How To Get Started with your IT Compliance Efforts for SOX

There’s no question about it. For many of you top executives in the corporate world, all roads leading to a brighter future have to go through SOX compliance. And because the business processes that contribute to financial reporting (the crux of the Sarbanes-Oxley Act) are now highly reliant on IT systems, it is important to focus a good part of your attention there.

It is a long and arduous path to IT compliance, so if you don’t want your company to fall by the wayside due to inefficient utilisation of resources, it is important to set out with a plan on hand. What we have here are some vital information that will guide you in putting together a sound plan for SOX compliance of your company?s IT systems.

Why focus on IT systems for SOX compliance?

We’ll get to that. But first, let’s take up the specific portions of the Sarbanes-Oxley Act that affect information technology. These portions can be found in Section 302 and Section 404 of the act.

In simplified form, Section 302 grants the SEC (Securities and Exchange Commission) authority to come up with rules requiring you, CEOs and CFOs, to certify in each annual or quarterly financial report the following:

  • that you have reviewed the report;
  • that based on your knowledge, the report does not contain anything or leave out anything that would render it misleading;
  • that based on your knowledge, all financial information in the report fairly represent the financial conditions of the company;
  • that you are responsible for establishing internal controls over financial reporting; and
  • that you have assessed the effectiveness of the internal controls.

Similarly, Section 404, stated in simplified form, allows the SEC to come up with rules requiring you, CEOs and CFOs, to add an internal control report to each annual financial report stating that you are responsible for establishing internal controls over financial reporting.

You are also required to assess the effectiveness of those controls and to have a public accounting firm to attest to your assessment based upon standards adopted by the Public Company Accounting Oversight Board (PCAOB).

While there is no mention of IT systems, IT systems now play a significant role in financial reporting. Practically all of the data you need for your financial reports are stored, retrieved and processed on IT systems, so you really have to include them in your SOX compliance initiatives and establish controls on them.

Now that that’s settled, your next question could very well be: How do you know what controls to install and whether those controls are already sufficient to achieve compliance?

Finding a suitable guide for IT compliance

The two bodies responsible for setting rules and standards dealing with SOX, SEC and PCAOB, point to a well-established control framework for guidance – COSO. This framework was drafted by the Committee of Sponsoring Organisations of the Treadway Commission (COSO) and is the most widely accepted control framework in the business world.

However, while COSO is a tested and proven framework, it is more suitable for general controls. What we recommend is a widely-used control framework that aligns well with COSO but also caters to the more technical features and issues that come with IT systems.

Taking into consideration those qualifiers, we recommend COBIT. COBIT features a well thought out collection of IT-related control objectives grouped into four domains: Plan and Organise (PO), Acquire and Implement (AI), Deliver and Support (DS), and Monitor and Evaluate (ME). The document also includes maturity models, performance goals and metrics, and activity goals.

A few examples of COBIt’s detailed control objectives are:

DS4.2 – IT Continuity Plans
DS4.9 – Offsite Backup Storage
DS5.4 – User Account Management
DS5.8 – Cryptographic Key Management
DS5.10 – Network Security
DS5.11 – Exchange of Sensitive Data

By those titles alone, you can see that the framework is specifically designed for IT. But the document is quite extensive and, chances are, you won’t need all of the items detailed there. Furthermore, don’t expect COBIT to specify a control solution controls for every control objective. For example, throughout the control objective DS4 (Ensure Continuous Service), you won’t find any mention of virtualisation, which is common in any modern business continuity solution.

Basically, COBIT will tell you what you need to attain in order to achieve effective governance, management and control, but you’ll have to pick the solution best suited to reach that level of attainment.

Articles highly relevant to the one you just read:

Month End Accounting The Way It Should Be Today
Spreadsheet Woes ? Burden in SOX Compliance and Other Regulations
Spreadsheet Woes ? Limited Features For Easy Adoption of a Control Framework
How Internal Auditors Can Win The War Against Spreadsheet Fraud

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Firewalls

There are two main reasons why some companies are hesitant to plug into the Internet.

  1. They know they’ll be exposing their company data to outside attacks from malicious individuals and malware.
  2. They fear their employees might get too many distractions: games, porn, chats, videos, and even social networking sites.

One vital component for your overall security strategy against such concerns? A firewall.

A firewall can block unauthorised access to certain Internet services from inside your organisation as well as prevent unauthenticated access from the outside. It is also used to monitor users’ activities while they were online.

In an enterprise setting, one may expect a collection of firewalls either for providing layered protection or segmenting off different units in the organisation. Some areas only need a standard line of defence while others require more restrictions. As such, certain firewalls may have different configurations compared to others.

Naturally, the more intricate an organisation’s defence requirements get, the more complex the task of monitoring, testing and configuring the firewalls becomes. That’s why we’re here to help.

  • We’ll evaluate your network as well as the security requirements of each department under your organisation to determine which firewall architecture is most suitable.
  • To achieve maximum efficiency, we’ll point out where each firewall should be positioned.
  • We’ll work with your key personnel to make sure all firewall configurations are set and optimised with your business rules in mind.
  • If a large number of firewalls are required, we’ll help you set up a firewall configuration management system.
  • Firewalls should be regularly tested and assessed to ensure they are in line with the organisation’s security policies. We’ll perform these routine tasks as well.

Firewalls aren’t very good at defending against sophisticated viruses. There are much better solutions for malware-related vulnerabilities, and we can help you in that regard too.

Other defences we’re capable of putting up include:

A Definitive List of the Business Benefits of Cloud Computing

When you run a Google search for the “benefits of cloud computing”, you’ll come across a number of articles with a good list of those. However, most of them don’t go into the details, which nevertheless might still suit some readers. But if you’re looking for compelling business reasons to move your company’s IT to the cloud, a peripheral understanding of what this technology can do for you certainly won’t cut it.

Now, cloud computing is not just one of those “cool” technologies that come along every couple of years and which can only benefit a particular department.?What we’re talking about here really is a paradigm shift in computing that can transform not only entire IT infrastructures but also how we run our respective organisations.

I hate to think that some people are holding back on cloud adoption just because they haven’t fully grasped what they’re missing. That is why I decided to put together this list. I wanted to produce a list that would help top management gain a deeper understanding of the benefits of the cloud.

Cloud computing is one bandwagon you really can’t afford not to jump into. Here are ten good reasons why:

1.?Zero?CAPEX and low TCO for an enterprise-class IT infrastructure

2. Improves cash flow

3. Strengthens business continuity/disaster recovery capabilities

4. Lowers the cost of analytics

5. Drives business agility

6. Ushers in anytime, anywhere collaboration

7. Enhances information, product, and service delivery

8. Keeps entire organisation in-sync

9. ?Breathes life into innovation in IT

10. Cultivates optimal environments for development and testing

Zero CAPEX and low TCO for an enterprise-class IT infrastructure

Most cloud adopters with whom I’ve talked to cite this particular reason for gaining interest in the cloud.

Of course they had to dig deeper and consider all other factors before ultimately deciding to migrate. But the first time they heard cloud services could give them access to enterprise class IT infrastructures without requiring any upfront capital investment, they realised this was something worth exploring.

A good IT infrastructure can greatly improve both your cost-effectiveness and your capability to compete with larger companies. The more reliable, fast, highly-available, and powerful it is, the better.

But then building such an infrastructure would normally require a huge capital investment for networking equipment, servers, data storage, power supply, cooling, physical space, and others, which could run up to tens or even hundreds of thousands of euros. To acquire an asset this costly, you’d have to take in debt and be burdened by the ensuing amortisation.

If you’ve got volumes of cash stashed in your vault, cost might not be a problem. But then if you really have so much savings, wouldn’t it be more prudent to use it for other sales-generating projects? An extensive marketing endeavour perhaps?

A capital expenditure of this magnitude and nature, which normally has to be approved by shareholders, can be regarded as a high financial risk. What if business doesn’t do well and you wouldn’t need all that computing power? What if the benefits expected from the IT investment are not realised??You cannot easily convert your IT infrastructure into cash.

Remember we’re talking about a depreciating asset. So even assuming you can liquidate it, you still can’t hope to sell it at its buying price. These factors are going to play in the minds of your Board of Directors when they’re asked to decide on this CAPEX.

Incidentally, these issues don’t exist in a cloud-based solution.

A cloud solution typically follows a pay-as-you-go utility pricing model where you get billed monthly (sometimes quarterly) just like your electricity. ?In other words, it’s an expense you’ll need to pay for?at the end of a period over which the service’s value would have already been realised. Compare that with a traditional infrastructure wherein you’ll have to spend upfront but the corresponding value will still have to be delivered gradually in the succeeding months or years.

demand expense traditional infrastructure

From the point of view of your CFO, what could have been a CAPEX to acquire an asset that depreciates with time (and consequently reduces your company’s net worth), becomes a flexible operating expense (OPEX).?Truly, it is an operating expense that you can increase, decrease, or even totally discontinue, depending on what the prevailing business conditions demand.

demand expense cloud infrastructure

People who think they have done the math in comparing cloud-based and traditional IT infrastructures claim that, although they see how cloud solutions transform CAPEX into OPEX, they really don’t see any significant difference in overall costs.

However, these people have only gone as far as adding up the expected monthly expenses of a cloud solution over the estimated duration of an equivalent IT infrastructure’s effective lifespan and comparing the sum with that IT infrastructure’s price tag. You won’t get a clear comparison that way.

You need to consider all factors that contribute to the infrastructure’s Total Cost of Ownership (TCO). Once you factor in the costs of electricity, floor space, storage, and IT administrators, the economical advantages of choosing a cloud solution will be more evident. Add to that the costs of downtime such as: interruptions to business operations, technical support fees, and the need to maintain expensive IT staff who spend most of their time “firefighting”, and you’ll realise just how big the savings of cloud adopters can be.

Still not convinced? Well, we’re still getting started.?On our next post, we’ll take a closer look at the additional benefits of paying under an OPEX model instead of a CAPEX model.

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The Future of Cloud Backup and Recovery

We came across a post on Docurated that pulled together thirty-seven suggestions for the top cloud storage mistakes user companies make. Given that cloud storage seems to be the best backup solution for now at least, we decided to turn these ideas around to sense the direction cloud backup and recovery needs to take, if it is still to be relevant in say ten years? time.

Has Cloud Storage Largely Saturated the West?
It probably has. Outside of major corporates who make their own arrangements ? and SME?s that use free services by email providers ? the middle band of companies in Europe and America have found their service providers, although they may have never tested the recovery process, to see if it works.

The new gold rush in the cloud backup and recovery business is, or should be emerging markets in Asia, Africa, South America, and the Middle East. There, connectivity is brittler than over here. To be relevant in these fragile, more populous areas our cloud backup and recovery industry need to be more agile and nimble.

? It must provide a simpler service emerging commerce can afford, refresh its user interfaces in third world languages, have more accessible help, and be patient to explain how cloud storage works to newbies. In other words, it must source its call centre operators in the areas it serves.

? It must adapt to local connectivity standards, and stop expecting someone with ADSL broadband to keep up with cloud server networks running at up to 1GBPS compared to their 10MBPS at best. For user sourcing and retention purposes, these new cloud backup and recovery services must be the ones who adapt.

? It must facilitate disaster recovery simulations among its clients in calmer moments when things are going well. Are they backing up the right files, are they updating these, and are their brittle ADSL networks able to cope with their cloud service providers? upload and download speeds?

? It must develop lean and agile systems slim enough to accommodate a micro client starting out, but sufficiently elastic to transfer them seamlessly to big data performance. The Asian, African, South American, and Middle Eastern regions are volume driven, and individual economies of scale are still rare.

? It must not expect its users to know automatically what they need, and be honest to admit that Western solutions may be wrong-sized. Conversion funnels in the new gold rush are bound to be longer. Engagements there depend on trust, not elevator sales letters. Our competition in these countries already works this way.

? It must be honest and admit cloud storage is only part of the solution. To recruit and retain users it must step back to 1983, when Compuserve offered its customers 128k of disc space, and spent an amount of effort explaining how to filter what to put there.

Cloud Storage of Data is Only One Part of the Solution
Governance reports and stock certificates burn just as easily as do servers in a fire. We must not transfer bad habits to exciting new markets. We close this article with the thoughts of John Howie, COO of Cloud Security Alliance, as reported in the Docurated post we mentioned, and these apply across the globe, we believe.
There is no single most important thing to carry forward into the future of cloud backup and recovery. We must be mindful when moving data that this can be fragile too. We must also create layers of backup the way insurance companies re-insure, that make any one cloud backup and recovery business redundant if it happens.
We hold the trust of our customers in our hands but trust is delicate too. We must cease trying to make a pile of money quickly, and become more interested in ensuring that data transferred back and forth is synchronised. The cloud backup and recovery industry needs only one notorious mistake, to become redundant itself in the ten years we mentioned.

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