How COBIT helps you achieve SOX Compliance

First released way back in 1996, COBIT has already been around for quite a while. One reason why it never took off was because companies were never compelled to use it ? until now. Today, many CEOs and CIOs are finding it to be a vital tool for achieving SOX compliance in IT.

Thanks to SOX, COBIT (Control Objectives for Information and related Technology) is now one of the most widely accepted source of guidance among companies who have IT integrated with their accounting/financial systems. It has also gained general acceptability with third parties and regulators. But how did this happen?

Role of control frameworks in SOX compliance

You see, the Sarbanes-Oxley Act, despite having clearly manifested the urgency of establishing effective internal controls, does not provide a road map for you to follow nor does it specify a yardstick to help you determine whether an acceptable mileage in the right direction has already been achieved.

In other words, if you were a CIO and you wanted to find guidance on what steps you had to take to achieve compliance, you wouldn’t be able to find the answers in the legislation itself.

That can be a big problem. Two of your main SOX compliance obligations as a CEO or CIO is to assume responsibility in establishing internal controls over financial reporting and to certify their effectiveness. After that, the external auditors are supposed to attest to your assertions. Obviously, there has to be a well-defined basis before you can make such assertions and auditors can attest to anything.

In the language of auditors, this ?well-defined basis? is known as a control framework. Simply put, once you certify the presence of adequate internal controls in your organisation, the external auditor will ask, ?What control framework did you use??

Knowing what control framework you employed will help external auditors determine how to proceed with their evaluations and tests. For your part, a control framework can serve as a guide to help you work towards specific objectives for achieving compliance. Both of you can use it as a common reference point before drawing any conclusions regarding your controls.

But there are many control frameworks out there. What should you use?

How SOX, COSO, and COBIT fit together

Fortunately, despite SOX?s silence regarding control frameworks, you aren’t left entirely to your own devices. You could actually take a hint from the SEC and PCAOB, two of the lead organisations responsible for implementing SOX. SEC and PCAOB point to the adoption of any widely accepted control framework.

In this regard, they both highly endorse COSO, a well-established internal control framework formulated by the Committee of Sponsoring Organisations of the Treadway Commission (COSO). Now, I must tell you, if you’re looking specifically for instructions pertaining to IT controls, you won’t find those in COSO either.

Although COSO is the most established control framework for enterprise governance and risk management you’ll ever find (and in fact, it’s what we recommend for your general accounting processes), it lacks many IT-related details. What is therefore needed for your IT processes is a framework that, in addition to being highly aligned with COSO, also provides more detailed considerations for IT.

This is where COBIT fits the bill.

How COBIT can contribute to your regulatory compliance endeavors

COBIT builds upon and adheres with COSO while providing a finer grain of detail focused on IT. You can even find a mapping between COBIT IT processes and COSO components within the COBIT document itself.

Designed with regulatory compliance in mind, COBIT lays down a clear path for developing policies and good practice for IT control, thus enabling you to bridge the gap between control requirements, technical issues, and business risks.

Some of the components you’ll find in COBIT include:

IT control objectives

These are statements defining specific desired results that, as a whole, characterise a well-managed IT process. They come in two forms for each COBIT-defined IT process: a high-level control objective and a number of detailed control objectives. These objectives will enable you to have a sense of direction by telling you exactly what you need to aim for.

Maturity models

These are used as benchmarks that give you a relative measurement stating where your level of management or control over an IT process or high-level control objective stands. It serves as a basis for setting as-is and to-be positions and enables support for gap analysis, which determines what needs to be done to achieve a chosen level. Basically, if a control objective points you to a direction, then its corresponding maturity model tells you how far in that direction you’ve gone.

RACI charts

These charts tell you who (e.g. CEO, CFO, Head of Operations, Head of IT Administration) should be Responsible, Accountable, Consulted, and Informed for each activity.

Goals and Metrics

These are sets of goals along with the corresponding metrics that allow you to measure against those goals. Goals and metrics are defined in three levels: IT goals and metrics, which define what business expects from IT; process goals and metrics, which define what the IT process should deliver to support It’s objectives; and activity goals and metrics, which measure how well the process is performing.

In addition to those, you’ll also find mappings of each process to the information criteria involved, IT resources that need to be leveraged, and the governance focus areas that are affected.

Everything is presented in a logical and manageable structure, so that you can easily draw connections between IT processes and business goals, which will in turn help you decide what appropriate governance and control is needed. Ultimately, COBIT can equip you with the right tools to maintain a cost-benefit balance as you work towards achieving SOX compliance.

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Spreadsheet Risk Issues

It is interesting to note that the riskiness of operational spreadsheets are overlooked even by companies with high standards of risk management. Only when errors amount to actual losses do they realize that these risks have been staring them in the face all along.

Common spreadsheet risk issues

Susceptibility to trivial manual errors

Due to the fundamental structure of spreadsheets, a slight change in the formula or value in any of their inhabited cells may already affect their overall output. An

  • accidental copy-paste,
  • omission of a negative sign,
  • erroneous range selection,
  • incorrect data input or
  • unintentional deletion of a character,cell, range, column, or row

are just some of the simple errors spreadsheet users frequently encounter. Rarely are there any counter-checking controls in place in a spreadsheet-based activity and manual errors therefore easily go undetected.

Possibility of the user working on the wrong version

How do you store spreadsheet files?

Since the most common reports are usually generated on a monthly basis, users tend to store them using variations of these two configurations:

spreadsheet storage

If you notice, a user can accidentally work on the wrong version with any of these structures.

Prone to inconsistent company-wide reporting

This happens when a summary or ?final? spreadsheet is fed information by different departments coming from their own spreadsheets. Even if most of the data in their spreadsheets come from one source (the company-wide database), erroneous copy-pasting and linking, or even different interpretations of the same data can result to contradicting information in the end.

Often defenceless against unauthorised access

Some spreadsheets contain information needed by various individuals or department units in an organisation. Hence, they are often shared via email or through shared folders in a network. Now, because spreadsheets don’t normally use any access control, any user can easily open a spreadsheet file and view or modify the contents as he wishes.

Highly vulnerable to fraud

A complex spreadsheet system with zero or very minimal controls provides the perfect setting for would-be fraudsters. Hidden cells with malicious formulas and links to bogus information can go unnoticed for a long time especially if the final figures don’t deviate much from expected values.

Spreadsheet risk mitigation solutions may not suffice

Inherent complexity makes testing and logic inspection very time consuming

Deep testing can uncover possible errors hidden in spreadsheet cells and consequently mitigate risks. But spreadsheets used to support financial reporting are normally large, complex, highly-personalised and, without ample supporting documentation, understandably hard to follow.

No clear ownership of risk management responsibilities

There?s always a dilemma when an organisation starts assigning risk management responsibilities for spreadsheets. IT personnel believe users in the business side of the organisation should be responsible since they are the ones who create, edit, store, duplicate, and share the spreadsheet files. On the other hand, users believe IT should be responsible since they have always been in-charge of managing IT infrastructure, applications, and files.

To get rid of spreadsheet risks, you’ll have to get rid of spreadsheets altogether

One remedy is to have a risk management activity that involves both IT personnel and spreadsheet users. But wouldn’t you want to get rid of the complexity of having to distribute the responsibilities between the two parties instead of just one?

Learn more about Denizon’s server application solutions and how you can get rid of spreadsheet risk issues.

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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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What is Business Intelligence?

How well do you know your customers? That is, can you actually pinpoint which among them are you most profitable with and which are making you spend more? Are you content with the accuracy of your forecasts and market predictions? Do you feel you’re spending more on legal costs and regulatory compliance than you should?

Your IT department may be handling these concerns pretty well but perhaps you’d like to know how you can further improve things.

What we’ve got is an IT solution wrapped in a fancy name called ‘Business Intelligence’ or BI. If you think that’s too strong a term, we invite you to read more below, then you be the judge.

Dashboards – Determine the health of your business at a glance

Most drivers rarely make use of their car’s dashboard. After all, you can still reach your destination by just using the steering wheel, pedals, gear stick and so on. But that’s not exactly the most efficient way to drive, right?

If you want to save on fuel, you’ll want to glance on the RPM and speedometer from time to time. You might also want to utilise the trip meter to determine which route is the shortest to a given destination. Other dashboard components like the fuel gauge, tire pressure gauge, engine temperature indicator, and volt meter can likewise provide information about your car’s health.

The same concept applies to business management. If you want to run your business intelligently, you can make use of BI dashboards. These are tools in a typical business intelligence package that will allow you to determine the health of your business via a set of smartly configured gauges and other intuitive graphical representations.

So that, literally, at a mere glance, you’ll already know whether various units in your company are working efficiently. A dashboard will also give you instant feedback of the strategies you’ve recently implemented; to let you know if things are working as planned.

If you want more information than a dashboard can provide, our BI packages also include highly customised reports.

Reports that help you decide faster

Dashboards are great for getting valuable information at a glance but they won’t tell you everything. For more details, you’ll need to view highly customised reports. Our reports are tailor made for each user. We see to it that, by default, each person gets the information he needs the most.

If you belong to the sales department, you normally won’t need a presentation of the data that is appropriate for people in accounting. That way, you don’t spend time filtering. Instead, you and your people can move on to making well-informed decisions.

Our BI systems make use of your vast collection of data to provide reports that will organise your regulatory requirements and call your attention to approaching deadlines. The same system will provide the right information for your people on the field. If your team members are equipped with smart phones and Pocket PCs, they can retrieve whatever it is they need to know to close deals, make sales, and serve clients faster than the competition.

Generating logical information from disparate sources of data scattered over an enterprise-wide organisation is no easy task. But we’ll make it look simple. That’s because we’ve got the expertise to bring it all together into a robust data warehouse and to extract them in the form of reports and dashboards through OLAP.

OLAP and Data Warehousing – Powering the generation of actionable information

Want to know how to generate reports with the highest degree of accuracy and reliability? In theory, what you need is a single repository or a data warehouse. That is, order receipts, sales invoices, as well as customer & supplier data is integrated with regulatory details, personnel data, and others. These are all specially organised for future reporting and analysis.

However, data, no matter how all-embracing, is useless until it is processed into actionable information. Through OLAP or Online Analytical Processing, you can seamlessly collect all relevant data from your vast repository to answer queries like “What is our company’s profitability for the 2nd quarter in all identified key cities for our top-of-the-line products?”.

The strength of OLAP lies in its inherent ability to perform data analysis and very complex calculations, thus enabling it to return complex queries much faster than other database technologies. It is therefore suitable for very large data sources, i.e., data warehouses.

Dashboards and reports will only give your organisation the edge if the information retrieved is reliable, fast, and accurate – exactly the kind OLAP is so good at.

Mobile BI – Step back and see the big picture anytime, anywhere

Spreadsheets are great for displaying detailed information. However, in today’s highly competitive market, retrieving information that matters the most in the shortest possible time is vital in maintaining a sizeable lead over the competition. To step back and see the big picture, you’ll need insightful tools like dashboards and automatically generated reports.

Reports can be beamed to mobile devices such as smart phones and Pocket PCs. They can also be viewed on eBook readers as well. You can also do the same tasks with spreadsheets. But imagine how you’d need to scroll over a large spreadsheet on any of these mobile devices just to know which customer in your current location has performed well over the last month.

If you really want to make quick, well-informed decisions, BI dashboards for mobile devices is the way to go. You can make use of various business objects such as drill-able charts, performance metrics, and metric trend graphs to make crucial decisions even when on you’re in the field.

Will UK Retailers Skim the Cream with ESOS?

The British Retail Consortium (BRC) was quick out on the starting blocks with an ambitious plan to cut energy costs by 25% in 5 years. Their ?25-in-5? initiative is chasing a target of ?4.4 billion savings during the duration. Part of this program involves ?cutting a path through a complex and inaccessible policy landscape?. BRC believes this drawback is making its members think twice about making energy efficiency investments.

The UK?s sprawling network of grocers, department stores and malls is the nation?s second most hungry energy customer, having spent ?3.3 billion on it in 2013 when it accounted for almost 20% of carbon released. If you think that sounds bad, it purchased double that amount in 2005. However the consortium believes there is still more to come.

It bases this assumption on the push effect of UK energy rates increasing by a quarter during the duration of the project. ?So it makes sense to be investing in energy efficiency rather than paying bills,? Andrew Bolitho (property, energy, and transport policy adviser) told Business Green. The numbers mentioned exclude third party transport and distribution networks not under the British Retail Consortium umbrella.

The ?complex and inaccessible policy landscape? is the reflection of UK legislators not tidying up as they go along. BRC cites a ?vast number of policies ? spreading confusion, undermining investment and making it harder to raise capital?. The prime culprits are Britain?s CRC Energy Efficient Scheme (previously Carbon Reduction Commitment) which publishes league tables and ESOS. Andrew Bolitho believes this duality is driving confused investors away.

The British Retail Consortium is at pains to point out that this is not about watering things down, but making it simpler for participating companies to report on energy matters at a single point. It will soon go live with its own information hub providing information for retailers wishing to measure consumption at critical points, assemble the bigger picture and implement best practice.

Ecovaro agrees with Andrew Bolitho that lowering energy demand and cutting carbon is not just about technology. We can do much in terms of changing attitudes and providing refresher training and this does not have to cost that much. Studies have shown repeatedly that there is huge benefit in inviting employees to cross over to our side. In fact, they may already be on board to an extent that may surprise.

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