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Resources · Data Governance

Master data controls.

Internal audit data governance tests whether the data used by the business has owners, approved definitions, controlled changes, quality checks and retention discipline. It matters because vendor bank, customer credit, employee payroll, GL mapping and user-role fields can change cash, compliance and reporting outcomes before an auditor ever samples a transaction.

Use this pack when master-data failures repeat across P2P, O2C, R2R, H2R, treasury, inventory, statutory compliance or ITGC reviews.

Open source-data readinessOpen ITGC checklist
Downloads

Data governance workbook workbook

Download the Excel/PDF pack for data-domain ownership, critical data elements, master-data change controls, quality tests, retention/privacy mapping, monitoring handoff and product-reuse fields.

Domains

Master data domains to test first fields

Vendor master

PAN, GSTIN, MSME status, bank account, payment terms and related-party flags drive P2P cash leakage, tax compliance and supplier reporting risk.

Customer master

Credit limits, pricing group, GSTIN/PAN, billing address and related-party flags affect revenue recognition, collections, GST and O2C exposure.

Employee master

Bank account, grade, CTC, statutory IDs, joining date, exit date and cost centre affect payroll leakage, PF/ESI/TDS and access removal.

GL and reporting master

GL codes, mappings, account ownership, Schedule III tags and close access affect R2R reporting, analytics, dashboards and management packs.

Item and material master

Item code, UOM, BOM link, HSN, valuation class and active status affect inventory accuracy, costing, GST and obsolescence review.

Bank and treasury master

Bank mandates, authorised signatories, counterparty masters, limits and payment modes affect treasury authority and cash movement.

User and role master

User IDs, roles, privileged access, leaver status and SoD conflicts determine whether master-data changes can be traced and controlled.

Controls

What internal audit should verify govern

Named data owner

Each critical data domain should have a business owner and steward. IT may administer the system, but the process owner should approve field definitions, changes and periodic reviews.

Critical data elements

Identify fields where an error can change cash, compliance, reporting, access, tax, payroll or audit conclusions. Test these fields more deeply than ordinary reference fields.

Maker-checker change control

New records and changes to high-risk fields should retain requester, maker, checker, old value, new value, date/time, reason and approval evidence.

Periodic certification

Owners should periodically review active, dormant, duplicate, high-risk and privileged records. Internal audit should test unresolved exceptions, not just the existence of the review file.

Data quality tests

Completeness, uniqueness, validity, accuracy, timeliness and lineage checks should run before using master data for sampling, analytics, dashboards or monitoring.

Access and segregation

Users who can create or change master data should not also approve transactions that use that master without a reviewed compensating control.

Retention and privacy

Master-data extracts often contain personal or sensitive data. Store them in the approved evidence repository, restrict access and delete working copies under policy after use.

Monitoring handoff

Repeatable exceptions should become continuous monitoring rules only when source fields, thresholds, owner review and false-positive handling are stable.

Red flags

Exceptions worth recurring review monitor

Vendor bank changed then paid

A payment made soon after bank detail change needs old/new value evidence, independent callback, maker-checker approval and payment release review.

Duplicate PAN, GSTIN or bank account

Duplicates can hide split vendors, duplicate customers, ghost employees, related-party leakage or bypassed onboarding controls.

Leaver remains active

Exited employees should not remain active in ERP, HRMS, payroll, bank portal or reporting tools beyond the approved access-removal timeline.

GL mapping changed during close

Late changes to reporting tags, account mappings or close roles can alter financial dashboards and management reports without enough review.

Dormant master reactivated

Reactivation after a long inactive period should trigger refreshed due diligence, approval and first-transaction review.

Bulk upload without old values

Bulk create/change files are high-risk if the audit trail cannot show old values, approver, business reason and rejected rows.

Authority anchors

Sources to cite in the workpaper cite

DAMA-DMBOK data governance vocabulary

Use data owner, data steward, critical data element, data quality, master/reference data, metadata and lineage language so audit findings match how data teams operate.

IIA Big Data and Global Standards

Use IIA guidance when internal audit relies on data, analytics, automation or dashboards. The file should show reliable, relevant, sufficient and useful information.

ICAI Standards on Internal Audit

For Indian files, connect data governance testing to SIA 120 internal controls, SIA 130 risk management, SIA 220 overall internal audit planning, SIA 310 assignment planning, SIA 320 evidence, SIA 330 documentation, SIA 350 review and supervision, SIA 360 communication, SIA 370 reporting and SIA 520 IT environment work.

Companies Act Section 138 and Rule 13

For covered Indian companies, master-data and data-governance reviews should fit the approved internal audit scope, functioning, periodicity and methodology.

DPDP Act, Rules and company policy

Where master data contains digital personal data, verify the DPDP Act 2023, DPDP Rules 2025 notified on 14 November 2025, current effective dates, processor terms, retention rules, access restrictions and breach/escalation process before final reporting.

Product reuse

Website resource now, product model later model

This public resource can become specification input for the separate Internal Audit product build: data domains, critical data elements, master-data change evidence, data-quality tests, retention/privacy controls and monitoring rules.

Data domain register

Reference data model: Domain, source system, owner, steward, critical fields, risk rating and review cadence.

Critical data element catalogue

Control library: Field, risk impact, validation rule, source evidence, owner, linked cycle and monitoring candidate.

Master-data change log

Evidence workflow: Old value, new value, requester, maker, checker, date, reason, ticket and downstream transaction impact.

Quality test library

Analytics engine: Completeness, uniqueness, validity, accuracy, timeliness and lineage tests by domain and cycle.

Retention and privacy map

Data protection workflow: Personal-data flag, purpose, access group, retention route, export control and deletion evidence.

Monitoring rules handoff

Continuous monitoring: Rule ID, source fields, threshold, owner, false-positive route, closure evidence and dashboard flag.

Related resources

Use this with data, ITGC and cycle audits next

Source Data Readiness

Validate report extraction, control totals, field dictionaries and join keys before testing.

ITGC Internal Audit Checklist

Use ITGC for access, audit logs, change management, interfaces and report reliability controls.

P2P Internal Audit Checklist

Apply vendor master and payment master controls to procurement and AP fieldwork.

O2C Internal Audit Checklist

Apply customer master, credit-limit, pricing and GST field controls to revenue work.

R2R Internal Audit Checklist

Apply GL, reporting mapping and close-access controls to financial reporting work.

Continuous Monitoring Rules

Convert repeat master-data exceptions into owner-reviewed monitoring rules.

FAQs

Data governance audit questions answered

What is data governance in internal audit?

Data governance in internal audit is the review of whether critical business data has clear ownership, approved definitions, controlled changes, quality checks, access restrictions, retention discipline and evidence strong enough to support audit testing, analytics and reporting.

What master data should internal audit test first?

Start with master data that can move cash, change compliance, affect reporting or override access: vendor bank details, customer credit limits, employee bank and exit fields, GL/reporting mappings, item masters, bank mandates and privileged user roles.

How is this different from source data readiness?

Source data readiness checks whether a specific report or extract can be relied on for testing. Data governance checks whether the underlying domains, owners, critical fields, master-data changes, retention and monitoring rules are controlled over time.

Should internal audit treat master-data exceptions as observations?

Not automatically. Exceptions should be traced to approval evidence, business rationale, transaction impact, compensating controls and repeat patterns. Report the issue when the control failure is real, material to the audit objective and not cleared by evidence.

Can data governance testing support continuous monitoring?

Yes. Vendor bank changes, duplicate masters, leaver access, dormant reactivation, GL mapping changes and privileged master-data activity are strong monitoring candidates when source fields, thresholds, owner review and closure evidence are stable.