Spreadsheet Woes – Burden in SOX Compliance and Other Regulations

End User Computing (EUC) or end User Developed Application (UDA) systems like spreadsheets used to be ideal ad-hoc solutions for data processing and financial reporting. But those days are long gone.

Today, due to regulations like the:

  • Sarbanes-Oxley (SOX) Act,
  • Dodd-Frank Act,
  • IFRS (International Financial Reporting Standards),
  • E.U. Data Protection Directive,
  • Basel II,
  • NAIC Model Audit Rules,
  • FAS 157,
  • yes, there?s more ? and counting

a company can be bogged down when it tries to comply with such regulations while maintaining spreadsheet-reliant financial and information systems.

In an age where regulatory compliance have become part of the norm, companies need to enforce more stringent control measures like version control, access control, testing, reconciliation, and many others, in order to pass audits and to ensure that their spreadsheets are giving them only accurate and reliable information.

Now, the problem is, these control measures aren’t exactly tailor-made for a spreadsheet environment. While yes, it is possible to set up a spreadsheet and EUC control environment that utilises best practices, this is a potentially expensive, laborious, and time-consuming exercise, and even then, the system will still not be as foolproof or efficient as the regulations call for.

Testing and reconciliation alone can cost a significant amount of time and money to be effective:

  1. It requires multiple testers who need to test spreadsheets down to the cell level.
  2. Testers will have to deal with terribly disorganized and complicated spreadsheet systems that typically involve single cells being fed information by other cells in other sheets, which in turn may be found in other workbooks, or in another folder.
  3. Each month, an organisation may have new spreadsheets with new links, new macros, new formulas, new locations, and hence new objects to test.
  4. Spreadsheets rarely come with any kind of supporting documentation and version control, further hampering the verification process.
  5. Because Windows won’t allow you to open two Excel files with the same name simultaneously and because a succession of monthly-revised spreadsheets separated by mere folders but still bearing the same name is common in spreadsheet systems, it would be difficult to compare one spreadsheet with any of its older versions.

But testing and reconciliation are just two of the many activities that make regulatory compliance terribly tedious for a spreadsheet-reliant organisation. Therefore, the sheer intricacy of spreadsheet systems make examining and maintaining them next to impossible.

On the other hand, you can’t afford not to take these regulations seriously. Non-compliance with regulatory mandates can have dire consequences, not the least of which is the loss of investor confidence. And when investors start to doubt the management’s capability, customers will start to walk away too. Now that is a loss your competitors will only be too happy to gain.

Learn more about our server application solutions and discover a better way to comply with regulations.

More Spreadsheet Blogs


Spreadsheet Risks in Banks


Top 10 Disadvantages of Spreadsheets


Disadvantages of Spreadsheets – obstacles to compliance in the Healthcare Industry


How Internal Auditors can win the War against Spreadsheet Fraud


Spreadsheet Reporting – No Room in your company in an age of Business Intelligence


Still looking for a Way to Consolidate Excel Spreadsheets?


Disadvantages of Spreadsheets


Spreadsheet woes – ill equipped for an Agile Business Environment


Spreadsheet Fraud


Spreadsheet Woes – Limited features for easy adoption of a control framework


Spreadsheet woes – Burden in SOX Compliance and other Regulations


Spreadsheet Risk Issues


Server Application Solutions – Don’t let Spreadsheets hold your Business back


Why Spreadsheets can send the pillars of Solvency II crashing down

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The General Data Protection Regulation & The Duty to use Encryption

The General Data Protection Regulation, abbreviated to GDPR, raised a storm when it arrived. In reality, it merely tightened up on existing good practice according to digital security specialists Gemalto. The right to withhold consent and to be forgotten has always been there, for example. However, the GDPR brings a free enforcement service for consumers, thus avoiding the need for third party, paid assistance.

The GDPR Bottom Lines for Data Security
Moreover, the GDPR has penalties it can apply, of the order that might have a judge choking on his wig. Under it, data security measures such as pseudonymisation (substitution of identifying fields) and encryption (encoding including password protection) have become mandatory. Businesses must further respect their client data by:

a) Storing it in a secure environment supported by robust services and systems

b) Having proven measures to restore availability and access after a breach

c) Being able to prove frequent effectiveness testing of these measures.

The General Data Protection Regulation places an onus on businesses to report any data breaches. This places us in a difficult situation. We must either face at least a wrist slap upon reporting failures. Alternatively, pay a fine of up to ?10 million, or 2% of total worldwide annual turnover.

The Engineered Weak Link in the System
Our greatest threat of breach is probably when the data leaves our secure environment, and travels across cyberspace to an employee, stakeholder, collaborator, or the client themselves. Since email became open to attack, businesses and individuals have turned to sharing platforms like Dropbox, Google Drive, Skydrive, and so on. While these do allow an additional layer of password protection, none of these has proved foolproof. The GDPR may still fine us heavily, whether or not we are to blame for the actual breach.

How Hacking is Approaching Being a Science
We may make a mistake we may regret, if we do not take hacking seriously. The 10 worst data hacks Identity Force lists are proof positive that spending lots of money does not guarantee security (any more than having the biggest stock of nuclear weapons). We have to be smart, and start thinking the way that hackers do.

Hacker heaven is finding an Experian or a Dun & Bradstreet that may have shielded 143 million, and 33 million consumer records respectively, behind a single, flimsy cyber-security door. Ignorance is no excuse for them. They should simply have known better. They should have rendered consumer data unreadable at individual record level. The hackers could have found this too demanding to unpick, and have looked elsewhere.

How Data Encryption Can Help Prevent Hackers Succeeding
Encrypting data is dashboard driven, and businesses need not concern themselves about it works. There are, however, a few basic decisions they must take:

a) Purge the database of all information held without explicit permission

b) Challenge the need for the remaining data and purge the nice-to-haves

c) Adopt a policy of encrypting access at business and customer interfaces

d) Register with three freemium encryption services that seem acceptable

e) After experimenting, sign up for a premium service and be prepared to pay

Factors to Consider When Reaching a Decision
Life Hacker?suggests the following criteria although the list is a one-size-fits-all

a) Is the system fast, simple, and easy to operate

b) Can you encrypt hidden volumes within volumes

c) Can you mass-encrypt a batch of files easily

d) Do all other files remain encrypted when you open one

e) Do files automatically re-encrypt when you close them

f) How confident are you with the vendor, on a scale of 1 to 10

It may be wise to encrypt all the files on your system, and not just your customer data. We are always open to a hack by the competition after our strategic planning. If we leave the decision up to IT, then IT, being human may take the easy way out, and encrypt as little as possible.

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How Bouygues manages an Empire-Sized Footprint

Bouygues is into telecoms / media, and building and road construction. It also knows it has to watch its energy footprint closely. Owning 47% of energy giant Alstom keeps it constantly in the media spotlight. Shall we find out more about its facility management policies?

The journal Premises and Facilities Management interviewed MD Martin Bouygues on his personal opinions concerning managing energy consumption in facilities. He began by commenting that this was hardly a subject for the C-Suite in years gone by. Low-level clerks simply paid the bills following which the actual amounts were lost in the general expenses account. That of course has changed.

Early pressure came from soaring energy bills, which were pursued by a whole host of electricity-saving gadgets. However, it was only after the carbon crisis caught business by surprise that the link was forged to aerial pollution, and the social responsibilities of big business to help with the solution. The duty to have an energy strategy became an obligation eagerly policed by organisations such as Greenpeace.

Unsurprisingly, Martin Bouygues? advice begins with keeping energy consumption and its carbon footprint as high up on the agenda as health and safety. ?It needs bravery and a lot of hard work to get it there,? he says, ?so perseverance is the key?. 

The company has developed proprietary software that enables it to pull data from remote sensors in more than 80 countries every fifteen minutes. A single large building can contribute 50 million data items annually making data big business in the system. Every building has an allocated energy performance contract against which results are reported monthly, as a basis for reviewing progress.

The system is intelligent and able to incorporate low-occupancy periods such as weekends and public holidays. What is measured gets managed. We all know that, but how many of us apply the principle to our energy bills. With assistance from ecoVaro, the possible becomes real.

We offer a similar service to the Bouygues model with one notable exception. You don’t buy the software and you only pay when you use it. Our systems are simply designed for busy financial managers.

Using Pull Systems to Optimise Work Flows in Call Centres

When call centres emerged towards the end of the 20th century, they deserved their name ?the sweatshops of the nineties?. A new brand of low-paid workers crammed into tiny cubicles to interact with consumers who were still trying to understand the system. Supervisors followed ?scientific management? principles aimed at maximising call-agent activity. When there was sudden surge in incoming calls, systems and customer care fell over.

The flow is nowadays in the opposite direction. Systems borrowed from manufacturing like Kanban, Pull, and Levelling are in place enabling a more customer-oriented approach. In this short article, our focus is on Pull Systems. We discuss what are they, and how they can make modern call centres even better for both sets of stakeholders.

Pull Systems from a Manufacturing Perspective

Manufacturing has traditionally been push-based. Sums are done, demand predicted, raw materials ordered and the machines turned on. Manufacturers send out representatives to obtain orders and push out stock. If the sums turn out wrong inventories rise, and stock holding costs increase. The consumer is on the receiving end again and the accountant is irritable all day long.

Just-in-time thinking has evolved a pull-based approach to manufacturing. This limits inventories to anticipated demand in the time it takes to manufacture more, plus a cushion as a trigger. When the cushion is gone, demand-pull spurs the factory into action. This approach brings us closer to only making what we can sell. The consumer benefits from a lower price and the accountant smiles again.

Are Pull Systems Possible in Dual Call Centres

There are many comments in the public domain regarding the practicality of using lean pull systems to regulate call centre workflow. Critics point to the practical impossibility of limiting the number of incoming callers. They believe a call centre must answer all inbound calls within a target period, or lose its clients to the competition.

In this world-view customers are often the losers. At peak times, operators can seem keen to shrug them off with canned answers. When things are quiet, they languidly explain things to keep their occupancy levels high. But this is not the end of the discussion, because modern call centres do more than just take inbound calls.

Using the Pull System Approach in Dual Call Centres

Most call centre support-desks originally focused are handling technical queries on behalf of a number of clients. When these clients? customers called in, their staff used operator?s guides to help them answer specific queries. Financial models?determined staffing levels and the number of ?man-hours? available daily. Using a manufacturing analogy, they used a push-approach to decide the amount of effort they were going to put out, and that is where they planted their standard.

Since these early 1990 days, advanced telephony on the internet has empowered call centres to provide additional remote services in any country with these networks. They have added sales and marketing to their business models, and increased their revenue through commissions. They have control over activity levels in this part of their business. They have the power to decide how many calls they are going to make, and within reason when they are going to make them.

This dichotomy of being passive regarding incoming traffic on the one hand, and having active control over outgoing calls on the other, opens up the possibility of a partly pull-based lean approach to call centre operation. In this model, a switching mechanism moves dual trained operators between call centre duties and marketing activities, as required by the volume of call centre traffic, thus making a pull system viable in dual call centres.

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