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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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

2015 – What’s ahead for UK Business?

According to reports just in, the global environment industry is down. Less money is available for what some CEO?s still see as grudge expenditure, and many U.S. agencies are seeking soft budget cuts. The UK is proving to be an exception following the announcement of ESOS, and EcoVaro does not expect the May elections will have much impact in this regard.

ESOS calls for mandatory energy assessments in companies above a certain size, and requires specific proposals to cut consumption. There is no indication of compulsory follow-through, although it is clear the Environment Agency hopes rising electricity prices and the prospect of monetary savings will do the trick.

It is an open question whether the Tory government would have interfered with commerce to this extent, were it not for the European directive that enforced it. The overall goal is to cut EU energy consumption across the board by 20% by 2020. Energy consultants are rubbing their hands in glee. EcoVaro?s response is to provide cloud-based software.

We will be interested to see how many UK companies make the first deadline of 5 December 2015, in the light of reports that half the 9,000 firms affected appear not to even know that ESOS exists. Some will no doubt pay last-minute lip service. Those with an eye on their own sustainability will grasp the Energy Saving Opportunity Scheme with both hands.

The initial ESOS deadline was always going to be a challenge. Some big corporates have stolen a march albeit egged on by green stakeholders. The next challenge comes in June 2015 with the implementation of the European Union?s ?Waste Catalogue? of hazardous substances, and rules for their disposal. We hope a new ISO 14001 will arrive soon and pull the loose threads together.

The introduction of carbon trading late this year brings further opportunities to increase profits through wise stewardship. Auditable metrics are essential for this.

EcoVaro can assist by processing your raw data. We provide this service on a virtual cloud. In return, you can get advice on optimising the quality of your graphs for presentations. 

Operational Efficiency Initiatives

When was the last time you checked your technology spending against your IT infrastructure’s contribution to the bottom line?

Chances are, what’s happening underneath all those automated processes, expensive hardware, and fancy graphical user interfaces is not doing your bottom line any good.

If you don’t keep a watchful eye, your IT operations can easily nurture a lot of wastage and unnecessary costs. Underutilised servers, duplicate processes, poorly managed bandwidths, and too much complexity are among the common culprits.

For minor problems, we can eliminate wastage by setting up some technology enhancements, instilling best practices, and performing a few tweaks. However, if you’re not adequately trained on how to go about with it, your band-aid solutions can add more complexity to the mix.

Of course, there will always come a time when you will have to spend on new technologies to maintain the overall efficiency of your IT infrastructure. Whether you intend to purchase new hardware or software applications or build an entirely new infrastructure, the sheer cost of such undertakings warrants seeking expert advice.

Failure to do so can result in fragmented resources lacking in cohesiveness, which don’t contribute to efficiency at all.

Our solutions for improving operational efficiencies cover the entire spectrum: from planning what to buy, optimising what you’ve already bought, to making your team comfortable with them all. Please find time to view our solutions below and uncover ways to drive those profits up even as you work within your budget.

 

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