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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Implementing Matrix Management

Matrix management is a culture change. More than the hierarchical structures, lines of responsibilities, modes of communication and channels of decision-making, it is a concept that needs to be planned ahead and managed appropriately over time.

Implementing matrix management to any organization can be confusing. It is essential to ensure that it fits right to your business strategies, skills and competencies. With this, realizing matrix management should not be taken lightly. Careful stages should be considered, instead.

Here are the steps to proper implementation of matrix management:

Consider Your Business Context

You need to evaluate your organisation to analyse what are your development needs with regards to skills, products, services and market environment. This will help you decide on what type of matrix structure you will apply in your organisation. Consider the following questions in building up your context:

  • What is our strategy?
  • Where are the demands in our business?
  • What are the structures that our competitors currently employ?
  • What are the talents that my people possess?
  • What are other business organizations doing?

Set Your Implementation Scope

Next, you need to define the parameter and set the scope of your implementation. What area in your business do you think matrix management will successfully work? There are several things that you need to consider in setting your scope. You have to make sure that it works well with your overall business strategies, that it can be excellently communicated and easily understood. Also, you must ensure that you acquire the necessary talents and skills in the business to deliver the new system of responsibilities.

Implement the New Structure

When you have already decided what structure type you will implement, you are ready to give it a go. You will need to establish new communication channels so you can monitor the progress and receive feedback effectively.

Here?s how to apply the matrix structure:

  • Highlight your development needs
  • Define roles based on outputs and not inputs
  • Line up procedures and systems to support the structure and the behaviour that comes with it.
  • Invest in training and development
  • Support the key people in the structure by coaching them to better adapt in changes
  • Communicate regularly
  • Monitor progress and make necessary adjustments

Review the Matrix Structure, Roles and Responsibilities

Organisations that successfully implement matrix management adapt to the changes in their environment. With this, they do regular evaluations to highlight the need for changes and revisions. The review can either focus on the structure only or to the entire process as a whole. The results can alter the structure, the roles involved and the responsibilities taken.

The process of implementing matrix management follows a step-by step method. Each stage is equally important with the rest. Hence, if you plan to exploit it in your organisation, you have to recognise the purpose of each step and follow it appropriately. Balance is the key. And when you achieve stability in matrix management, amidst the complex changes in the world of business, then your organisational success is just around the corner.

eCommerce

 

We bet you’ve often read how getting rich through the Internet can be fast and easy. Time for your 5-second reality check: It’s going to entail lots of hard work, dedication, a great deal of information and the ability to use that information to your advantage. Sounds familiar?

Well, it should be. After all, it’s still business. However, while the basic ingredients to achieving success in business are still the basic prerequisites in eCommerce, there are also a lot of technical aspects that have to be factored in. This is where you’ll need us.

Well, actually, we’re going to help you out on those basic ingredients too. That’s because our dedicated specialists will perform most of the hard work until you gain enough know-how to run things on your own.

If you’re starting from scratch, we’ll help you build on your idea and transform it into an actual web-based business.

Then once you’ve got your site online, we’ll redirect traffic to it, attract the right visitors, convert those visitors into buyers and keep them satisfied so that they’ll come back and even spread the word.

Some of our related services include:

IT Risk and Control Solutions Specialists – Why you need them more than ever

Over the years, the capabilities of IT systems have certainly grown by leaps and bounds. But so have the risks that accompany them. Countless threats to IT systems now exist that are capable of seriously disrupting business operations. That’s why companies have to conduct assessments aimed at making sure their systems are still capable of functioning effectively, efficiently, and securely all the time.

If you think you’ve been lucky enough to be spared from these threats, then maybe it’s because you haven’t conducted a risk assessment on your IT system recently. All too often, we hear of CIOs who believed their IT system was in tip-top condition, only to be later caught off-guard by a critical system breakdown that would eventually cripple their business for days or weeks.

More information assets to look after

If, before, you only had to worry about regular office applications, workstations, a LAN and a server, today’s varied and more sophisticated information assets are more challenging to maintain.

In addition to network operating systems, database management systems, content management systems, email systems, virtualization platforms, document management systems, business intelligence applications, and accounting software, a typical enterprise may also have to look after firewalls, intrusion detection systems, storage and backup systems, and data loss prevention systems, to mention a few.

These understandably require the services of experts spanning a wide range of skill sets.

Rising threats to corporate identity and privacy

Individuals are no longer just the ones being preyed upon by identity thieves. Businesses can now be subject to corporate identity theft as well. You could wake up one day finding your business already accused of carrying out illegal activities, a big chunk of your money gone, and your directors? seats already occupied by complete strangers.

To make things worse, corporate threats aren’t just coming from the outside.

Threats to corporate privacy, for instance, can come from within the organisation itself. Sensitive information like trade secrets and financial data are often leaked out (purposely or inadvertently) by employees. This is largely caused by the ever growing number of options for communications and transferring data (e.g. emails, instant messaging, blogs, social networking sites, ftp, P2P, etc.).

Greater challenges in designing, developing, and implementing policies and programs

Laws and regulations like SOX and Solvency II, which have direct impacts on IT, are on the rise. That is why corporate policies and programs now require sweeping changes. You now have to be more deliberate in integrating IT when establishing governance, internal controls, change management, incident management, and performance management.

A solid understanding on widely accepted frameworks and good practices like COBIT, COSO, and CMMI will help you considerably in such undertakings. Using these frameworks as guidelines will not only help you keep your policies and programs attuned to the times, they will also keep you in compliance with regulations.

Increasing demand for disaster recovery and business continuity capabilities

Every time you have a down time, you increase the probability of losing your customers to competitors. The longer the down time, the greater that probability becomes. Therefore, when a major disruption strikes, you should be able to recover at the soonest. If possible, you should be able to deliver products and services as usual.

This of course requires spending to increase your disaster recovery (DR) and business continuity (BC) capabilities. Are you ready for it? Migrating your IT infrastructure from traditional systems to the latest technologies that are better equipped for BC/DR requires careful planning and implementation to ensure an optimal return on investment.

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