| Intelligence
Gathering and the Future of Internal Audit
Looking for Answers in Unlikely Places
By
Joseph W. Koletar
APRIL
2006 - As the internal audit function continues to come to
grips with the increasing demands placed upon it in a post–Sarbanes-Oxley
(SOX) environment, many chief audit executives (CAE) are turning
to technology to help them cope. This may be a function of
resource constraints, the need to produce timely and accurate
audit assessments, or simply the availability of a vast array
of products and services. Computer-assisted analytical tools
abound, and systems promising “dashboard” metrics
seem to be the rage. Many CAEs see these systems as a way
to handle an increased workload with fewer resources. Intrigued
by the promises of many a salesforce, they long for cheap,
off-the-shelf, plug-and-play solutions.
Intelligence
Gathering Throughout History
While
technology may offer many options, and perhaps even some
solutions, it is worth examining the 50-year history of
a distant but instructive field: intelligence collection.
Long considered the province of spies and glamorous gadgets,
intelligence collection is as old as humankind. Technology
has been increasingly used to gain foreknowledge of an adversary’s
capabilities and intentions. In this regard, the intelligence
and audit functions are similar. Both ask essentially the
same question, although for different reasons: “Is
anything going on out there that I should be concerned about?”
While
much has been made of the use of technology to further intelligence
aims in the 20th century, as long ago as the Civil War tethered
balloons were used as aerial observation posts and enemy
telegraph lines were tapped to intercept messages. But techno-intelligence
came into its own during the Cold War, when ships, airplanes,
submarines, ground locations, and satellites were used to
further U.S. intelligence interests. Most of these efforts
were directed at intercepting electronic data, including
radar signals, missile telemetry, and electromagnetic pulses
from devices and nuclear explosions, in work called signals
intelligence and electronic intelligence. An allied field
is the interception of communications intelligence. Billions
of dollars have been spent to operate, process, and protect
these sources of information.
At
the same time the oldest, and arguably the most reliable,
form of intelligence, human intelligence, was increasingly
falling behind. The classic spy of popular culture was becoming
passé simply because some of these individuals were
unsavory, deceitful, manipulative, misinformed, unstable,
grandiose, or plain crazy. Second, dealing in human intelligence
is labor-intensive; for example, a source’s motives
and usefulness must be painstakingly and continually vetted.
Third, some sources are intentional “plants”
working at the behest of a hostile intelligence service.
Fourth, some sources have a personal agenda of revenge or
opportunity, and may alter or exaggerate information accordingly.
Fifth, sources of intelligence can be the source of their
handler’s ruin. Former FBI agent John Connelly, now
in prison, was convicted of serious misdeeds during his
handling of several organized-crime informants, and former
FBI agent James Smith was seduced, literally and figuratively,
by a female Chinese spy he was handling. Finally,
many people find dealing with so-called traitors, snitches,
or rats to be distasteful.
While
the use of human intelligence waned, the use of signals
and communications intelligence surged. Evolving technology
allowed more intelligence to be collected, albeit for a
price. In addition to often being expensive and difficult
to maintain, the efficiency of these technologies sometimes
overwhelmed the resources available to evaluate the information
they collected (referred to in the intelligence community
as the “take”). Finally, the pulse of technological
innovation sometimes produced a “Let’s do it
because we can” mentality, with more collected information
being added to already-strained analytical capabilities.
Fairly
or not, a series of intelligence miscues caused a fair number
in the intelligence community to ask whether this imbalance
had gone too far. The collapse of the Soviet Union caught
intelligence services by surprise, as did the fall of the
Shah in Iran. The explosion by Pakistan of a nuclear device
was seen as another significant intelligence failure, as
were the tragic events of September 11, 2001.
While
hindsight is always 20/20, some knowledgeable observers
in the intelligence community began to question whether
the human intelligence shortfall had become too great. They
did not question the value, often considerable, of electronic
collection, but rather postulated that the equation needed
more balance to be truly effective. That is, the electronic
take had to be married to an equally robust human intelligence
capability. Only humans, they argued, can provide information
as to intentions, dispositions, plans, motives, weaknesses,
self-assessments, relationships, ambitions, feuds, alliances,
personalities, and other factors that form human character
and provide insight into what makes one tick.
If
this assessment has merit, it may have interesting implications
for internal auditing. Certainly, CAEs do not want to be
in the spy business, nor do they want to run spy networks
in their organizations. At the same time, the apparent move
to embrace increasing levels of technological assistance
is very much like the path that the intelligence community
took when it embraced ever-increasing levels of technological
capability in collecting various types of intelligence.
Human
Intelligence and the Internal Audit
What,
one may ask, is the human intelligence component that is
pertinent to internal audit? If we are not going to establish
and run spy networks, where does our human intelligence
come from? Interestingly, organizations are awash in human
intelligence, but do not recognize it and only rarely use
it effectively.
Human
resources (HR). This is often the unseen,
unappreciated, and neglected bloodstream that carries nutrients
throughout the organizational body. In performing their
duties, HR personnel routinely deal with problems, complaints,
mediations, and separations. These intensely human interactions
are often full of information about what is going on within
the organization. When discussing being overlooked for a
promotion, a disgruntled employee may reveal that he knows
that someone within the organization is cutting corners
to make his numbers. The exit interview is often seen as
a perfunctory exercise, but competently performed, it is
an invaluable opportunity to ask a few basic questions about
departing employees’ opinions of how the organization,
and their department in particular, is run. Often the opportunity
to develop valuable information is lost because no one thought
to ask for it.
Hotlines.
Statistics indicate that more than half of the calls coming
into hotlines involve HR issues, and some believe this is
a major weakness of the hotline function. To the contrary,
it is perhaps its greatest strength. HR issues are, by definition,
matters of intense personal interest to the caller. When
an employee’s complaint is handled promptly, competently,
and fairly, that employee’s faith in the hotline probably
increases. Although obviously not every hotline caller gets
what she wants, these calls generally work to the benefit
of the organization, because an employee is more likely
to report something of interest to the organization if it
has been fair and responsive in dealing with something of
interest to her. Also, an increasing number of organizations
are making their hotlines available to customers and vendors
as well, often with good results.
Anonymous
calls and letters. Many of these communications
are ignored, and few organizations have a policy as to how
to handle such matters. Accordingly, anonymous communications
lie scattered throughout various departments, and the organization
may never learn that in the last year department X or manager
Y was the subject of seven such communications. They may
mean little themselves, but collected and coordinated, they
may be an excellent early warning of problems. So, too,
for online chatrooms devoted to an organization’s
business, products, or services. Simple monitoring of these
in a coordinated fashion can be an excellent source of information.
Interestingly,
research reports that an increasing number of employees
are more likely to use hotlines if they permit reporting
via e-mail.
Public
relations (PR). This is usually the primary
interface between an organization and the outside world.
Although usually viewed as a one-way street, pushing information
out, in reality the street runs both ways. Inquiries, questions,
and complaints may often wind up in PR, and analyzing them
may reveal important issues inside the organization.
Sales.
Years ago, Hewlett-Packard made great inroads
into the marketplace by seeing its salesforce as an intelligence-collection
mechanism capable of informing the company about competitors’
activities and customers’ desires. Sales is another
function often seen as one-way, with the objective of pushing
products and services into the marketplace. Astute organizations
see sales as a two-way function. Each
day numerous salespeople interact with customers, competitors,
and other people who may have valuable information about
the organization. Complaints, observations, rumors, and
more often fall into their hands, because they personify
the organization to the customers they deal with. Some information
may be of great interest to the internal auditors, but little
of it is captured, because salespeople often do not see
reporting back as part of their jobs.
Procurement.
This is also viewed as a one-way process, but with blinders.
The procurement function brings goods and services into
the organization. What is not recognized is that it can
also bring information about what vendors say about the
company, its procurement practices, and its reputation in
the business community.
Security.
Often viewed as merely locks, alarms, and guards, security
can be an invaluable source of information because it spans
every area of the organization and often deals with disputes
and contentious issues, some of which may be of interest
to internal auditors. Again, like exit interviews, it behooves
internal auditors to ensure that security personnel are
aware of their issues and interests.
Using
the Intelligence at Hand
The
information sources noted above vary from organization to
organization, but they illustrate the rich human intelligence
environment present in most companies. The issue is not
so much creating new sources of information as it is systematically
tapping into ones that already exist. This must be done
in a manner consistent with organizational mores and culture,
lest the effort be seen as intrusive or heavy-handed. At
the same time, a CAE can go back, review the human intelligence
sources, and reflect upon his career. If he has been in
the business for any amount of time, a CAE has probably
dealt with an internal issue that originated in HR, PR,
or another area. Unfortunately, it was probably because
someone took the time to make a telephone call or ask a
pertinent question, not because the organization had decided
to use its rich human intelligence holdings in an organized
fashion.
As
internal auditing responds to the requirements of a post-SOX
world, signals, electronic, and communications intelligence
will continue to be important components of compliance.
Human intelligence should be invited to join the effort
as well.
Joseph
W. Koletar, CPA, CFE, is a principal and service
line leader with Ernst & Young LLP’s global investigations
and dispute advisory services practice.
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