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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Symbion Pharmacy Services? Definition of Responsibility

A ?symbion? is an organism in a symbiotic (i.e. mutually beneficial) relationship with another one. In the case of Australia?s giant Symbion Pharmacy Services, this means supplying and delivering over-counter Chemmart medicines to more than 3,000 hospital and retail pharmacies, while remaining mindful of its carbon footprint.

In 1999, the company with the tagline ?life matters? and a desire to be seen as ?a good corporate citizen? decided it was time to measure exactly what it was pumping out from 12 facilities and over 200 vehicles. This was a voluntary decision as even now there is still no carbon emissions law in Australia (although no doubt being a ?first mover? will put the company in a competitive position when this inevitably comes).

Symbion decided to install emission detection devices and connect these to a central monitoring system with the intention of managing what these measured. There were two stages to this process. First, Symbion determined its reporting requirements based on one of its larger warehouses. Following that, it established a carbon footprint for each of its wholly owned and managed facilities. This put it in a position to:

  • Analyse total emissions down to a level of detail where it understood the contribution of each source
  • Use big data management tools to identify carbon hotspots for priority remedial action
  • Inform the affected workforce, explain the monitoring system and keep them in the loop
  • Separately manage energy abatement programs such as lighting and delivery routes

The program also had productivity spin-offs in that it focused management attention on the processes behind the emissions that were ripe for material and system improvements. It also provided marketing leverage. Symbion?s customers are in the wellness business, ahead of the curve when it comes to how emissions contribute to chronic illness, and aware of the cost of this in terms of human capital.

EcoVaro could help you manage your throughputs by analysing your data on our cloud-based system. This includes trending your metrics, comparing them to your industry seasonal average, and providing you with a business-like view of how well you are doing.

Our service reduces your reliance on (and the cost of) third party audits, and simplifies the reporting process to your controlling authority. It simply makes more sense to contract your software out this way, and only pay for it when you need it.

What is Business Intelligence?

How well do you know your customers? That is, can you actually pinpoint which among them are you most profitable with and which are making you spend more? Are you content with the accuracy of your forecasts and market predictions? Do you feel you’re spending more on legal costs and regulatory compliance than you should?

Your IT department may be handling these concerns pretty well but perhaps you’d like to know how you can further improve things.

What we’ve got is an IT solution wrapped in a fancy name called ‘Business Intelligence’ or BI. If you think that’s too strong a term, we invite you to read more below, then you be the judge.

Dashboards – Determine the health of your business at a glance

Most drivers rarely make use of their car’s dashboard. After all, you can still reach your destination by just using the steering wheel, pedals, gear stick and so on. But that’s not exactly the most efficient way to drive, right?

If you want to save on fuel, you’ll want to glance on the RPM and speedometer from time to time. You might also want to utilise the trip meter to determine which route is the shortest to a given destination. Other dashboard components like the fuel gauge, tire pressure gauge, engine temperature indicator, and volt meter can likewise provide information about your car’s health.

The same concept applies to business management. If you want to run your business intelligently, you can make use of BI dashboards. These are tools in a typical business intelligence package that will allow you to determine the health of your business via a set of smartly configured gauges and other intuitive graphical representations.

So that, literally, at a mere glance, you’ll already know whether various units in your company are working efficiently. A dashboard will also give you instant feedback of the strategies you’ve recently implemented; to let you know if things are working as planned.

If you want more information than a dashboard can provide, our BI packages also include highly customised reports.

Reports that help you decide faster

Dashboards are great for getting valuable information at a glance but they won’t tell you everything. For more details, you’ll need to view highly customised reports. Our reports are tailor made for each user. We see to it that, by default, each person gets the information he needs the most.

If you belong to the sales department, you normally won’t need a presentation of the data that is appropriate for people in accounting. That way, you don’t spend time filtering. Instead, you and your people can move on to making well-informed decisions.

Our BI systems make use of your vast collection of data to provide reports that will organise your regulatory requirements and call your attention to approaching deadlines. The same system will provide the right information for your people on the field. If your team members are equipped with smart phones and Pocket PCs, they can retrieve whatever it is they need to know to close deals, make sales, and serve clients faster than the competition.

Generating logical information from disparate sources of data scattered over an enterprise-wide organisation is no easy task. But we’ll make it look simple. That’s because we’ve got the expertise to bring it all together into a robust data warehouse and to extract them in the form of reports and dashboards through OLAP.

OLAP and Data Warehousing – Powering the generation of actionable information

Want to know how to generate reports with the highest degree of accuracy and reliability? In theory, what you need is a single repository or a data warehouse. That is, order receipts, sales invoices, as well as customer & supplier data is integrated with regulatory details, personnel data, and others. These are all specially organised for future reporting and analysis.

However, data, no matter how all-embracing, is useless until it is processed into actionable information. Through OLAP or Online Analytical Processing, you can seamlessly collect all relevant data from your vast repository to answer queries like “What is our company’s profitability for the 2nd quarter in all identified key cities for our top-of-the-line products?”.

The strength of OLAP lies in its inherent ability to perform data analysis and very complex calculations, thus enabling it to return complex queries much faster than other database technologies. It is therefore suitable for very large data sources, i.e., data warehouses.

Dashboards and reports will only give your organisation the edge if the information retrieved is reliable, fast, and accurate – exactly the kind OLAP is so good at.

Mobile BI – Step back and see the big picture anytime, anywhere

Spreadsheets are great for displaying detailed information. However, in today’s highly competitive market, retrieving information that matters the most in the shortest possible time is vital in maintaining a sizeable lead over the competition. To step back and see the big picture, you’ll need insightful tools like dashboards and automatically generated reports.

Reports can be beamed to mobile devices such as smart phones and Pocket PCs. They can also be viewed on eBook readers as well. You can also do the same tasks with spreadsheets. But imagine how you’d need to scroll over a large spreadsheet on any of these mobile devices just to know which customer in your current location has performed well over the last month.

If you really want to make quick, well-informed decisions, BI dashboards for mobile devices is the way to go. You can make use of various business objects such as drill-able charts, performance metrics, and metric trend graphs to make crucial decisions even when on you’re in the field.

The Rights of Individuals Under The General Data Protection Regulation

The General Data Protection Regulation or GDPR is a European Union law reinforcing the rights of citizens concerning the confidentiality of their information, and confirming that they own it. We thought it would be interesting to examine the GDPR effective 25 May 2018 from an Irish citizen?s perspective. This article is a summary of information on the Data Protection Commissioner?s website, but as viewed through a businessperson?s lens.

How the Office Defines Data Protection

The Office believes that organisations receiving personal details have a duty to keep them private and safe. This applies inter alia to information that individuals supply to government, financial institutions, insurance companies, medical providers, telecoms services, and lenders. It also applies to information provided when they open accounts.

This information may be on paper, on computers, or in video, voice, or photographic records. The true owners of this information, the individuals have a right:

  • To make sure that it is factually correct
  • To the assurance that it is shared responsibly
  • That all with access only use it for stated purposes

Any organisation requesting personal information must state who they are, what the information is for, why they need to have it, and to whom else they may provide it.

Consumer Rights to Access Their Personal Information

Private persons have a right under the GDPR to a copy of all their information held or processed by a business. The regulation refers to such businesses as ?data controllers? as opposed to owners, which is interesting. They have to provide both paper and digital data, and ‘related information?.

Data controller fees for this are discretionary within limits. The request may be denied under certain circumstances. The data controller may release information about children to parents and guardians, only if it considers a minor too young to understand its significance. Other third parties such as attorneys must prove they have consent.

Consumer Rights to Port Their Data to Different Services

Since the personal information belongs to the individual, they have a right not only to access it, but also to copy or move it from one digital environment to another. The GDPR requires this be ?in a safe way, without hindrance to usability?. An application could be a banking client that wants to upload their transaction history to a third party price comparison website.

However, the right to data portability only applies to data originally provided by the consumer. Moreover, an automated method must be available for porting. Data controllers must release the information in an open format, and may not charge for the porting service.

Consumer Rights to Complain About Personal Data Abuse

Individuals have a right under the General Data Protection Regulation to have their information rectified if they discover errors. This right extends to an assurance that third parties know about the changes – and who these third party entities are. Data controllers must respond within one month. If they decline the request, they must inform the complainant of their right to further remedial action.

If a data controller refuses to release personal information to the owner, or to correct errors, then the Data Protection Office has legal power to enforce the consumer?s rights. The complainant must make full disclosure of the history of their complaint, and the steps they have taken themselves to attempt to set things right.

Further Advice on Getting Things Ready for 25 May 2018

The General Data Protection Regulation has the full force of law from 25 May 2018 onward, and supersedes all applicable Irish laws, regulations, and policies from that date. We recommend incorporating rights of data owners who are also your customers into your immediate plans. We doubt that forgetting to do so will cut much sway with the Data Commissioner. Remember, you have one month to respond to consumer requests, and only one more month to close things out subject to the matter being complex.

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