REPORT DIGEST SUPREME COURT OF ILLINOIS COMPLIANCE EXAMINATION FOR THE TWO YEARS ENDED JUNE 30, 2021 Release Date: July 13, 2022 FINDINGS THIS AUDIT: 2 CATEGORY: NEW -- REPEAT – TOTAL Category 1: 0 -- 0 -- 0 Category 2: 1 -- 1 -- 2 Category 3: 0 -- 0 -- 0 TOTAL: 1 -- 1 -- 2 FINDINGS LAST AUDIT: 1 Category 1: Findings that are material weaknesses in internal control and/or a qualification on compliance with State laws and regulations (material noncompliance). Category 2: Findings that are significant deficiencies in internal control and noncompliance with State laws and regulations. Category 3: Findings that have no internal control issues but are in noncompliance with State laws and regulations. State of Illinois, Office of the Auditor General FRANK J. MAUTINO, AUDITOR GENERAL To obtain a copy of the Report contact: Office of the Auditor General, Iles Park Plaza, 740 E. Ash Street, Springfield, IL 62703 (217) 782-6046 or TTY (888) 261-2887 This Report Digest and Full Report are also available on the worldwide web at www.auditor.illinois.gov INTRODUCTION Our compliance examination of the Supreme Court included Appellate Court Districts 1-5 and the Illinois Courts Commission. SYNOPSIS • (21-01) The Court did not maintain adequate internal controls related to its cybersecurity programs and practices. • (21-02) The Court did not maintain adequate controls over its service providers. FINDINGS, CONCLUSIONS, AND RECOMMENDATIONS WEAKNESSES IN CYBERSECURITY PROGRAMS AND PRACTICES The Court did not maintain adequate internal controls related to its cybersecurity programs and practices. During our examination of the Court’s cybersecurity programs and practices, we noted the Court had not: • Established policies and procedures governing the controls related to the onboarding of staff and contractors. • Ensured all staff and contractors received and acknowledged receipt of the security policies at least annually. • Provided cybersecurity training to staff and contractors upon hiring and annually thereafter. • Developed a project management framework to ensure new applications were adequately developed and implemented in accordance with management’s expectations. • Developed a comprehensive system development methodology. • Developed a comprehensive cybersecurity plan. • Developed a risk management methodology, conducted a comprehensive risk assessment, or implemented risk reducing controls. • Developed a data classification methodology. • Developed procedures for implementing and monitoring identified vulnerabilities. (Finding 1, pages 10-12) We recommended the Court: • Establish policies and procedures governing the controls related to the onboarding of staff and contractors. • Ensure all staff and contractors receive and acknowledge receipt of the security policies at least annually. • Provide cybersecurity training to staff and contractors upon hiring and annually thereafter. • Develop a project management framework to ensure new applications are adequately developed and implemented in accordance with management’s expectations. • Develop a comprehensive system development methodology, including details on the development phases, documentation requirements, user testing requirements and management approvals. • Develop a comprehensive cybersecurity plan. • Develop a risk management methodology, conduct a comprehensive risk assessment, and implement risk reducing controls. • Develop a data classification methodology, including data classifications and details on determining the classifications are adequately secured. • Develop procedures for implementing and monitoring identified vulnerabilities. Management stated the Court agrees with limited parts of the finding and will continue to follow best practices to enhance its documentation and planning. Management also stated the audit finding as drafted does not acknowledge or reference the Court’s many cybersecurity protocols and procedures that are in place. In an accountant’s comment, the accountants stated the Court failed to provide documentation to support the controls in place. The lack of documentation hinders our ability to review and assess the Court’s cybersecurity program and practices. INADEQUATE CONTROLS OVER THE REVIEW OF INTERNAL CONTROLS OVER SERVICE PROVIDERS The Court did not maintain adequate controls over its service providers. The Court did not provide documentation demonstrating their listing of service providers was complete and accurate. Due to these conditions, we are unable to conclude the Court’s population records were sufficiently precise and detailed under the Professional Standards promulgated by the American Institute of Certified Public Accountants (AT-C § 205.35). We performed testing over the one service provider identified by the Court. During our testing we noted for the period of July 1, 2020 through June 30, 2021, the Court had not: • Obtained a System and Organization Control (SOC) report. • Conducted an analysis of the Complementary User Entity Controls (CUECs). • Obtained and reviewed SOC reports for subservice organizations or performed alternative procedures to determine the impact on its internal control environment. (Finding 2, pages 13-14) We recommended the Court implement controls to identify and document all service providers utilized. We also recommended the Court obtain SOC reports annually. We further recommend the Court: • Monitor and document the operation of the CUECs related to the Court’s operations. • Either obtain and review SOC reports for subservice organizations or perform alternative procedures to satisfy itself the existence of the subservice organization would not impact the internal control environment. • Document its review of the SOC reports and review all significant issues with subservice organizations to ascertain if a corrective action plan exists and when it will be implemented, any impact to the Court, and any compensating controls. Court management disagreed with the finding and stated the Court performs System and Organization Control (SOC) reviews for service organizations, which analyzes all service providers contracted by the Court’s IT division. Contracts and vendor lists are reviewed to obtain a list of all potential service organizations. An assessment is completed for the service organizations, including an analysis of subservice organizations, to distinguish between service organizations and vendors. SOC reports are then reviewed and analyzed for all service organizations to ensure that controls exist and relate to the services provided. An accountant’s comment stated although the Court reviewed the Fiscal Year 2020 SOC report performed by an independent service auditor, we were not provided the SOC reports or their analysis of the SOC reports for Fiscal Year 2021. ACCOUNTANT’S OPINION The accountants conducted a State compliance examination of the Court for the two years ended June 30, 2021, as required by the Illinois State Auditing Act. The accountants stated the Agency complied, in all material respects, with the requirements described in the report. This State compliance examination was conducted by Adelfia LLC. JANE CLARK Division Director This report is transmitted in accordance with Section 3-14 of the Illinois State Auditing Act. FRANK J. MAUTINO Auditor General FJM:lkw