Question 1149 - CISA discussion

This is because privacy regulations are laws or rules that protect the personal information of individuals from unauthorized access, use, disclosure, or transfer by third parties. Payroll audit documentation may contain sensitive and confidential data, such as employee names, salaries, benefits, taxes, deductions, and bank accounts. If the audit management application is hosted by a third party in a different country, the organization may need to comply with the privacy regulations of both its own country and the host country, as well as any international or regional agreements or frameworks that apply. Privacy regulations may impose various requirements and obligations on the organization, such as obtaining consent from the data subjects, implementing appropriate security measures, notifying data breaches, and ensuring data quality and accuracy. Privacy regulations may also grant various rights to the data subjects, such as accessing, correcting, deleting, or transferring their data. Failing to comply with privacy regulations may expose the organization to significant risks and consequences, such as legal actions, fines, sanctions, reputational damage, or loss of trust.

Some examples of privacy regulations affecting the organization are:

The General Data Protection Regulation (GDPR), which is a comprehensive and strict privacy regulation that applies to any organization that processes personal data of individuals in the European Union (EU) or offers goods or services to them, regardless of where the organization or the data is located1.

The California Consumer Privacy Act (CCPA), which is a broad and influential privacy regulation that applies to any organization that collects personal information of California residents and meets certain thresholds of revenue, data volume, or data sharing2.

The Health Insurance Portability and Accountability Act (HIPAA), which is a sector-specific privacy regulation that applies to any organization that handles protected health information (PHI) of individuals in the United States, such as health care providers, health plans, or health care clearinghouses3.

Therefore, before using an audit management application hosted by a third party in a different country, the internal audit team should conduct a thorough assessment of the privacy regulations affecting the organization and ensure that they have adequate policies, procedures, and controls in place to comply with them.