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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Which KPI?s to Use in CRM

Customer relationship management emerged in the 1980?s in the form of database marketing. In those tranquil pre-social media days, the possibility of ?managing? clients may have been a possibility although Twitter and Facebook took care of that. Modern managers face a more dynamic environment. If you are one, then what are the trends you should be monitoring yourself (as opposed to leaving it to others).

If you want to drip feed plants, you have to keep the flow of liquid regular. The same applies to drip-feed marketing. Customers are fickle dare we say forgetful. Denizon recommends you monitor each department in terms of Relationship Freshness. When were the people on your list last contacted, and what ensued from this?

Next up comes the Quality of Engagements that follow from these efforts. How often do your leads respond at all, and how many interfaces does it take to coax them into a decision? You need to relate this to response blocks and unsubscribes. After a while you will recognise the tipping point where it is pointless to continue.

Response Times relate closely to this. If your marketing people are hot then they should get a fast response to sales calls, email shots and live chats. It is essential to get back to the lead again as soon as possible. You are not the only company your customers are speaking too. Fortune belongs to the fast and fearless.

The purpose of marketing is to achieve Conversions, not generate data for the sake of it. You are paying for these interactions and should be getting more than page views. You need to drill down by department on this one too. If one team is outperforming another consider investing in interactive training.

Finally Funnel Drop-Off Rate. Funnel analysis identifies the points at which fish fall off the hook and seeks to understand why this is happening. If people click your links, make enquiries and then drift away, you have a different set of issues as opposed to if they do not respond at all.

You should be able to pull most of this information off your CRM system if it is half-decent, although you may need to trigger a few options and re orientate reporting by your people in the field. When you have your big data lined up speak to us. We have a range of data analysts brimming over with fresh ideas.

How Small Irish Businesses Avoid the GDPR Sting

Accountants providing chartered accounting services and tax advice are alerting smaller Irish companies to the consequences of the pending General Data Protection Regulation (GDPR). They believe these are going to feel the most pain come 25 May 2018, if they do not implement GDPR by then. We are trying our best to help avoid this situation by providing advice.

How to Kick the GDPR Ball into Play

The Irish Information Commissioner?s Office has produced a toolkit regarding where?s best to start. They suggest beginning with an information security assessment to determine the gaps companies need to close. Once quantified, this leads naturally to a plan of action, and resources needed to fulfil it. Here?s how to go about it:

1. Start by assessing your current ability to identify, assess, and manage threats to customer data security. Have you done anything at all to date? You must be holding some customer information surely, and it is highly likely the GDPR applies to you.

2. Next, review your company?s current customer data security policies. Are they documented and approved, or do new employees discover them sitting next to Nellie? Rate yourself on a scale where ten is successful implementation.

3. Now consider how well you have pinned responsibilities on individuals to implement policies and take the lead on GDPR. The latter should be the business owner, or a board member with clout to make things happen.

4. By now, you should have a grasp of the scale of work ahead of you, remembering the EU deadline is 25 May 2018. If this sounds overwhelming, consider outsourcing to your accountant or a specialist provider.

5. Under the General Data Protection Regulation you have only 72 hours to report a breach of customer data security to the Information Commissioner?s Office. Do you have a quality assurance mechanism to oversee this?

Tangible Things to Bring Your Own People on Board

With all the changes going on, there is a risk of your employees regarding GDPR as ?another management idea going nowhere.? Thus, it is important to incorporate the new EU regulations in staff training, particularly with regard to data security generally. They may fully come on board only once they see tangible signs of progress. You should in any case put the following measures in place unless you already have them:

1. A secure area for your servers and for any paperwork your customers provided. This implies access control on a need-to-know basis to protect the information against loss, damage, and theft.

2. A protocol for storage media and record disposal when you no longer require them or something supersedes them. You are the custodian of other people?s information and they deserve nothing less.

3. Procedures to secure customer data on employee mobile devices and computers: This must extend to work done at home, at consultant sites, and by remote workers.

4. Secure configuration of all existing and new hardware to minimise vulnerability and storage media crashes. These quality assurance measures should extend to removable media and remote backups.

So Is This the Worst of the Pain?

We are at the heart of the matter, although there is more to tell in future articles. You may be almost there, if you already protect your proprietary information. If not, you may have key company information already open to malware.We should welcome the EU General Data Protection Regulation as a notice that it is time to face up to the challenges of data protection and security generally. The age of hacking and malware is upon us. The offender could be a disgruntled employee, or your competition just down the street. It is time to take precautions.

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The Cloud: Changing the Game for Small Businesses

There is a consensus among cloud experts that the onset of cloud computing will benefit small organisations the most. In fact, many even go as far as saying that the cloud and small businesses are a match made in IT heaven. How much of this is true and how much of this is merely part and parcel of the hype surrounding cloud computing?

The Cloud as the Great?Equaliser

If you closely examine the essential characteristics of cloud computing, particularly public cloud services, you will see why small organisations would be very interested in the cloud, and would eventually flock to it, like moths to a flame. And why not? Cloud computing is turning out to be the weapon that can allow small and medium organisations to compete on a more level playing field against large enterprises.

Here are some cloud computing benefits that may just close the gap between the two.

  • Significantly lower IT spending. With little to no investment at all on hardware infrastructure and practically zero maintenance costs, SMBs that would have required substantial capital for IT are now finding it easy to get a business started from scratch or develop and test out new products by using the cloud as the backbone of their IT set-up. The pay-as-you-go pricing scheme that cloud computing offers allows companies to start small and scale up as needed, or when the revenue starts coming in.
  • Higher employee productivity. Licensing fees for software applications can run high even if you don’t have a large staff. Good thing there are now a host of cloud-based office tools – word processors, spreadsheets, presentations, accounting systems, etc. – that can boost employee productivity without the corresponding costs that small businesses can ill afford. Plus, team members in remote locations can continue to collaborate with the rest through any internet-connected device in real time.
  • Easier, better communication. The easy accessibility of communication apps has also changed the way employees interact with fellow employees and more importantly, with customers. Whether through email, instant messaging, or social networks, cloud services have given individuals and businesses more ways of giving and getting feedback. The best thing about it is that most of these services don’t cost much or are even free, giving SMBs ample tools to create better products and improve service.
  • A Look at the Figures Many small businesses are already seeing the potential in the cloud, with SaaS (Software as a Service) applications most commonly used among the early adopters. These services include email and other communication apps, file sharing, and backup.

In a February 2012 Edge Strategies survey (commissioned by Microsoft) of 3,000 small businesses in the US, the following data came to light:

  • The number of small companies with 2 to 10 employees using paid cloud services will triple in the next three years;
  • Current cloud users report purchasing an average of 4 services in the cloud now and expect to use 6 in the future;
  • Fifty percent agree that cloud computing is going to become more important for businesses such as theirs.

Further, a survey of 323 SMBs recently released by social business site Spiceworks and sponsored by EMC reveals that from 48 percent at the start of 2012 and 28 percent a year ago, 62 percent of the businesses surveyed now use some type of cloud app.

What these numbers show is that cloud adoption among small and medium enterprises is starting to gain ground and for sure, more will do the same as understanding and awareness increase. Yes, these businesses should still perform their due diligence as there is no one-size-fits-all cloud solution. But for those companies who have managed to find the right cloud apps and services for their needs, it’s all sunny skies up ahead.

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