Why Spreadsheets can send the Pillars of Solvency II Crashing Down
Solvency II is now fast approaching and while it may provide added protection to policy holders, its impact on the insurance industry is not all a bed of roses. Expect insurance companies to restructure, increase manpower, and raise spending on actuarial operations and risk management initiatives. Those that cannot, will have to go. But what have spreadsheets got to do with all these?
Well, spreadsheets aren’t really the main casts in this blockbuster of a regulatory exercise but they certainly have a significant supporting role to play. Pillar I of Solvency II, which calls for improved supervision on internal control, risk management, and corporate governance, and Pillar II, which tackles supervisory reporting and public disclosure of financial and other relevant information, both affect systems that have high-reliance on spreadsheets.
A little background about spreadsheets might help.
Who needs an IT solution when you can have spreadsheets?
Everyone in any organisation just love spreadsheets; from the office clerk to the CEO. Because they’re so easy to use (not to mention they’re a staple in office computers), people employ them for processing numbers and as an all-around tool for planning, forecasting, reporting, complex modelling, market data analysis, and so on. They make such tasks faster and easier. Really?
You probably haven’t heard of spreadsheet hell
Unfortunately, spreadsheets do have certain shortcomings. Due to their inherent structure and lack of controls, it is so easy to commit simple errors like an accidental copy paste, an omission of a negative sign, an incorrect data input, or an unintentional deletion. Such shortcomings may seem harmless until your shareholders discover a multi-million discrepancy in your financial report.
And because spreadsheet errors can go undetected for a long time, they are constant targets of fraudsters. In other words, spreadsheets are high risk applications.
Solvency II Impact on Spreadsheet-based Financial and IT Systems
Regulations like Solvency II, are aimed at reducing risks to manageable levels. Basically, Solvency II is a risk-based system wherein a company?s capital requirements will depend on its measured riskiness. If companies want to avoid facing onerous capital requirements, they have to comply.
The three pillars of Solvency II have to be in place. Now, since spreadsheets (also known as User Developed Applications or UDAs) are high-risk applications with weak control features and prone to produce inaccurate reports, companies will have a lot of work to do to establish Pillars II and III.
There are at least 8 articles that impact spreadsheets in the directive. Article 82, for example, which requires firms to ensure a high level of data quality and accuracy, strikes at the very core of spreadsheets? weakness.
A whitepaper by Raymond Panko entitled ?Spreadsheets and Sarbanes-Oxley: Regulations, Risks, and Control Frameworks? mentioned that 94% of audited real world operational spreadsheets that were included in his study were found to have errors and that an average of 5.2% of all cells in the audited spreadsheets had errors.
Furthermore, many articles in the directive call for the enforcement of better documentation. This is one thing that’s very tedious and almost unrealistic to do with spreadsheets because just about anyone uses them. Besides, with different ‘versions? of the same data existing in different workstations throughout the organisation, it would be extremely difficult to keep track of them all.
Because of spreadsheets you now need an IT solution
It is clear that, with the growing number of regulations and the mounting complexity of tasks needed for compliance, spreadsheets no longer belong in this era. What you need is a server-based solution that allows for seamless collaboration, data reliability, data consistency, increased security, automatic consolidation, and all the other features that make regulation compliance more doable.
One important ingredient for achieving Solvency II compliance is sound data risk management. Sad to say, the ubiquitous spreadsheet will only expose your data to more risks.
The European Union?s General Data Protection Act (GDPR) is a new data authority coming into force on 25 May 2018. It replaces the current Data Protection Directive 95/46/EC, while extending the remit to include the export of personal data outside the EU. It aims to give EU citizens and residents living there more control over their personal information. It also hopes to make regulatory compliance simpler for participating businesses.
The Broad Implications for Business
The GDPR puts another layer of accountability on businesses falling within its remit. It requires them to implement ?comprehensive but proportionate governance measures? including recording how they make decisions. The long-term goal is to reduce privacy infringements. In the short run, businesses without good governance may find themselves writing new policies and procedures.
Article 5 of the European Union?s General Data Protection Act lays down the following guidelines for managing personal data. This shall be ?
? Processed transparently, fairly, and lawfully
? Acquired for specific, legitimate purposes only
? Adequate, relevant and limited to essentials
? Not used for any other, incompatible purpose
? However it may be archived in the public interest
? Kept up to date with all inaccuracies corrected
? Ring-fenced when the information becomes irrelevant
? Adequately protected against unauthorised access
? Stored in a way that prevents accidental loss
Furthermore, affected businesses shall appoint a ?controller responsible for, and able to demonstrate, compliance with the principles.?
Implementing Accountability and Governance
The UK Information Commissioner?s Office has issued guidelines regarding provisions to assure governance and accountability. These are along the lines of the ?don’t tell me, show me? management approach the office has generally been following. In summary form, a business, and its controller must:
? Implement measures that assist it to ensure demonstrated compliance
? Maintain suitable, relevant records of personal data processing activities
? Appoint a dedicated data protection officer if scale makes this appropriate
? Implement technologies that ensure data protection by design
? Conduct data protection assessments and respond to results timeously
Implementing the General Data Protection Act in Ireland
The Irish Data Protection Commissioner has decided it is unnecessary to incorporate the GDPR into Irish law, since EU regulations have direct effect. The office of the Commissioner is working in tandem with data practitioners, and industry and professional bodies to raise awareness in business through 2017. It has produced a document detailing what it considers the essentials for business compliance. Briefly, these pre-requisites are:
? Ensure awareness among key personnel, and make sure they incorporate the GDPR into their planning
? Conduct an early assessment of quality management gaps, and budget for additional resources needed
? Do an audit of personal data held, to determine the origin, the necessity to hold it, and with whom shared
? Inform internal and external stakeholders of the current status, and your future plans to implement the GDPR
? Examine current procedures in the light of the new directive. Could you ?survive? a challenge from a data subject?
? Determine how you will process requests for access to the data in the future from within and outside your organization
? Assess how you currently obtain customer consent to store their data. Is this “freely given, specific, informed and unambiguous”?
? Find how you handle information from underage people. Do you have systems to verify ages and obtain guardian consent?
? Implement procedures to detect, investigate, and report data breaches to the Data Protection Commissioner within 72 hours
? Implement a culture of always assessing the effect on individual privacy before starting new initiatives
So Is the GDPR Good or Bad for Business
The GDPR should be good news for business customers. Their personal data will be more secure, and they should see their rate of spam marketing come down. The GDPR is also good news for businesses currently investing resources to protect their clients? interests. It could however, be bad news for businesses that have not been focussing on these matters. They may have a high mountain to climb to come in line with the GDPR.
Disclaimer: This article is for information only and not intended as a comprehensive guide.
This is the final chapter in our series of short posts summarising the quite complex ESOS guidelines (click on ?Comply with ESOS? to see the details). This one addresses the legalities to follow to complete your report – and how to appeal if you are not happy with any of the Environment Agency?s decisions.
Director Sign-Off
This is by no means an easy ride. Confirmation of the work at individual or lead assessor level locks the company into the penalty cycle in the event there are significant irregularities. By signing off the assessment, the board level director(s) # agree that they have
Reviewed the enterprise?s ESOS recommendations
Believe the enterprise is within the scope of the scheme
Believe the enterprise is compliant with the scheme
Believe the information provided is correct
Having an internal assessor requires a second board-level signature.
Compliance
You report compliance on the internet. This is free and you can do it at any time within the deadline. You can dip in and out of the process as many times as you wish, but must use the link in the receipting email. While this is something a board member must do, there is no reason why the lead assessor should not complete the basics. The online compliance notification addresses the following topics:
The ESOS contact person in the enterprise
Any aggregation / dis-aggregation during the period
The names and contact details of the lead assessor
The proportion of energy consumption per compliance route
The Environment Agency will acknowledge receipt. This does not constitute acceptance. You should keep the ESOS evidence pack in a safe place with at least one backup elsewhere.
Compliance & Enforcement Issues
In the event the Environment Agency decides your enterprise has not met ESOS requirements, it may either (a) issue a compliance notice with instructions, or (b) apply one of the following civil penalties:
A fine of up to ?5,000 for failure to maintain records
A fine of up to ?50,000 for failure to undertake an energy audit
A fine of up to ?50,000 for a false or misleading statement
Any enterprise has the right of appeal against government decisions. In the case of ESOS, this is via:
The First-Tier Tribunal if your enterprise is England, Wales or off-shore based
The Scottish Minister if your enterprise is based in Scotland
The Planning Commission if your enterprise is Northern Ireland-based
The notice you appeal against will supply details of the appeal steps to take.
This blog and its companion chapters concerning the ESOS Guidelines as amended 2015 are with compliments of ecoVaro. We are the people who break ESOS data into manageable chunks of information, so that board-level directors have greater confidence in what they sign.
For many people within the UK, water is not really something to worry about. Surely enough of it falls out the sky throughout the year that it does feel highly unlikely that we?ll ever run out of it. There certainly does seem to be an abundance of Branded Water available in plastic bottles on our supermarket shelves.
Water, water, every where, And all the boards did shrink; Water, water, every where, Nor any drop to drink.
Despite this, Once-unthinkable water crises are becoming commonplace. If you consider that In England and Wales, we use 16 billion litres of clean drinking water every day ? that’s equivalent to 6,400 Olympic sized swimming pools.
Currently, water companies can provide slightly more than we need ? 2 billion litres are available above and beyond what we’re using. In some areas, though, such as south east England, there is no surplus and, as such, these regions are more likely to face supply restrictions in a dry year.
If we take little moment to reflect on some of the most notable water related stories over the past few years, we’ll start to get a picture of just how real the potential and the threat of water shortages can be.
Reservoirs in Chennai, India?s sixth-largest city, are nearly dry right now. Last year, residents of Cape Town, South Africa narrowly avoided their own Day Zero water shut-off.
It was only year before that, Rome rationed water to conserve scarce resources.
Climate change is likely to mean higher temperatures which may drive up the demand for water (alongside population growth) and increase evaporation from reservoirs and water courses during spring and summer.
The impact of climate change on total rainfall is uncertain, but the rain that does fall is likely to arrive in heavier bursts in winter and summer. Heavier rain tends to flow off land more quickly into rivers and out to sea, rather than recharging groundwater aquifers.
A greater chance of prolonged dry periods is also conceivable. This combined with the harsh reality that no human population can sustain itself without sufficient access to fresh water.
If present conditions continue, 2 out of 3 people on Earth will live within a water-stressed zone by 2025
What is water stress?
Water stress is a term used to describe situation when demand for water is greater than the amount of water available at a certain period in time, and also when water is of poor quality and this restricts its usage. Water stress means deterioration in both the quantity of available water and the quality of available water due to factors affecting available water.
Water stress refers to the ability, or lack thereof, to meet human and ecological demand for water. Compared to scarcity, water stress is a more inclusive and broader concept.
Water Stress considers several physical aspects related to water resources, including water scarcity, but also water quality, environmental flows, and the accessibility of water.
Supply and Demand
Major factors involved when water scarcity strikes is when a growing populations demand for water exceeds the areas ability to service that need.
Increased food production and development programs also lead to increased demand for water, which ultimately leads to water stress.
Increased need for agricultural irrigation in order to produce more crops or sustain livestock are major contributors to localised water stress.
Overconsumption
The demand for water in a given population is fairly unpredictable. Primarily, based on the fact that you can never accurately predict human behaviour and changes in climate.
If too many people are consuming more water than they need because they mistakenly believe that water is freely available and plentiful, then water stress could eventually occur.
This is also linked to perceived economic prosperity of a give region. Manufacturing demand for water can have huge impact regardless whether water is actively used within the manufacturing process or not.
Water Quality
Water quality in any given area is never static. Water stress could happen as a result of rising pollution levels having a direct impact on water quality.
Water contamination happens when new industries either knowingly or unknowingly contaminate water with their industrial practices.
Largely, this can happen and frequently does so because these industries do not take effective control of monitoring and managing their impact on communal water supplies. Incorrectly assuming this is the responsibility of an additional third party like the regional water company.
The truth is, water quality and careful monitoring of it is all of our responsibility.
Water Scarcity
Simple increases in demand for water can in itself contribute to water scarcity. However, these are often preceded by other factors like poverty or just the natural scarcity of water in the area.
In many instances, the initial locations of towns or cities were not influenced by the close proximity of natural resources like water, but rather in pursuit of the extraction of other resources like Gold, Coal or Diamonds.
For Instance, Johannesburg, South Africa is the largest City in South Africa and is one of the 50 largest urban areas in the world. It is also located in the mineral rich Witwatersrand range of hills and is the centre of large-scale gold and diamond trade.
Johannesburg is also one of the only major cities of the world that was not built on a river or harbour. However, it does have streams that contribute to two of Southern Africas mightiest rivers – Limpopo and the Orange rivers. However, most of the springs from which many of these streams emanate are now covered in concrete!
Water Stress and Agriculture
Peter Buss, co-founder of Sentek Technology calls ground moisture a water bank and manufactures ground sensors to interrogate it. His hometown of Adelaide is in one of the driest states in Australia. This makes monitoring soil water even more critical, if agriculture is to continue. Sentek has been helping farmers deliver optimum amounts of water since 1992.
The analogy of a water bank is interesting. Agriculturists must ?bank? water for less-than-rainy days instead of squeezing the last drop. They need a stream of real-time data and utilize cloud-based storage and processing power to curate it.
Sentek?s technology can be found in remote places like Peru?s Atacamba desert and the mountains of Mongolia, where it supports sustainable floriculture, forestry, horticulture, pastures, row crops and viticulture through precise delivery of scarce water.
This relies on precision measurement using a variety of drill and drop probes with sensors fixed at 4? / 10cm increments along multiples of 12? / 30cm up to 4 times. These probe soil moisture, soil temperature and soil salinity, and are readily repositioned to other locations as crops rotate.
Peter Buss is convinced that measurement is a means to an end and only the beginning. ?Too often, growers start watering when plants don’t really need it, wasting water, energy, and labour. By accurately monitoring water can be saved until when the plant really needs it.
Peter also emphasises that crop is the ultimate sensor, and that ?we should ask the plant what it needs?.
This takes the debate a stage further. Water wise farmers should plant water-wise crops, not try to close the stable door after the horse has bolted and dry years return.
The South Australia government thinks the answer also lies in correct farm dam management. It wants farmers to build ones that allow sufficient water to bypass in order to sustain the natural environment too.
There is more to water management than squeezing the last drop. Soil moisture goes beyond measuring for profit. It is about farming sustainably using data from sensors to guide us.
Ecovaro is ahead of the curve as we explore imaginative ways to exploit the data these provide for the common good of all.
A Quarter of the World?s Population, Face High Water Stress
Data from WRI?s Aqueduct tools reveal that 17 countries? home to one-quarter of the world?s population?face ?extremely high? levels of baseline water stress, where irrigated agriculture, industries and municipalities withdraw more than 80% of their available supply on average every year.
Water stress poses serious threats to human lives, livelihoods and business stability. It’s poised to worsen unless countries act: Population growth, socioeconomic development and urbanization are increasing water demands, while climate change can make precipitation and demand more variable.
How to manage water stress
Water stress is just one dimension of water security. However, like any challenge, its outlook depends on adequate monitoring and management of environmental data.
Even countries with relatively high water stress have effectively secured their water supplies through proper management by leveraging the knowledge they have garnered by learning from the data they gathered.
3 ways to help reduce water stress
In any geography, water stress can be reduced by measures ranging from common sense to innovative technology solutions.
There are countless solutions, but here are three of the most straightforward:
1. Increase agricultural efficiency: The world needs to make every drop of water go further in its food systems. Farmers can use seeds that require less water and improve their irrigation techniques by using precision watering rather than flooding their fields.
Businesses need to increase investments to improve water productivity, while engineers develop technologies that improve efficiency in agriculture.
2. Invest in grey and green infrastructure: D Data produced by Aqueduct Alliance – shows that water stress can vary tremendously over the year. WRI and the World Bank?s researchshows that built infrastructure (like pipes and treatment plants) and green infrastructure (like wetlands and healthy watersheds) can work in tandem to tackle issues of both water supply and water quality.
3. Treat, reuse and recycle: We need to stop thinking of wastewater as waste.
Treating and reusing it creates a ?new? water source.
There are also useful resources in wastewater that can be harvested to help lower water treatment costs. For example, plants in Xiangyang, China and Washington, D.C. reuse or sell the energy- and nutrient-rich byproducts captured during wastewater treatment.
Summary
The data is undeniably clear, there are very worrying trends in water.
Businesses and other other organisations need to start taking action now and investing in better monitoring and management, we can solve water issues for the good of people, economies and the planet. We collectively cannot kick this can down the road any further, or assume that this problem will be solved by others.
It is time, for a collective sense of responsibility and for everyone to invest in future prosperity of our Planet as a collective whole. Ecological preservation should be at the forefront of all business plans because at the end of the day profit is meaningless without an environment to enjoy it in!
