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


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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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2015 ESOS Guidelines Chapter 6 – Role of Lead Assessor

The primary role of the lead assessor is to make sure the enterprise?s assessment meets ESOS requirements. Their contribution is mandatory, with the only exception being where 100% of energy consumption received attention in an ISO 50001 that forms the basis of the ESOS report.

How to Find a Lead Assessor

An enterprise subject to ESOS must negotiate with a lead assessor with the necessary specialisms from one of the panels approved by the UK government. This can be a person within the organisation or an third party. If independent, then only one director of the enterprise need countersign the assessment report. If an employee, then two signatures are necessary. Before reaching a decision, consider

  • Whether the person has auditing experience in the sector
  • Whether they are familiar with the technology and the processes
  • Whether they have experience of auditing against a standard

The choice rests on the enterprise itself. The lead assessor performs the appointed role.

The Lead Assessor?s Role

The Lead Assessor?s main job is reviewing an ESOS assessment prepared by others against the standard, and deciding whether it meets the requirements. They may also contribute towards it. Typically their role includes:

  • Checking the calculation for total energy consumption across the entire enterprise
  • Reviewing the process whereby the 90% areas of significant consumption were identified
  • Confirming that certifications are in place for all alternate routes to compliance chosen
  • Checking that the audit reports meet the minimum criteria laid down by the ESOS system

Note: A lead assessor may partly prepare the assessment themselves, or simply verify that others did it correctly.

In the former instance a lead assessor might

  • Determine energy use profiles
  • Identify savings opportunities
  • Calculate savings measures
  • Present audit findings
  • Determine future methodology
  • Define sampling methods
  • Develop audit timetables
  • Establish site visit programs
  • Assemble ESOS information pack

Core Enterprise Responsibilities

The enterprise cannot absolve itself from responsibility for good governance. Accordingly, it remains liable for

  • Ensuring compliance with ESOS requirements
  • Selecting and appointing the lead assessor
  • Drawing attention to previous audit work
  • Agreeing with what the lead assessor does
  • Requesting directors to sign the assessment

The Environment Agency does not provide assessment templates as it believes this reduces the administrative burden on the enterprises it serves.

The Connection between Big Data and MDM

Master Data is information that is critical to your business. This could include contracts, proprietary information, intellectual capital and a whole lot more besides. Because this often reposes in a variety of different places, you need a master data management / MDM policy to control it. That way, you can link it all together in a single, secure, backed up file.

This Sounds Like Big Data

Not necessarily: big data refers to extremely large data sets that are best stored and analysed on a cloud using big technology, in order to uncover trends, patterns and associations often relating to human behaviour. Of course, if you run a niche restaurant your critical master data might be limited to a few recipes and the books you do not care to show your accountant.

The distinction is largely a question of size: think of your master data as the subset of big data that you already have your mind around. According to John Case of IBM this is probably already in a structured format and available to share. He goes on to present a cogent case for using this as a peg point around which to systematise the rest. This is because the average organisation already has master data recording customers? and prospects? behaviour.

Do I Still Need My Master Data?

Yes you do, because real people created it with the benefit of human insight. Retain it as a separate set. Then compare it with the results of big data processing for even richer insights. Two heads are better that one and that goes for data processing too.

Trends in CRM Big Data

Adding data via location-aware devices like smartphones and tablets is adding a new dimension to customer information. We now know where they were when they made the enquiry or punched in the information. Use this geo-location data to hone the way you interact with customers and service their accounts. Do not phone a customer who makes decisions at work when they are at home.

Does My Master Data Belong on a Cloud?

There are a number of ?ifs? to consider. How comfortable are you with your service provider. What would happen if someone hacked their server? There are many advantages to cloud technology. Denizon knows of solutions you can rely on, and makes sure its clients have contingency plans to protect them at all times.

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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.

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