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

Check our similar posts

Job & Staff Scheduling with FieldElite Mobile Service Management Software

Field Service Management (FSM) software systems are designed to enable you to manage your mobile workforce from a central point- and do away with the paperwork involved with the process. They connect your technicians on the ground (via app on their phones), to the staff at the head office- who have an interactive dashboard accessed through their browsers. The office team will have access to all the jobs that are to be handled by the company, simplifying the management process and taking away the risks that come with manual data entry. Here, we will walk you through a quick process of scheduling a job for your personnel with FieldElite.

Say you are a HVAC contractor, licensed, bonded and insured. You’ve made quite a name for yourself in the industry, and have a wide range of clients- in both residential and commercial establishments. Consequently, you also have a large workforce to attend to the different situations- from installing to repair and maintenance. One of your clients- let’s call them ABC Computer Supplies, has an issue with their HVAC unit- perhaps a pipe is leaking. It needs to be fixed, and ABC have booked an appointment.? Your goal here is to get one of your personnel to handle the task as soon as possible, and this field service scheduling software comes in handy.

There are two approaches that you can take:

1. Job Scheduling

From your Dashboard, on the left-hand side you will see the menu option. Clicking on Jobs, will take you to all jobs carried out by your company.

FieldElite

The filters will allow you to view different categories of jobs:

  • Complaint– This means that there was an issue with on ground during the task delivery, and the client lodged a complaint.
  • On hold– Here, different aspects can cause a job to be paused- like when spare parts or equipment required for repair jobs have been ordered, and one needs to wait for them to be shipped in from a different location.
  • Pending– This is basically your in-tray, a list of jobs that are to be carried out.
  • In Progress– The technicians are on the ground, attending to the client’s needs, and you’re getting routine updates from them.
  • Incomplete– Though the job had been assigned to the required technician, it was not completed in the set amount of time, thus requiring an additional visit to the site. Given that the FSM solution increases the first-time fix rate, cases of ?incomplete tasks? are reduced.
  • Complete– The task is successfully done and the customer has appended their e-signature, and now it can be invoiced.
  • Cancelled Invoice– The head office determines that a particular invoice shouldn’t be paid, and thus cancels it.

Our focus here is the pending tasks, so use this filter. ABC’s HVAC job will be among these. Clicking on its Job ID will open up the details of the task, with such an Update Job window:

FieldElite Job

This section contains all the information of the job- both past and present, which you can update in real-time. Any changes will be recorded by the system and can be viewed on the “Audit” tab.

As you can see here, the HVAC repair job is both “pending” and “urgent”. No one really likes sitting in an office that feels like an oven. Being the headquarters, it’s likely handles lots of foot traffic, and the damaged HVAC unit will make the working conditions really difficult. It’s best not to keep the client waiting, right?

So, head on over to the Supervisor and Workers section (on the same “Details” tab), and select the personnel suited for the task.

FieldElite Job Details

Set the time that the task will take for your technician, and once satisfied with the details of the job, click on Update. Voila! You’re done.

FieldElite Job Update

Immediately this happens, the worker received a notification on their app, telling them that they have been assigned the job.

From the app, the technician will be able to view the specifics of the HVAC job, including notes and attachments that you can add directly from your own dashboard, such as schematics of the building and reports from other technicians who installed the air conditioning system for the facility. You also get to add products that will be required for the task- like the pipe and panel mounted socket shown here. As the system also includes an inventory of the products used, their quantity and costs, you will be able to keep an accurate record of the supplies as they as are used.

As such, the field workers will not have to keep coming back to the central office to get documents and reports of new tasks, or walk around with bulky files. When they are carrying out the job, they will also be able to keep the staff at the office updated about its progress, through the chat feature on the mobile app, taking photos and adding notes as required.

2. Staff Scheduling

With this approach, the perspective is basically: ?So I have a couple of jobs- which of my employees has time to handle them?? The FSM allows you to optimise your productivity- by ensuring that you get the most out of the staff work hours, and avoid cases of jobs going into overtime.

Follow these steps:

  1. Select ?Scheduler? from the left-hand side of the window. You will have a view of the workers of your company and how their day is planned out, and a summary of the unassigned jobs.

Here, you can tell whose busy, and who can have a new task assigned to them at the click of a button- which is far more effective than keeping on jotting down points in your diary or going through files of documents.

If the job has yet to be added to the system- like for the cases of new clients, simply click on the ?Add Job? button and key in its details.

2. Scroll down, you will see a list of unassigned jobs.

unassigned jobs

3. Next, click on the edit button under ?Actions?. This will take you to the same ?Update Job? window described in the first approach, in order to assign the preferred worker to the role.

This real-time dispatching avoids cases of your desk getting cluttered with paper sheets, and prevents duplicate entries as each job has its own ID and task details- from the scheduling to the invoicing. In this case, your HVAC technician will have access to the information needed right at the palm of their hand, to ensure that the task at ABC?s head office goes seamlessly. The optimised schedule will enable the task to be carried out faster- restoring normalcy to your client’s facility.? In case the client’s location is on the route that one of your technicians takes while heading home, you can take advantage of this by giving them the task towards the end of their working day- thus clearing more of your backlog, sorting out your client, and easing your technician?s worries about getting home late.

As you can see, the field service scheduling software enables you to easily and efficiently handle your workflow, avoid the mess that is associated with manual documentation and cases of your employees getting conflicting schedules and overlaps- which would strain them and dampen their morale. Streamlining your workflow and standardising operations ultimately results in increased customer satisfaction.

The Better Way of Applying Benford’s Law for Fraud Detection

Applying Benford’s Law on large collections of data is an effective way of detecting fraud. In this article, we?ll introduce you to Benford’s Law, talk about how auditors are employing it in fraud detection, and introduce you to a more effective way of integrating it into an IT solution.

Benford’s Law in a nutshell

Benford’s Law states that certain data sets – including certain accounting numbers – exhibit a non-uniform distribution of first digits. Simply put, if you gather all the first digits (e.g. 8 is the first digit of ?814 and 1 is the first digit of ?1768) of all the numbers that make up one of these data sets, the smallest digits will appear more frequently than the larger ones.

That is, according to Benford’s Law,

1 should comprise roughly 30.1% of all first digits;
2 should be 17.6%;
3 should be 12.5%;
4 should be 9.7%, and so on.

Notice that the 1s (ones) occur far more frequently than the rest. Those who are not familiar with Benford’s Law tend to assume that all digits should be distributed uniformly. So when fraudulent individuals tinker with accounting data, they may end up putting in more 9s or 8s than there actually should be.

Once an accounting data set is found to show a large deviation from this distribution, then auditors move in to make a closer inspection.

Benford’s Law spreadsheets and templates

Because Benford’s Law has been proven to be effective in discovering unnaturally-behaving data sets (such as those manipulated by fraudsters), many auditors have created simple software solutions that apply this law. Most of these solutions, owing to the fact that a large majority of accounting departments use spreadsheets, come in the form of spreadsheet templates.

You can easily find free downloadable spreadsheet templates that apply Benford’s Law as well as simple How-To articles that can help you to implement the law on your own existing spreadsheets. Just Google “Benford’s law template” or “Benford’s law spreadsheet”.

I suggest you try out some of them yourself to get a feel on how they work.

The problem with Benford’s Law when used on spreadsheets

There’s actually another reason why I wanted you to try those spreadsheet templates and How-To’s yourself. I wanted you to see how susceptible these solutions are to trivial errors. Whenever you work on these spreadsheet templates – or your own spreadsheets for that matter – when implementing Benford’s Law, you can commit mistakes when copy-pasting values, specifying ranges, entering formulas, and so on.

Furthermore, some of the data might be located in different spreadsheets, which can likewise by found in different departments and have to be emailed for consolidation. The departments who own this data will have to extract the needed data from their own spreadsheets, transfer them to another spreadsheet, and send them to the person in-charge of consolidation.

These activities can introduce errors as well. That’s why we think that, while Benford’s Law can be an effective tool for detecting fraud, spreadsheet-based working environments can taint the entire fraud detection process.

There?s actually a better IT solution where you can use Benford’s Law.

Why a server-based solution works better

In order to apply Benford’s Law more effectively, you need to use it in an environment that implements better controls than what spreadsheets can offer. What we propose is a server-based system.

In a server-based system, your data is placed in a secure database. People who want to input data or access existing data will have to go through access controls such as login procedures. These systems also have features that log access history so that you can trace who accessed which and when.

If Benford’s Law is integrated into such a system, there would be no need for any error-prone copy-pasting activities because all the data is stored in one place. Thus, fraud detection initiatives can be much faster and more reliable.

You can get more information on this site regarding the disadvantages of spreadsheets. We can also tell you more about the advantages of server application solutions.

UK Hauliers Pull Together on ESOS

ESOS is what UK business needed, to encourage it to become more responsible for the environmental consequences of making money. Government has met with industry leaders to hammer out the finer details. Now there are heartening signs of intra-industry collaboration, for the example the FTA approach we discuss here.

The Freight Transport Association (FTA) is one of the UK?s biggest trade associations, and exists to represent the interests of companies moving goods by air, rail, sea and road. It is their representative at national, European and local level that advises them on legal compliance. In February 2015, it announced plans to help the industry comply with ESOS too.

The association has been active since the announcement of the UK?s Energy Saving Opportunity Scheme. It has engaged with government and membership through the portal of its Logistics Carbon Reduction Scheme (LCRS). The Environment Agency has singled this out as a benchmark other industries could follow.

FTA general manager for consultancy and tendering Karen Packham recently said, ?With our highly experienced and fully qualified team of transport auditors ?the FTA is best placed to offer practical advice and is able to provide specialist audits to ensure members are fully compliant ? and will gain all the benefits that the scheme has to offer.?

These co-audits with Environment Agency specialists advising, will focus on the full range of operational and supporting activities, and ensure that all haulage companies with over 250 employees do the following:

  • Assess energy use across their full spread of buildings, transport media and industrial activity
  • Examine energy-intensive pressure points and identify savings opportunities that provide financial benefit
  • Nominate an ESOS person to conduct future audits, or oversee and approve them independently
  • Report to the Environment Agency as scheme administrator per statutory intervals

Ecovaro has energy management software that turns metrics into high-level information that busy people understand. Give us a call if you are puzzling how best to present your data. We believe two heads can achieve so much more together.

Ready to work with Denizon?