Spreadsheet Woes – Limited Features For Easy Adoption of a Control Framework

Like it or not, regulations are here to stay and for a company to comply with them, its IT and financial systems will have to be equipped with a suitable control framework. One common stumbling block to such an implementation is a company?s over-reliance on spreadsheets.

Why is it so difficult to adopt controls for a system that’s reliant on spreadsheets? To understand this, let’s pinpoint some of the strongest, most powerful attributes of these User Developed Applications (UDA).

By nature, spreadsheets are the epitome of simplicity: easy to develop, easily accessible and easily altered. All computers in your workplace will most likely have them and everyone in your organization may be sharing them, making their own versions, and storing them in personal folders.

Sad to say though, these strengths are also control weaknesses and constitute the very reasons why spreadsheets require effective risk management.

Easy to develop. Being easy to develop, most spreadsheet systems are created by non-IT users who have limited knowledge on best control practices. Being constantly under time pressure, these ?developers? may also relegate documentation, security, and data verification to the back burner in favour of coming up with a timely report.

Easy to access. Information in a spreadsheet can be opened by practically anyone within the organization?s network. Who accessed what? And when? If anything goes wrong, it would be difficult to identify the culprit, and the failure to pinpoint responsibility for erroneous data could lead to bigger, more costly mistakes.

Easy to alter. Lastly, if the information is easy to access, then it can also be easily altered, consequently making reports more prone to both accidental errors and fraudulent modifications.

The rise of multimillion dollar scandals due to accidental and intentional spreadsheet errors have prompted regulatory bodies to publish guidelines for mitigating spreadsheet-associated risks. These controls include:

Change control
Version control
Access control
Input
Security and data integrity
Documentation
Development life cycle
Backup and archiving
Logic inspection/Testing
Segregation of duties/roles, and procedures
Analytics

In theory, these controls should be able to bring down risks considerably. However, because of the inherent nature of spreadsheets, such controls are rarely implemented effectively in the real world.

Take for example Security and Data Integrity. One of the most common causes of spreadsheet error is due to ?hardwiring?. This happens when values are inadvertently entered into a formula cell, naturally changing the logic of the spreadsheet.

As a way of control, cell locking can be applied on the formula cells to prevent users without the proper authority from making any changes. However, when reporting deadlines approach drawing spreadsheets to the forefront of data processing, more people are given access rights to the locked cells. Ironically, it is during these crunch times, when errors are most likely to happen.

Because the built-in features of a spreadsheet support none of the controls mentioned above, some companies are tempted to purchase control-enabling programs for spreadsheets just to continue using them for financial reporting. But although these programs can integrate the required controls, you?d still be interacting with the same complex and outdated interface: the spreadsheets.

Thus, these band-aid solutions may not suffice because the root cause of these problems are the spreadsheets themselves.

Learn more about our server application solutions and discover a better way to implement controls.

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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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Data Leakage Prevention – Protecting Sensitive Information

When DuPont lost $400 million in intellectual property, it wasn’t because a hacker from the other side of the world infiltrated their system. The information was simply stolen by a former employee. Alarmingly, data loss incidents are not always caused by deliberate actions.

A file containing personal information accidentally attached to an email and sent to multiple recipients; financial data stored in a USB pen drive, accidentally left in a restaurant; or bank account data of colleagues, inadvertently posted on a company website – these are also some of the everyday causes of data loss.

A report done by research company Infowatch regarding global data leaks in 2010 showed that there were actually more accidental data leaks in that year compared to intentional ones. Accidental leaks comprised 53%, while intentional leaks comprised 42% (the rest were unidentified).

But even if they ?only? happened accidentally, breach incidents like these can still be very costly. The tens of thousands of dollars that you could sometimes end up paying in civil penalties (as in the case when you lose other people?s personal information) can just be the beginning. More costly than this is the loss of customer and investor confidence. Once you lose those, you could consequently lose a considerable portion of your business.

Confidential information that may already be leaking out right under your nose

With all the data you collect, process, exchange, and store electronically every day, your IT system has surely now become a storehouse of sensitive information. Some of them, you may be even taking for granted.

But imagine what would happen if any of the following trade secrets fell into the wrong hands: marketing plans, confidential customer information, pricing data, product development strategies, business plans, supplier information, source codes, and employee salaries.

These are not the only kind of data that you should be worried about. You could also get into trouble if your sloppy IT security fails to protect employee or client personal information such as their names; social security numbers; drivers license numbers; or bank account numbers and credit/debit card numbers along with their corresponding PINs.

In some countries, you could face onerous data breach notification requirements and heavy fines when these kind of data are involved.

There are now more holes to plug

It’s not just the different varieties of sensitive electronic information that you have to worry about. Because these data can take on different forms, i.e. data-at-rest, data-in-motion, and data-at-the-endpoints, you also need to take aim at different areas in your IT system.

Sensitive information can be found ?at rest? in each of your employees? hard disks, in your servers, storage disks, and in off-site backup disks. They can also be found ?in motion? in email, instant messaging, social networking messaging, P2P file sharing, ftp, http, and so on.

That’s not all. Your highly mobile workforce may have already introduced yet another high-risk area into your system: data-at-the-endpoints. This includes USB flash-disks, laptops, portable hard disks, CDs, and even smartphones.

The main challenge of data leak prevention

Having been made aware of the various aspects of data leakage, have you already come to grips with the extent of the task at hand?

There are two major things you need to do here to prevent data leakage.

One, you need to identify what data you have that can be considered as sensitive/confidential information. Of course you have financial information and employee salaries in your files. But do you also store personally identifiable information? Do you have trade secrets that are stored in electronic form?

Two, you need to pinpoint their locations. Are they only on your hard disks and laptops? Or have they made their way to flash drives, CDs/DVDs, or portable HDDs? Are they being transmitted through email or any other file transfer media?

The reason why you need to know what your sensitive data are as well as where they are is because you would like all efforts of securing them to be as efficient and unobtrusive as possible.

Let’s say, as a way of protecting your data, you decide to implement encryption. Since encryption can consume a lot of storage space and significantly reduce performance, it may be impractical to encrypt your entire database or all your files. For the same reason, you wouldn’t want to encrypt every single email that you send.

Thus, the best way would be to encrypt only the data that really need encryption. But again, you need to know what data needs to be encrypted and where those data can be found. That alone is no simple task.

Not only will you need to deal with the data you already have, you will also have to worry about the data that will go through your systems during the course of your day-to-day transactions.

Identifying sensitive data as it enters or leaves your system, goes through your network, or gets stored in your file system or database, and then applying the necessary security actions should be done automatically and intelligently. Otherwise, you could end up spending on a lot of man-hours or, worse, wasting them on a lot of false positives and negatives.

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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

Vendor Selection

When shopping for an IT solution for your enterprise, there are two things you should scrutinise: the product (or service) itself and its vendor. Many times, companies overlook the importance of the latter, giving the reason that “it’s only the product we need”.

Wrong.

What about after-sales technical support and training? Ok, so you have an in-house team with the required competency for that IT solution in question… not that I believe it’s reasonable basis to pass up on the expertise that the vendor can provide. How about upgrades, patches, and documentation?

Still unperturbed? Here’s one factor that you may not have started to consider – What happens to your product if the vendor goes bankrupt or gets swallowed by a merger and acquisition? Surely, you no longer believe this is far from possible, do you?

But how are you supposed to know the financial stability of each vendor or whether it is an acquisition target? Well, you can either conduct your own research or you can leave that up to us. Part of our job includes not only establishing linkages in the industry but also being in-the-know on such relevant information.

Evaluation of Business Needs

You can’t separate vendor selection from the process of choosing the desired IT tool. That’s why our vendor selection services starts by defining exactly what your business needs are.

Once we’ve pinned down your needs, we can then narrow down the list of possible IT solutions. Only then can we proceed with the main vendor selection process.

Have you ever been caught in a situation wherein you thought you knew what you wanted, only to end up realising it’s not what you were looking for after all? We’re here to make sure you don’t get caught in that kind of situation when choosing an enterprise-class IT solution.

With the TCO (total cost of ownership) of such solutions typically running up to hundreds of thousands of euros, you can’t afford to arrive at what you really want by way of trial and error.

These are the things you stand to benefit the moment we start working with you:

Thorough assessment of your IT needs. We’ll consult the people in your organisation who’ll be affected the most in order to obtain a clear picture of what your specific needs really are. Most IT solution purchases are made with very little consultation that, after installation, many of the end users don’t benefit at all.
Minimal interruption during assessment. As with all our other services, we see to it that the interruptions we make are absolutely necessary. So the moment we start with our work, you can still continue with yours.
Insightful suggestions of the required IT solution. You still know your business better. So even after we’ve gone through the assessment and given our recommendations, the decision as to what IT tool should be pursued will still be up to you. The difference now is, you’ll be making a decision based on expertly gathered information put forward in an insightful proposal.

Request and Evaluation of Vendor Proposals

With so many IT solutions companies mushrooming, it is becoming more difficult to keep track of them, their specialities, strengths, and weaknesses.

Companies selling best-of-breed products may be relatively easy to spot. But there are also other attributes that are equally important but not as well publicised. For instance, which companies offer better quality management philosophies? Which companies have strategic visions running parallel to yours? Which of them possess implementation capabilities that can cater to your rapidly growing IT requirements?

Vendors who answer positively to these queries need to be given the appropriate importance in the selection process. We see to it that these and other relevant attributes are factored into our scorecards and evaluation processes.

These are the things you can look forward to when you grant us the opportunity to serve you.

Experience is a vital item in our vendor selection criteria. Our vast knowledge of the reliable players in the industry will lead you to experienced vendors who can hit the ground running from day one and continue with the same vigour onward.
We can help you draw positive response for each of your Request For Proposals (RFPs) or Request For Information (RFIs). Did you expect these vendors to be enthusiastic in sending out proposals each time you asked them to? Think again. You’ll have to persuade them first of your sincerity to become a potential customer. With our help, your RFPs will make preferred vendors see “opportunity” written all over.
No need to go “Eany, meeny, miny, moe”. Deciding which vendors should move up in the selection process can take up a lot of time if you don’t know which criterion should be given more weight. Our scorecards are designed to collect the most relevant information and to generate results that will help you decide on these matters at a glance.

Interview, Negotiation, and Monitoring

As soon as you start getting positive response to your Request For Proposals, the interview process should be next. It’s at this point that vendors can present and highlight their strengths while we try to glean as much information of their true capabilities as well as their dedication to the project.

Some companies can provide proof-of-concepts and we may require them as part of the interview process. This will not only give us a better idea as with regards to their product’s capabilities, but also to their level of expertise on the solution in question.

We’ll help you set up the interview process and organise the evaluation committee. Members of the committee will typically include representatives from each department that will be affected by the new technology, which we would have already identified during our Evaluation of Business Needs.
Since our scorecards are designed to expedite the filtering and selection process, you may eventually be able to choose the finalists yourself. However, in the event that two or more vendors turn out evenly matched, we’ll help you identify the better company.
We’re very familiar with the price ranges of various IT solutions, including the effects on price of certain variables. As such, we can tell you whether a product’s price tag is justified or not.
Our exceptional familiarity on both the IT industry and the entire negotiation processes itself will give you the edge when it’s time for us to haggle for the best bang for the buck.
After the contract is awarded, we’ll even be on hand to monitor whether deliverables are handed over and milestones are achieved as promised.