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Continuous Control Monitoring: putting audit back in control

For internal audit functions, a worrying circularity occurs when auditing IT controls. And it’s this: to obtain the data that the audit function needs to check, it is necessary for them to go to a plethora of different business functions and request it.

In other words, the controls being audited, are owned by the very same people that are providing the data that is used to assess them.

And audit, as any auditor will tell you, isn’t supposed to work like that. An auditor is supposed to determine the risks on which assurance is required, specify the data which will determine if adequate assurance does indeed exist, request that data, and then examine it in real time. The function being audited is quite separate from that process.

Not always when it comes to IT, though. The IT function is often intimately involved—typically receiving a request for a pack of audit data, and subsequently delivering it painstakingly later. Worse, in some organisations, IT is intimately involved in specifying both the risks to be assessed, and providing the data with which to assess those risks.

To belabour the point, audit isn’t supposed to work like that.

Independent and objective

To be fair, audit functions know this. And they know it all too well. They’re supposed to be in the driving seat when it comes to risk auditing—and when it comes to IT, more often than not, they’re unable to have full confidence in the data they are assessing due to manual data collection and un-connected systems providing sample data only.

Audit functions also understand all too well that different parts of an organisation will have different views on constitutes risk, and what ‘good’ or ‘bad’ looks like in respect of that risk.

And they know that their role is to objectively define risk, and objectively assess the relevant data with respect to risk. Relying on other parts of the organisation to define risk and produce the data with which to assess that risk weakens the integrity of the audit process—much more so, of course, when the function is question is the very function that is responsible for managing the controls that relate to the risks being audited.

Simply put, an audit process that isn’t demonstrably independent and objective is an audit process with obvious weaknesses.

Driving seat

Now, there’s no suggestion that IT functions are actively ‘gaming the system’, and abusing the position of trust in which they find themselves. That would be dangerous, and short-sighted.

The problem is one of perception: the risk that this could happen is what degrades the objectivity and independence of the audit, rather than the fact that it is happening.

And it’s also true that everyone—audit functions, IT functions, and the broader organisation—has an interest in effective and objective audits being carried out. Audit, after all, is often called the ‘third line of defence’ when it comes to IT, after the IT function itself, and the organisation’s risk and compliance professionals.

So what can be done? How can truly independent and objective IT audits be carried out? Is there a way out of this impasse? And a way of putting audit functions back in the driving seat, where they should be, providing strategic insights back to the business confident in their data set?

Introducing Continuous Controls Monitoring

The answer: yes, thanks to a paradigm shift in how IT audits can be carried out.

Because a technology known as Continuous Controls Monitoring—a new, proven innovation being espoused by auditors and independent advisory organisations such as Gartner and Forrester—delivers just such a means of providing audit functions with the data that they need. Doing so in real-time, instantaneously and without requiring IT involvement at all.

Simply put, Continuous Controls Monitoring gathers—continuously, and in real-time—all the data and evidence required in order to audit IT reassuringly, by continually monitoring all of a business’s risk management systems and internal controls, direct from the source merging the metrics you require to automate the data gathering process.

It’s IT data that is factual and objective. It’s IT data that is immediate. It’s IT data that is drawn from right across the organisation’s risk and vulnerability landscape. And it is IT data that comes directly to audit functions, rather than through the auspices of the IT security function itself.

A better way of auditing IT? We think so.


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Will Tonge

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Will has spent the last 9-years embedded in Cyber Security working with global, household names and innovative start-ups.

Passionate about bringing people and technology together, Will has worked in various settings, helping build high-growth organisations across multiple sectors. During this time, he has built an extensive network with access to some of the best talent out there.

Outside of QO, his young daughter keeps him well on his toes!

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Mark Hudson

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Mark works with SMEs and charities to develop strategies to help them grow and access development capital. He is a NED, charity trustee and mentor to a wide range of people. His plural career started in 2017 after 16 years at pwc as a Deals partner working with large corporates and PE houses; at pwc he also ran the Retail and Consumer practice and was Chairman of the pwc UK Supervisory Board. Prior to pwc he was an executive director at Welcome Break and Iceland Group, and a partner at Bain and Company. He trained as an engineer at Imperial College and has an MBA from INSEAD. 

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Eamon Flavin

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Eamon is a highly regarded and massively respected technology career professional as well as serial entrepreneur. He has started, grown and successfully taken to market three technology business.

Genuinely expert in technology, Eamon has enjoyed long-term working relationships with many of the world’s top companies and organisations in finance, banking, government, manufacturing, engineering, technology and the charities sector.

He draws on unparalleled contacts and experience and provides advice, solutions and recommendations, as well as helping respond to emergencies. Eamon has grown in-house and client teams and has a gift for hiring great people.

Peter Martin

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Peter has the ability to do what many fail to and that is to consistently bring together highly professional teams and build a business environment that is supportive, agile, professional and where everyone enjoys coming into the office.

Bringing a unique blend of business acumen and technical knowledge to the role of non-exec director, Peter has already demonstrated his ability to bring an exceptional flair for dealing with complex situations with a clear, considered approach.

Personally, Peter brings humility and a strong moral compass to the team. His disarming and self-deprecating approach wins everyone over.

Anwen Haynes

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Anwen has worked in B2B and B2C marketing for over 20 years. From transforming end-to-end customer journeys in retail with strategic customer-centric plans to target driven focused strategies for B2B sales. With extensive experience in digital marketing including SEO, as well as Brand development, she loves to develop a cohesive approach to brand image and communications to drive and develop the business proposition and perception.

Alice Walker

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Alice has worked in the IT industry for 20 years. Starting in Procurement, she moved into Software Asset Management before transitioning into Customer Success Management. Working across a variety of roles for different industries as both a customer and a service provider has given her a great understanding of what makes a great service. She has always been passionate about building and maintaining great customer relationships and helping her customers achieve their goals.

Owain Rowley

Lead Developer -

Owain has spent nearly a decade building software solutions and products within the cyber security sphere for the likes of government entities, large telecommunication companies, banks and card transaction companies.

This level of experience allows him to swiftly identify business and security processes that can be streamlined with automation, increase the efficiency of existing processes, as well as generate insightful data visualisations and models for members of an organisation at each different level.

Ami Penolver

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Ami is a finance sector career professional, with many years’ experience working in financial services, both in London and throughout the UK. In addition to financial control, she looks after HR and legal for the company.

Being a mother of two also equips her with the basic skills required to manage a senior team of management and technology consultants.

Ami’s sense of balance and perspective is an essential ingredient of the Quod Orbis culture.

Alastair Dickson

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Alastair has spent the last 20 years working in Cyber Security and Risk Management. He is a passionate believer that security solutions should enable a business to take advantage of all the benefits of the digital world, while not putting the organisation’s data or productivity at risk.

Alastair has developed high-performing teams in some of the industry’s most competitive markets and launched new innovative technologies to market.

Being a rugby coach, and also having four sons at home, means he has lots of experience in keeping a passionate team in order but always has time for some fun!

Gary Penolver


Gary has 15 years’ experience in senior technology roles, and has already been closely involved in starting and taking two technology companies to market.

Totally comfortable with a fast-moving, state-of-the-art technical landscape, he helps his clients maintain and improve security and compliance.

He has a reputation for delivering pragmatic and easy to maintain solutions – business owners and managers enjoy knowing that the security and compliance is well managed and automated, properly instrumented and reported at a competitive cost point.

Honest, open, unflappable and very social, Gary is trusted by many household-name organisations to protect their, and their client’s data.

Martin Greenfield


Martin is an experienced technology and organisational transformation specialist and an excellent, proven leader and communicator in mission-critical operations, particularly in security technology.

Over the past 20 years, multi-billion pound commercial organisations, including global banks, utilities and major investment funds have trusted Martin to transform their operations to meet financial, operational and compliance targets.

Martin optimises operations, managing and transforming operational teams of between 50 and 500 people, to deliver the highest levels of audit compliance, risk management and financial efficiency.

Often working with other major consultancies and suppliers for new global corporate owners or management teams, Martin will help integrate and streamline operations on a global basis.

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