3.10
Control Environment
Principle 3: Establish Structure, Responsibility, and Authority
Attribute 3.10: Effective documentation assists in management's design of internal control by establishing and communicating the who, what, when, where, and why of internal control execution to personnel. Documentation also provides a means to retain organizational knowledge and mitigate the risk of having that knowledge limited to a few personnel, and to communicate that knowledge as needed to external parties, such as external auditors.
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This specific discussion of a Potential Green Book Deviation is from a sub-section titled, Motor Vehicle Department Contract.
I had sought the contract between MC and the Motor Vehicle Department as a means to understand the logistics of the collection of sensitive voter registration information and subsequent transfer to the MC. I was not seeking the confidential information; I sought to understand the process. MC management and legal team claimed there were no written agreement to document this activity.
Potential Green Book Deviation:
Contrary to the Green Book, no documentation was created or retained to describe the logistic of data collection and transfer by the MVD. There certainly was inadequate information available to conduct an audit by external parties. I wasn't trying to perform an audit; I was trying to assess governance.
