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.

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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Saving Energy Step 3 ? Towards a Variable Energy Bill

Do you remember the days when energy was so cheap we paid the bill almost without thinking about it? Things have changed and we have the additional duty of reducing consumption to help save the planet. This is the third article in our mini-series on saving energy. It follows on from the first that explored implementing a management system, and the second listing practical things to implement on the shop floor. These open up the possibility of the variable energy bill we expand on as follows.

If ?variable energy bill? sounds strange to you, I used the unusual turn of phrase to encourage you to view things in a different light. We need to move on from the ?pie chart? mentality where we focus on the biggest numbers like materials, facilities and labour, and zoom in on energy where we can achieve similar gains faster with less pain. But first, we need to see beyond the jargon that governments and consultants love, and get to grips with the reality that we can vary our energy bill and bring cost down.

As executives we recognise this, although other pressures distract us from accepting it as a personal goal. And so we delegate it down the organisation to a level where it becomes ?another crazy management idea? we have to follow to stay out of trouble. I read somewhere that half the world?s organisations do not have energy as a defined objective to monitor in the C Suite. No wonder commerce is only pecking away at energy wastage at a rate of 1% per year.

Find out where you are ?spending energy? and relate this to your core business. If there are places where you are unable to make a connection, challenge the activity?s right to exist. Following the energy trail produces unexpected benefits because it permeates everything we do.

  • Improved product design reducing time spent in factory
  • Streamlined production schedules reducing machine run times
  • Less wear on equipment reducing costly maintenance
  • A more motivated workforce that is prouder of ?what we do?

As you achieve energy savings you can pass these on in terms of lower prices and greater market share. All this and more is possible when you focus on the variables behind your energy bill. Run the numbers. It deserves more attention than it often gets.

Are Master Data Management and Hadoop a Good Match?

Master Data is the critical electronic information about the company we cannot afford to lose. Accordingly, we should sanitise it, look after it, and store it safely in several separate places that are independent of each other. The advent of Big Data introduced the current era of huge repositories ?in the clouds?. They are not, of course but at least they are remote. This short article includes a discussion about Hadoop, and whether this is a good platform to back up your Master Data.

About Hadoop

Hadoop is an open-source Apache software framework built on the assumption that hardware failure is so common that backups are unavoidable. It comprises a storage area and a management part that distributes the data to smaller nodes where it processes faster and more efficiently. Prominent users include Yahoo! and Facebook. In fact more than half Fortune 50 companies were using Hadoop in 2013.

Hadoop – initially launched in December 2011 ? has survived its baptism of fire and became a respected, reliable option. But is this something the average business owner can tackle on their own? Bear in mind that open source software generally comes with little implementation support from the vendor.

The Hadoop Strong Suite

  • Free to download, use and contribute to
  • Everything you need ?in the box? to get started
  • Distributed across multiple fire-walled computers
  • Fast processing of data held in efficient cluster nodes
  • Massive scaleable storage you are unlikely to run out of

Practical Constraints

There is more to Hadoop than writing to WordPress. The most straightforward solutions are uploading using Java commands, obtaining an interface mechanism, or using third party vendor connectors such as ACCESS or SAS. The system does not replace the need for IT support, although it is cheap and exceptionally powerful.

The Not-Free Safer Option

Smaller companies without in-depth in-house support are wise to engage with a technical intermediary. There are companies providing commercial implementations followed by support. Microsoft, Amazon and Google among others all have commercial versions in their catalogues, and support teams at the end of the line.

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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