: Auditing Interpretations of Section 534, AU Section 543 - Part of Audit Performed by Other Independent Auditors, AU Section 9543 - Part of Audit Performed by Other Independent Auditors: Auditing Interpretations of Section 543, AU Section 544 - Lack of Conformity With Generally Accepted Accounting Principles, AU Section 550 - Other Information in Documents Containing Audited Financial Statements, AU Section 9550 - Other Information in Documents Containing Audited Financial Statements: Auditing Interpretations of Section 550, AU Section 552 - Reporting on Condensed Financial Statements and Selected Financial Data, AU Section 558 - Required Supplementary Information, AU Section 9558 - Required Supplementary Information: Auditing Interpretations of Section 558, AU Section 561 - Subsequent Discovery of Facts Existing at the Date of the Auditor's Report, AU Section 9561 - Subsequent Discovery of Facts Existing at the Date of the Auditor's Report: Auditing Interpretations of Section 561, AU Section 622 - Engagements to Apply Agreed-Upon Procedures to Specified Elements, Accounts, or Items of a Financial Statement, AU Section 9622 - Engagements to Apply Agreed-Upon Procedures to Specified Elements, Accounts, or Items of a Financial Statement: Auditing Interpretations of Section 622, AU Section 9623 - Special Reports: Auditing Interpretations of Section 623, AU Section 625 - Reports on the Application of Accounting Principles, AU Section 634 - Letters for Underwriters and Certain Other Requesting Parties, AU Section 9634 - Letters for Underwriters and Certain Other Requesting Parties: Auditing Interpretations of Section 634, AU Section 9642 - Reporting on Internal Accounting Control: Auditing Interpretations of SAS No.