How COBIT helps you achieve SOX Compliance

First released way back in 1996, COBIT has already been around for quite a while. One reason why it never took off was because companies were never compelled to use it ? until now. Today, many CEOs and CIOs are finding it to be a vital tool for achieving SOX compliance in IT.

Thanks to SOX, COBIT (Control Objectives for Information and related Technology) is now one of the most widely accepted source of guidance among companies who have IT integrated with their accounting/financial systems. It has also gained general acceptability with third parties and regulators. But how did this happen?

Role of control frameworks in SOX compliance

You see, the Sarbanes-Oxley Act, despite having clearly manifested the urgency of establishing effective internal controls, does not provide a road map for you to follow nor does it specify a yardstick to help you determine whether an acceptable mileage in the right direction has already been achieved.

In other words, if you were a CIO and you wanted to find guidance on what steps you had to take to achieve compliance, you wouldn’t be able to find the answers in the legislation itself.

That can be a big problem. Two of your main SOX compliance obligations as a CEO or CIO is to assume responsibility in establishing internal controls over financial reporting and to certify their effectiveness. After that, the external auditors are supposed to attest to your assertions. Obviously, there has to be a well-defined basis before you can make such assertions and auditors can attest to anything.

In the language of auditors, this ?well-defined basis? is known as a control framework. Simply put, once you certify the presence of adequate internal controls in your organisation, the external auditor will ask, ?What control framework did you use??

Knowing what control framework you employed will help external auditors determine how to proceed with their evaluations and tests. For your part, a control framework can serve as a guide to help you work towards specific objectives for achieving compliance. Both of you can use it as a common reference point before drawing any conclusions regarding your controls.

But there are many control frameworks out there. What should you use?

How SOX, COSO, and COBIT fit together

Fortunately, despite SOX?s silence regarding control frameworks, you aren’t left entirely to your own devices. You could actually take a hint from the SEC and PCAOB, two of the lead organisations responsible for implementing SOX. SEC and PCAOB point to the adoption of any widely accepted control framework.

In this regard, they both highly endorse COSO, a well-established internal control framework formulated by the Committee of Sponsoring Organisations of the Treadway Commission (COSO). Now, I must tell you, if you’re looking specifically for instructions pertaining to IT controls, you won’t find those in COSO either.

Although COSO is the most established control framework for enterprise governance and risk management you’ll ever find (and in fact, it’s what we recommend for your general accounting processes), it lacks many IT-related details. What is therefore needed for your IT processes is a framework that, in addition to being highly aligned with COSO, also provides more detailed considerations for IT.

This is where COBIT fits the bill.

How COBIT can contribute to your regulatory compliance endeavors

COBIT builds upon and adheres with COSO while providing a finer grain of detail focused on IT. You can even find a mapping between COBIT IT processes and COSO components within the COBIT document itself.

Designed with regulatory compliance in mind, COBIT lays down a clear path for developing policies and good practice for IT control, thus enabling you to bridge the gap between control requirements, technical issues, and business risks.

Some of the components you’ll find in COBIT include:

IT control objectives

These are statements defining specific desired results that, as a whole, characterise a well-managed IT process. They come in two forms for each COBIT-defined IT process: a high-level control objective and a number of detailed control objectives. These objectives will enable you to have a sense of direction by telling you exactly what you need to aim for.

Maturity models

These are used as benchmarks that give you a relative measurement stating where your level of management or control over an IT process or high-level control objective stands. It serves as a basis for setting as-is and to-be positions and enables support for gap analysis, which determines what needs to be done to achieve a chosen level. Basically, if a control objective points you to a direction, then its corresponding maturity model tells you how far in that direction you’ve gone.

RACI charts

These charts tell you who (e.g. CEO, CFO, Head of Operations, Head of IT Administration) should be Responsible, Accountable, Consulted, and Informed for each activity.

Goals and Metrics

These are sets of goals along with the corresponding metrics that allow you to measure against those goals. Goals and metrics are defined in three levels: IT goals and metrics, which define what business expects from IT; process goals and metrics, which define what the IT process should deliver to support It’s objectives; and activity goals and metrics, which measure how well the process is performing.

In addition to those, you’ll also find mappings of each process to the information criteria involved, IT resources that need to be leveraged, and the governance focus areas that are affected.

Everything is presented in a logical and manageable structure, so that you can easily draw connections between IT processes and business goals, which will in turn help you decide what appropriate governance and control is needed. Ultimately, COBIT can equip you with the right tools to maintain a cost-benefit balance as you work towards achieving SOX compliance.

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Computer Forensics

So you had a customer data security breach last weekend? Do you know you could be held liable in court for failing to implement required security procedures? That’s right. Due to the overwhelming surge in identity theft wherein nearly 20 million Americans have already been affected, most states have enacted laws to curtail this fast rising crime. Therefore, it is important to redefine how your company deals with customer data security.

  • First, you’ll want to know what your obligations are as dictated by law. Some places, for example, require the destruction or deletion of personal data through shredding, erasing, or by rendering them undecipherable.
  • Second, not only do you need to comply with the said requirements, you’ll also have to prove in court that you actually complied if ever a security breach does happen.
  • Third, you need to be aware of your post-breach duties to avoid being dealt additional penalties.

Obviously, such situations now call for individuals who are experts in both the legal and technical aspects regarding data security. Such individuals are practitioners of a relatively new discipline known as computer forensics.

Armed with our computer forensics specialists, we’ll be able to help you deal with the above concerns. As a result, you can be prevented from having to pay fines that can go up to hundreds of thousands of euros.

There are other equally important reasons why you would want to avail of computer forensics services. For example, you’ll need computer forensics specialists because you want to:

  • Catch a person involved in criminal activities such as child porn, stealing of personal data, and destroying intellectual property.
  • Investigate a computer, network, or even a mobile device for clues that may lead to the culprit.
  • Determine the extent and possible causes when you discover your digital data has been damaged.
  • Find and recover damaged, deleted or encrypted data regardless of whether the cause was intentional or not. If the data in question will be used as evidence in a legal action, there are certain procedures that need to be followed during recovery operations to retain the integrity of the data. Computer forensic specialists are highly qualified for such operations.
  • Implement security policies in your organisation. Such policies have to operate within legal bounds if you want to avoid possible sanctions in the future. These policies should also be designed such that future forensic operations can be conducted with a high likelihood of success.

That said, a company that integrates computer forensics into its IT security policies and practices will be better equipped to remedy the situation once data security has already been compromised than a company that doesn’t.

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What Sub-Metering did for Nissan in Tennessee

When Nissan built its motor manufacturing plant in Smyrna 30 years ago, the 5.9 million square-foot factory employing over 8,000 people was state of art. After the 2005 hurricane season sky-rocketed energy prices, the energy team looked beyond efficient lighting at the more important aspect of utility usage in the plant itself. Let’s examine how they went about sub-metering and what it gained for them.

The Nissan energy team faced three challenges as they began their study. They had a rudimentary high-level data collection system (NEMAC) that was so primitive they had to transfer the data to spread-sheets to analyse it. To compound this, the engineering staff were focused on the priority of getting cars faster through the line. Finally, they faced the daunting task of making modifications to reticulation systems without affecting manufacturing throughput. But where to start?

The energy team chose the route of collaboration with assembly and maintenance people as they began the initial phase of tracking down existing meters and detecting gaps. They installed most additional equipment during normal service outages. Exceptions were treated as minor jobs to be done when convenient. Their next step was to connect the additional meters to their ageing NEMAC, and learn how to use it properly for the first time.

Although this was a cranky solution, it had the advantage of not calling for additional funding which would have caused delays. However operations personnel were concerned that energy-saving shutdowns between shifts and over weekends could cause false starts. ?We’ve already squeezed the lemon dry,? they seemed to say. ?What makes you think there?s more to come??

The energy team had a lucky break when they stumbled into an opportunity to prove their point early into implementation. They spotted a four-hourly power consumption spike they knew was worth examining. They traced this to an air dryer that was set to cyclical operation because it lacked a dew-point sensor. The company recovered the $1,500 this cost to fix, in an amazing 6 weeks.

Suitably encouraged and now supported by the operating and maintenance departments, the Smyrna energy team expanded their project to empower operating staff to adjust production schedules to optimise energy use, and maintenance staff to detect machines that were running without output value. The ongoing savings are significant and levels of shop floor staff motivation are higher.

Let’s leave the final word to the energy team facilitator who says, ?The only disadvantage of sub-metering is that now we can’t imagine doing without it.?

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Technology and process improvement

Tightening organisational flow to improve productivity and minimise costs is a growing concern for many businesses post the Global Financial Crisis. Businesses can no longer afford to waste time and personnel on inefficient processes. Organisations using either Six Sigma or Lean techniques better manage their existing resources to maximise product out-put. Both of these techniques involve considerable evaluation of current processes.

What is Six Sigma?

Six Sigma is an organisational management strategy that evaluates processes for variation. In the Six Sigma model, variation equates waste. Eliminating variation for customer fulfilment allows a business to better serve the end-user. In this thought model, the only way to streamline processes is to use statistical data. Each part of a process must be carefully recorded and analysed for variation and potential improvements. The heart of the strategy embodied by Six Sigma is mathematical. Every process is subject to mathematical analysis and this allows for the most effective problem solving.

What is a Lean Model?

Lean businesses do not rely on mathematical models for improvement. Instead, the focus is on reducing steps in the customer delivery cycle, which do not add value to the final deliverable. For example, maintaining excess inventory or dealing with shortages would both be examples of waste behaviour. Businesses that operate using Lean strategies have strong cash flow cycles. One of the best and most famous examples of Lean in action is the Toyota Production System (TPS). In this system, not only is inventory minimised, but physical movement for employees also remains sharply controlled. Employees are able to reach everything needed to accomplish their tasks, without leaving the immediate area. By reducing the amount of movement needed to work, companies also remove wasted employee time.

Industry Applications for Lean and Six Sigma

Lean businesses reduce the number of steps between order and delivery. The less inventory on hand, the less it costs a business to operate. In industries where it is possible to create to order, Lean thinking offers significant advantages. Lean is best utilised in mature businesses. New companies, operating on a youthful model, may not be able to identify wasteful processes. Six Sigma has shown its value across industries through several evolution’s. Its focus on quality of process makes it a good choice for even brand new businesses. The best use is the combination of the two strategies. With the Lean focus on speed and the Six Sigma focus on quality combined, the two organisational processes create synergy. By itself, Lean does not help create stable, repeating success. Six Sigma does not help increase speed and reduce non value-added behaviours. Combined, these two strategies offer incredible value to every business in cost savings.

Using Technology to Implement Lean Six Sigma

Automation processes represent an opportunity for businesses to implement a combination of both Lean and Six Sigma strategies. Any technology that replaces the need for direct human oversight reduces costs and increases productivity. A few examples of potentially cost saving IT solutions include document scanning, the Internet, and automated workflow systems.

  • Document Scanning – Reducing dependency on paper copies follows both Lean and Six Sigma strategies. It is a Lean addition in that it allows employees to access documents instantly from any physical location. It is Six Sigma compliant in that it allows a reduction on process variation, since there is no bottleneck on the flow of information.
  • The Internet – The automation potential offered by the Internet is limitless. Now, businesses can enter orders, manage logistics and perform customer service activities from anywhere, through a hosted portal. With instant access to corporate processes from anywhere, businesses can manage workflow globally, allowing them to realise cost savings from decentralisation.
  • Automated Work Systems – One of the identified areas of waste in any business is processing time. The faster orders are processed and delivered, the greater the profits for the company and the less the expense per order. When orders sit waiting for attention, they represent lost productivity and waste. Automated work systems monitor workflow and alert users when an item sits longer than normal. These systems can also reroute work to an available employee when the original worker is tied up.

Each of these IT solutions provides a method for businesses to either reduce the number of steps in a process or improve the quality of the process for improved customer service.

Identifying Areas for Lean Six Sigma Implementation

Knowing that improved processes result in improved profits, identifying areas for improvement is the next step. There are several techniques for creating tighter processes with less waste and higher quality. Value Stream Mapping helps business owners and managers identify areas of waste by providing a visual representation of the total process stream. Instead of improving single areas for minimal increases in productivity, VSM shows the entire business structure and flow, allowing management to target each area of slow down for maximum improvement in all areas.

Seeing the areas of waste helps management better determine how processes should work to best obtain the desired outcomes. Adding in automated processes helps with improved process management, when put in place with a complete understanding of current systems and their weaknesses. Start with mapping and gain a bird’s-eye view of the situation, in order to make the changes needed for improvement.

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