Spreadsheet Woes – Burden in SOX Compliance and Other Regulations

End User Computing (EUC) or end User Developed Application (UDA) systems like spreadsheets used to be ideal ad-hoc solutions for data processing and financial reporting. But those days are long gone.

Today, due to regulations like the:

Sarbanes-Oxley (SOX) Act,
Dodd-Frank Act,
IFRS (International Financial Reporting Standards),
E.U. Data Protection Directive,
Basel II,
NAIC Model Audit Rules,
FAS 157,
yes, there?s more ? and counting

a company can be bogged down when it tries to comply with such regulations while maintaining spreadsheet-reliant financial and information systems.

In an age where regulatory compliance have become part of the norm, companies need to enforce more stringent control measures like version control, access control, testing, reconciliation, and many others, in order to pass audits and to ensure that their spreadsheets are giving them only accurate and reliable information.

Now, the problem is, these control measures aren’t exactly tailor-made for a spreadsheet environment. While yes, it is possible to set up a spreadsheet and EUC control environment that utilises best practices, this is a potentially expensive, laborious, and time-consuming exercise, and even then, the system will still not be as foolproof or efficient as the regulations call for.

Testing and reconciliation alone can cost a significant amount of time and money to be effective:

It requires multiple testers who need to test spreadsheets down to the cell level.
Testers will have to deal with terribly disorganized and complicated spreadsheet systems that typically involve single cells being fed information by other cells in other sheets, which in turn may be found in other workbooks, or in another folder.
Each month, an organisation may have new spreadsheets with new links, new macros, new formulas, new locations, and hence new objects to test.
Spreadsheets rarely come with any kind of supporting documentation and version control, further hampering the verification process.
Because Windows won’t allow you to open two Excel files with the same name simultaneously and because a succession of monthly-revised spreadsheets separated by mere folders but still bearing the same name is common in spreadsheet systems, it would be difficult to compare one spreadsheet with any of its older versions.

But testing and reconciliation are just two of the many activities that make regulatory compliance terribly tedious for a spreadsheet-reliant organisation. Therefore, the sheer intricacy of spreadsheet systems make examining and maintaining them next to impossible.

On the other hand, you can’t afford not to take these regulations seriously. Non-compliance with regulatory mandates can have dire consequences, not the least of which is the loss of investor confidence. And when investors start to doubt the management’s capability, customers will start to walk away too. Now that is a loss your competitors will only be too happy to gain.

Learn more about our server application solutions and discover a better way to comply with regulations.

More Spreadsheet Blogs

Spreadsheet Risks in Banks

Top 10 Disadvantages of Spreadsheets

Disadvantages of Spreadsheets – obstacles to compliance in the Healthcare Industry

How Internal Auditors can win the War against Spreadsheet Fraud

Spreadsheet Reporting – No Room in your company in an age of Business Intelligence

Still looking for a Way to Consolidate Excel Spreadsheets?

Disadvantages of Spreadsheets

Spreadsheet woes – ill equipped for an Agile Business Environment

Spreadsheet Fraud

Spreadsheet Woes – Limited features for easy adoption of a control framework

Spreadsheet woes – Burden in SOX Compliance and other Regulations

Spreadsheet Risk Issues

Server Application Solutions – Don’t let Spreadsheets hold your Business back

Why Spreadsheets can send the pillars of Solvency II crashing down

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What GDPR Means in Practice for Irish Business

The General Data Protection Regulation (GDPR) is a European directive aimed at ring-fencing consumer data against illegal or unnecessary access. There is nothing to discuss or debate with local politicians, or the Irish Data Protection Commissioner for that matter. As a European directive, it has over-riding power. To obtain an English version, please visit this link, and select ?EN? from the table of languages.

As you reach for your tea, coffee or Guinness after sighting it, you will be glad to know the Irish Data Protection Commissioner has the lead in turning this into business English we understand. The following diagram should assist you to obtain a quick overview of the process we all have to go through. In this article, we briefly describe what is inside Boxes 1 to 12. The regulation comes into force on 25 May 2018 so we have less than a year to get ready.

The 12 Essential Steps to Implementing the General Data Protection Act

1. Create awareness among your people of what is coming their way. The GDPR has given our regulator discretion to dish out fines up to ?20,000,000 (or 4% of total annual global turnover, whichever is greater) so there is determination to make this happen.

2. Become accountable by understanding the consumer data you hold. Why are you retaining it, how did you obtain it, and why did you originally collect it. Now you know it is there, how much longer will you still need it? How secure is it in your hands, have you ever shared it?

3. Open a communication channel with your staff, your customers, and anyone else using the data. Share how you feel about how accountable you have been with the information in the past. Explain how you plan to comply with the GDPR in future, and what needs to change.

4. Understand the personal privacy entitlement of the subjects of the information. They have rights to access it, correct mistakes, remove information, restrict its use, decline direct marketing, and copy it to their own files. What needs to change in your systems to assure these rights?

5. Issue a policy for allowing consumers access to their information you hold. You must process requests within a month, and you may not charge for the service unless your cost is excessive. You may decline unfounded or excessive demands within your policy guidelines.

6. Adapt to the requirement that you must have a legal basis for everything you do with, and to consumer data. You need to be in a position to justify your actions to the Irish Data Protection Commissioner in the event of a complaint. Having a legitimate interest is no longer sufficient.

7. Ensure that consumer consent to collect, use, and distribute their data is ?freely given, specific, informed, and unambiguous.? From 25 May 2018 onward, this consent will be your only ground to do so. You cannot force consent. Your benchmark becomes what the GDPR says.

8. Issue rules for managing data of underage subjects. This is currently under review and we are awaiting results. Put systems in place to verify age. Set triggers for where guardians must give consent. Make sure age is verifiable. Use language young people understand.

9. Introduce a culture of openness and honesty, whereby breaches of the GDPR are detected, reported, investigated, and resolved. You will have a duty to file a GDPR report with the Data Protection Commissioner within 72 hours, thus it is important to fast track the process.

10. Introduce a policy of conducting a privacy assessment before taking new initiatives. The GDPR calls for ?privacy by deign?, and we need to engineer it in. This may be the right time to appoint a data controller in your company, and start implementing the GDPR while you have time.

11. You may also need to appoint a data protection officer depending on the size of your business. Alternatively, you need to add managing data protection compliance to an employee?s duties, or appoint an external data-protection compliance consultant.

12. Finally, and you will be glad to know this is the end of the list, the GDPR has an international flavour in that multinational organisations will report into the EU Lead Supervisory Authority. This will manage the process centrally while consulting national data authorities.

The GDPR is a project we all need to complete. If we are out of line, it is in our interests to get things straightened out. Once everything is in place, the task should not be too onerous. Getting there could be the pain.

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Spreadsheet Woes – Ill-Equipped for an Agile Business Environment

These days, crucial business decisions have to be made in a split second. However, the quality of these decisions hinges quite often on timely, insightful information and relevant business reporting.

How effective is your business reporting solution in providing you with the information you need at the time you need it?

Chances are, like 75% of small and medium businesses, your company is using spreadsheets. True, spreadsheets are the most common go-to solutions for on-the-fly forecasting, but they may not be your best option for presenting information that require consolidation and in-depth analysis and involve a lot of number crunching, especially with critical data at stake.

Furthermore, spreadsheet-based reports are rarely produced in a timely manner. In today?s fast evolving business environment where flexibility, mobility, and timeliness are the order of the day, this simply won’t do.

Let’s take a look at the particular areas where spreadsheets fall short when it comes to providing dynamic and sound financial reports:

Collaboration

With rapidly changing market conditions, organisations have to conduct budgeting, forecasting, and planning more often. Hectic schedules and geographical distances aren’t a hindrance though, because technologies like the Internet, advanced telecommunications and mobile devices can put instantaneous collaboration at everyone?s fingertips.

But collaborative activities in a dynamic setting can only succeed if all participating individuals are given secure, real time and simultaneous access to the same relevant information. This way, every change made is automatically consolidated and projected unto the bigger picture for everyone to digest.

Alas, spreadsheets aren’t built for this.

Cost Efficiency

Whether we’re in a recession or not, cost efficiency has to be taken into consideration. Are spreadsheets really the cost-effective solution?

Think ?time is money?. With the length of time needed to prepare data, establish controls, consolidate reports and distribute copies, you’ll realise how expensive spreadsheets actually are.

The ability to innovate in a changing economic environment and limited resources – a valuable derivative of agile practices – can give your company a very significant advantage. But dedicating so much time on spreadsheet management can strip your organisation of room for innovation.

Quality of Reports

Business empires rise and fall on the power of relevant information. At the end of the day, top management should assess their sources of key performance reports, planning tools and budgeting applications using these parameters:

Does your financial reporting system give you the right information right when you need it?
Do the reports allow you to look beyond the numbers to spot trends or forecast changes in the market?
Do they furnish enough significant data for you to make informed decisions in good time?

Spreadsheets weren’t designed to analyse data on the enterprise level. As a result, spreadsheet reports often take far too long to prepare and more importantly, may lack the dimension and depth that are crucial in decision making.

Data Reliability

We’re all familiar with the risks associated with spreadsheets. This error-prone UDA can provide inaccurate information simply because of a broken link, an incomplete range, a deleted number, or an incorrect formula. In an active business scenario where data manipulation has to be done under constant time pressure, the risk probabilities escalate.

As they always say, ?If anything can go wrong, it will?. With spreadsheets, a lot of things could go wrong. Is this the kind of tool you?d like to work with when making fast, crucial decisions? If you’re still using spreadsheets, then you?d best forget about dynamic reports and rolling forecasts.

Inability to adapt to personnel turnover

A key challenge in maintaining the spreadsheet system is picking up where another left off. A user would find it difficult to debug, revise, or analyse a spreadsheet system he developed himself and the process becomes doubly complicated if or when another person takes over.

Starting from scratch is painfully counterproductive, so that a newcomer has to spend hours figuring out the original entries in the spreadsheet and the reports it yields.

While no one is indispensable in any organisation, it’s pretty much accurate to say that if a spreadsheet ?developer? leaves, it could momentarily halt the production of key finance reports. In a fast changing business landscape, such failure to monitor performance at critical times could sound the death knell for your company.