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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Spreadsheet Woes – Limited features for easy adoption of a control framework


Spreadsheet woes – Burden in SOX Compliance and other Regulations


Spreadsheet Risk Issues


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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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A Small External Enterprise Development Team is Cheaper than Your Own

Time is money in the application development business. We have to get to market sooner so someone else does not gazump us, and pip us at the post. We increase the likelihood of this with every delay. Moreover, the longer your in-house team takes to get you through the swamp, the higher the project cost to you.

Of course, in theory this should not be the case. Why bring in a team from outside, and pay more to support their corporate structure? Even going for a contract micro team ought not to make financial sense, because we have to fund their mark-up and their profit taking. Our common sense tells us that this is crazy. But, hold that thought for a minute. What would you say if a small external enterprise development team was actually cheaper? To achieve that, they would have to work faster too.

The costs of an Enterprise Internal Development Team

Even if you were able to keep your own team fully occupied ? which is unlikely in the long term ? having your own digital talent pool works out expensive when you factor in the total cost. Your difficulties begin with the hiring process, especially if you do not fully understand the project topic, and have to subcontract the hiring task.

If you decide to attempt this yourself, your learning curve could push out the project completion date. Whichever way you decide to go, you are up for paying advertising, orientation training, technical upskilling, travel expenses, and salaries all of which are going to rob your time. Moreover, a wrong recruitment decision would cost three times the new employee?s annual salary, and there is no sign of that changing.

But that is not all, not all by far. If want your in-house team to keep their work files in the office, then you are going to have to buy them laptops, plus extra screens so they can keep track of what they are doing. Those laptops are going to need desks, and those employees, chairs to sit in. Plus, you are going to need expensive workspace with good security for your team?s base.

If we really wanted to lay it on, we would add software / cloud costs, telephony, internet access, and ongoing technical training to the growing pile. We did a quick scan on PayScale. The median salary of a computer programmer in Ireland is ?38,000 per year and that is just the beginning. If you need a program manager for your computer software, their salary will be almost double that at ?65,000 annually.

Advantages of R&D outsourcing

The case for a small externally sourced enterprise development team revolves around the opportunity cost ? or loss to put in bluntly ? of hiring your own specialist staff for projects. If you own a smaller business with up to 100 people, you are going to have to find work for idle digital fingers, after you roll out your in-house enterprise project. If you do not, you head down the road towards owning a dysfunctional team lacking a core, shared objective to drive them forward.

Compared to this potential extravagance, hiring a small external enterprise development team on an as-needed basis makes far more sense. Using a good service provider as a ?convenience store? drives enterprise development costs down through the floor, relative to having your own permanent team. Moreover, the major savings that arise are in your hands and free to deploy as opportunities arise. A successful business is quick and nimble, with cash flow on tap for R & D.

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.

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