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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Knowing the Caveats in Cloud Computing

Cloud computing has become such a buzzword in business circles today that many organisations both small and large, are quick to jump on the cloud bandwagon – sometimes a little too hastily.

Yes, the benefits of the cloud are numerous: reduced infrastructure costs, improved performance, faster time-to-market, capability to develop more applications, lower IT staff expenses; you get the picture. But contrary to what many may be expecting or have been led to believe, cloud computing is not without its share of drawbacks, especially for smaller organisations who have limited knowledge to go on with.

So before businesses move to the cloud, it pays to learn a little more about the caveats that could meet them along the way. Here are some tips to getting started with cloud computing as a small business consumer.

Know your cloud. As with anything else, knowledge is always key. Because it is a relatively new tool in IT, it’s not surprising that there is some confusion about the term cloud computing among many business owners and even CIOs. According to the document The NIST Definition of Cloud Computing, cloud computing has five essential characteristics, three basic service models (Saas, Paas and Iaas), and four deployment models (public, community, private and hybrid).

The first thing organisations should do is make a review of their operations and evaluate if they really need a cloud service. If they would indeed benefit from cloud computing, the next steps would be deciding on the service model that would best fit the organisation and choosing the right cloud service provider. These factors are particularly important when you consider data security and compliance issues.

Read the fine print. Before entering into a contract with a cloud provider, businesses should first ensure that the responsibilities for both parties are well-defined, and if the cloud vendor has the vital mechanisms in place for contingency measures. For instance, how does the provider intend to carry out backup and data retrieval operations? Is there assurance that the business’ critical data and systems will be accessible at all times? And if not, how soon can the data be available in case of a temporary shutdown of the cloud?

Also, what if either the company or the cloud provider stops operations or goes bankrupt? It should be clear from the get go that the data remains the sole property of the consumer or company subscribing to the cloud.

As you can see, there are various concerns that need to be addressed closely before any agreement is finalised. While these details are usually found in the Service Level Agreements (SLAs) of most outsourcing and servicing contracts, unfortunately, the same cannot be said of cloud contracts.

Be aware of possible unforeseen costs. The ability of smaller companies to avail of computing resources on a scalable, pay-as-you-go model is one of the biggest selling points of cloud computing. But there’s also an inherent risk here: the possibility of runaway costs. Rather than allowing significant cost savings, small businesses could end up with a bill that’s bound to blow a big hole in their budget.

Take for example the case of a software company cited on InformationWeek.com to illustrate this point. The 250-server cluster the company rented from a cloud provider was inadvertently left turned on by the testing team over the weekend. As a result, their usual $2,300 bill ballooned to a whopping $23,400 over the course of one weekend.

Of course, in all likelihood, this isn’t going to happen to every small and midsize enterprise that shifts to the cloud. However, this should alert business owners, finance executives, and CEOs to look beyond the perceived savings and identify potential sources of unexpected costs. What may start as a fixed rate scheme for on-demand computing resources, may end up becoming a complex pricing puzzle as the needs of the business grow, or simply because of human error as the example above shows.

The caveats we’ve listed here are among the most crucial ones that soon-to-be cloud adopters need to keep in mind. But should these be reasons enough for businesses to stop pursuing a cloud strategy? Most definitely not. Armed with the right information, cloud computing is still the fastest and most effective way for many small enterprises to get the business off the ground with the lowest start-up costs.

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Spend more to reduce costs?

It is becoming increasingly important to not to analyse energy consumption for all utility types, be it electricity, gas, water, heat, renewables, oil etc. The bottom line is both operational efficiency and utility costs monitoring. In the long run, these are management strategies designed to drive energy costs downwards as a continuous improvement cycle and as a measure of reducing carbon emissions.

It is also getting increasingly easier for organisations reduce energy use and achieve this goal using technology without having to “remember” to do it yourself. Organisations can never go wrong by investing in energy management software. There are varied software options to choose from depending on the organisational objective.
Some of the energy management objectives that organisations may need to meet are:

? Establishing baseline energy use

? Carrying out Energy audits

? Monitoring and measuring energy performance against the energy policies of an organisation and objectives

? Achieving energy certification
Energy management software?s come in handy when an organization wishes to achieve either of the above objectives.

Use of energy management software?s also assists organisations in measurement and verification of energy consumption as well as Monitoring and Targeting. Measurement and verification is where a company quantifies energy consumption beforehand (baseline energy use) and after energy consumption measurements are implemented in order to verify and report on the level of savings actually achieved.

Organisations that wish to verify the energy savings achieved by building retrofits can use energy management software?s. This is an important objective for companies that wish to either satisfy internal financial accounting and reporting requirements, or to meet the terms of third-party contracts for project implementation and management. Monitoring and targeting is also made easier by use of software. This is critical as a management technique, regardless of whether an organisation has specific facility retrofits in order to keep operations efficient and to monitor utility costs.
Overall, an investment in energy management software, is worthwhile in the achievement of management strategies designed to drive energy costs downwards as a continuous improvement cycle.

The Rights of Individuals Under The General Data Protection Regulation

The General Data Protection Regulation or GDPR is a European Union law reinforcing the rights of citizens concerning the confidentiality of their information, and confirming that they own it. We thought it would be interesting to examine the GDPR effective 25 May 2018 from an Irish citizen?s perspective. This article is a summary of information on the Data Protection Commissioner?s website, but as viewed through a businessperson?s lens.

How the Office Defines Data Protection

The Office believes that organisations receiving personal details have a duty to keep them private and safe. This applies inter alia to information that individuals supply to government, financial institutions, insurance companies, medical providers, telecoms services, and lenders. It also applies to information provided when they open accounts.

This information may be on paper, on computers, or in video, voice, or photographic records. The true owners of this information, the individuals have a right:

  • To make sure that it is factually correct
  • To the assurance that it is shared responsibly
  • That all with access only use it for stated purposes

Any organisation requesting personal information must state who they are, what the information is for, why they need to have it, and to whom else they may provide it.

Consumer Rights to Access Their Personal Information

Private persons have a right under the GDPR to a copy of all their information held or processed by a business. The regulation refers to such businesses as ?data controllers? as opposed to owners, which is interesting. They have to provide both paper and digital data, and ‘related information?.

Data controller fees for this are discretionary within limits. The request may be denied under certain circumstances. The data controller may release information about children to parents and guardians, only if it considers a minor too young to understand its significance. Other third parties such as attorneys must prove they have consent.

Consumer Rights to Port Their Data to Different Services

Since the personal information belongs to the individual, they have a right not only to access it, but also to copy or move it from one digital environment to another. The GDPR requires this be ?in a safe way, without hindrance to usability?. An application could be a banking client that wants to upload their transaction history to a third party price comparison website.

However, the right to data portability only applies to data originally provided by the consumer. Moreover, an automated method must be available for porting. Data controllers must release the information in an open format, and may not charge for the porting service.

Consumer Rights to Complain About Personal Data Abuse

Individuals have a right under the General Data Protection Regulation to have their information rectified if they discover errors. This right extends to an assurance that third parties know about the changes – and who these third party entities are. Data controllers must respond within one month. If they decline the request, they must inform the complainant of their right to further remedial action.

If a data controller refuses to release personal information to the owner, or to correct errors, then the Data Protection Office has legal power to enforce the consumer?s rights. The complainant must make full disclosure of the history of their complaint, and the steps they have taken themselves to attempt to set things right.

Further Advice on Getting Things Ready for 25 May 2018

The General Data Protection Regulation has the full force of law from 25 May 2018 onward, and supersedes all applicable Irish laws, regulations, and policies from that date. We recommend incorporating rights of data owners who are also your customers into your immediate plans. We doubt that forgetting to do so will cut much sway with the Data Commissioner. Remember, you have one month to respond to consumer requests, and only one more month to close things out subject to the matter being complex.

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