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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IT Risk and Control Solutions Specialists – Why you need them more than ever

Over the years, the capabilities of IT systems have certainly grown by leaps and bounds. But so have the risks that accompany them. Countless threats to IT systems now exist that are capable of seriously disrupting business operations. That’s why companies have to conduct assessments aimed at making sure their systems are still capable of functioning effectively, efficiently, and securely all the time.

If you think you’ve been lucky enough to be spared from these threats, then maybe it’s because you haven’t conducted a risk assessment on your IT system recently. All too often, we hear of CIOs who believed their IT system was in tip-top condition, only to be later caught off-guard by a critical system breakdown that would eventually cripple their business for days or weeks.

More information assets to look after

If, before, you only had to worry about regular office applications, workstations, a LAN and a server, today’s varied and more sophisticated information assets are more challenging to maintain.

In addition to network operating systems, database management systems, content management systems, email systems, virtualization platforms, document management systems, business intelligence applications, and accounting software, a typical enterprise may also have to look after firewalls, intrusion detection systems, storage and backup systems, and data loss prevention systems, to mention a few.

These understandably require the services of experts spanning a wide range of skill sets.

Rising threats to corporate identity and privacy

Individuals are no longer just the ones being preyed upon by identity thieves. Businesses can now be subject to corporate identity theft as well. You could wake up one day finding your business already accused of carrying out illegal activities, a big chunk of your money gone, and your directors? seats already occupied by complete strangers.

To make things worse, corporate threats aren’t just coming from the outside.

Threats to corporate privacy, for instance, can come from within the organisation itself. Sensitive information like trade secrets and financial data are often leaked out (purposely or inadvertently) by employees. This is largely caused by the ever growing number of options for communications and transferring data (e.g. emails, instant messaging, blogs, social networking sites, ftp, P2P, etc.).

Greater challenges in designing, developing, and implementing policies and programs

Laws and regulations like SOX and Solvency II, which have direct impacts on IT, are on the rise. That is why corporate policies and programs now require sweeping changes. You now have to be more deliberate in integrating IT when establishing governance, internal controls, change management, incident management, and performance management.

A solid understanding on widely accepted frameworks and good practices like COBIT, COSO, and CMMI will help you considerably in such undertakings. Using these frameworks as guidelines will not only help you keep your policies and programs attuned to the times, they will also keep you in compliance with regulations.

Increasing demand for disaster recovery and business continuity capabilities

Every time you have a down time, you increase the probability of losing your customers to competitors. The longer the down time, the greater that probability becomes. Therefore, when a major disruption strikes, you should be able to recover at the soonest. If possible, you should be able to deliver products and services as usual.

This of course requires spending to increase your disaster recovery (DR) and business continuity (BC) capabilities. Are you ready for it? Migrating your IT infrastructure from traditional systems to the latest technologies that are better equipped for BC/DR requires careful planning and implementation to ensure an optimal return on investment.

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What Sub-Metering did for Nissan in Tennessee

When Nissan built its motor manufacturing plant in Smyrna 30 years ago, the 5.9 million square-foot factory employing over 8,000 people was state of art. After the 2005 hurricane season sky-rocketed energy prices, the energy team looked beyond efficient lighting at the more important aspect of utility usage in the plant itself. Let’s examine how they went about sub-metering and what it gained for them.

The Nissan energy team faced three challenges as they began their study. They had a rudimentary high-level data collection system (NEMAC) that was so primitive they had to transfer the data to spread-sheets to analyse it. To compound this, the engineering staff were focused on the priority of getting cars faster through the line. Finally, they faced the daunting task of making modifications to reticulation systems without affecting manufacturing throughput. But where to start?

The energy team chose the route of collaboration with assembly and maintenance people as they began the initial phase of tracking down existing meters and detecting gaps. They installed most additional equipment during normal service outages. Exceptions were treated as minor jobs to be done when convenient. Their next step was to connect the additional meters to their ageing NEMAC, and learn how to use it properly for the first time.

Although this was a cranky solution, it had the advantage of not calling for additional funding which would have caused delays. However operations personnel were concerned that energy-saving shutdowns between shifts and over weekends could cause false starts. ?We’ve already squeezed the lemon dry,? they seemed to say. ?What makes you think there?s more to come??

The energy team had a lucky break when they stumbled into an opportunity to prove their point early into implementation. They spotted a four-hourly power consumption spike they knew was worth examining. They traced this to an air dryer that was set to cyclical operation because it lacked a dew-point sensor. The company recovered the $1,500 this cost to fix, in an amazing 6 weeks.

Suitably encouraged and now supported by the operating and maintenance departments, the Smyrna energy team expanded their project to empower operating staff to adjust production schedules to optimise energy use, and maintenance staff to detect machines that were running without output value. The ongoing savings are significant and levels of shop floor staff motivation are higher.

Let’s leave the final word to the energy team facilitator who says, ?The only disadvantage of sub-metering is that now we can’t imagine doing without it.?

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Which Services to Share?

It often makes sense to pool resources. Farmers have been doing so for decades by collectively owning expensive combine harvesters. France, Germany, the United Kingdom and Spain have successfully pooled their manufacturing power to take on Boeing with their Airbus. But does this mean that shared services are right in every situation?

The Main Reasons for Sharing

The primary argument is economies of scale. If the Airbus partners each made 25% of the engines their production lines would be shorter and they would collectively need more technicians and tools. The second line of reasoning is that shared processes are more efficient, because there are greater opportunities for standardisation.

Is This the Same as Outsourcing?

Definitely not! If France, Germany, the United Kingdom and Spain has decided to form a collective airline and asked Boeing to build their fleet of aircraft, then they would have outsourced airplane manufacture and lost a strategic industry. This is where the bigger picture comes into play.

The Downside of Sharing

Centralising activities can cause havoc with workflow, and implode decentralised structures that have evolved over time. The Airbus technology called for creative ways to move aircraft fuselages around. In the case of farmers, they had to learn to be patient and accept that they would not always harvest at the optimum time.

Things Best Not Shared

Core business is what brings in the money, and this should be tailor-made to its market. It is also what keeps the company afloat and therefore best kept on board. The core business of the French, German, United Kingdom and Spanish civilian aircraft industry is transporting passengers. This is why they are able to share an aircraft supply chain that spun off into a commercial success story.

Things Best Shared

It follows that activities that are neither core nor place bound – and can therefore happen anywhere ? are the best targets for sharing. Anything processed on a computer can be processed on a remote computer. This is why automated accounting, stock control and human resources are the perfect services to share.

So Case Closed Then?

No, not quite. ?Technology has yet to overtake our humanity, our desire to feel part of the process and our need to feel valued. When an employee, supplier or customer has a problem with our administration it’s just not good enough to abdicate and say ?Oh, you have to speak to Dublin, they do it there?.

Call centres are a good example of abdication from stakeholder care. To an extent, these have ?confiscated? the right of customers to speak to speak directly to their providers. This has cost businesses more customers that they may wish to measure. Sharing services is not about relinquishing the duty to remain in touch. It is simply a more efficient way of managing routine matters.

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