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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What Kanban can do for Call Centre Response Times

When a Toyota industrial engineer named Taiichi Ohno was investigating ways to optimise production material stocks in 1953, it struck him that supermarkets already had the key. Their customers purchased food and groceries on a just-in-time basis, because they trusted continuity of supply. This enabled stores to predict demand, and ensure their suppliers kept the shelves full.

The Kanban system that Taiichi Ohno implemented included a labelling system. His Kanban tickets recorded details of the factory order, the delivery destination, and the process intended for the materials. Since then, Ohno?s system has helped in many other applications, especially where customer demand may be unpredictable.

Optimising Workflow in Call Centres
Optimising workflow in call centres involves aiming to have an agent pick up an incoming call within a few rings and deal with it effectively. Were this to be the case we would truly have a just-in-time business, in which operators arrived and left their stations according to customer demand. For this to be possible, we would need to standardise performance across the call centre team. Moving optimistically in that direction we would should do these three things:

  • Make our call centre operation nimble
  • Reduce the average time to handle calls
  • Decide an average time to answer callers

When we have done that, we are in a position to apply these norms to fluctuating call frequencies, and introduce ?kanbanned? call centre operators.

Making Call Centre Operations Nimble
The best place to start is to ask the operators and support staff what they think. Back in the 1960?s Robert Townsend of Avis Cars famously said, ?ask the people ? they know where the wheels are squeaking? and that is as true as ever.

  1. Begin by asking technical support about downtime frequencies, duration, and causes. Given the cost of labour and frustrated callers, we should have the fastest and most reliable telecoms and computer equipment we can find.
  1. Then invest in training and retraining operators, and making sure the pop-up screens are valuable, valid, and useful. They cannot do their job without this information, and it must be at least as tech-savvy as their average callers are.
  1. Finally, spruce up the call centre with more than a lick of paint to awaken a sense of enthusiasm and pride. Find time for occasional team builds and fun during breaks. Tele-operators have a difficult job. Make theirs fun!

Reducing Average Time to Handle Calls
Average length of contact is probably our most important metric. We should beware of shortening this at the cost of quality of interaction. To calculate it, use this formula:

Total Work Time + Total Hold Time + Total Post Call Time

Divided By

Total Calls Handled in that Period

Share recordings of great calls that highlight how your best operators work. Encourage role-play during training sessions so people learn by doing. Publish your average call-handling time statistics. Encourage individual operators to track how they are doing against these numbers. Make sure your customer information is up to date. While they must confirm core data, limit this so your operators can get down to their job sooner.

Decide a Target Time to Answer Calls
You should know what is possible in a matter of a few weeks. Do not attempt to go too tight on this one. It is better to build in say 10% slack that you can always trim in future. Once you have decided this, you can implement your Kanban system.

Introducing Kanban in Your Call Centre Operation
Monitor your rate of incoming calls through your contact centre, and adjust your operator-demand metric on an ongoing basis. Use this to calculate your over / under demand factor. Every operator should know the value on this Kanban ticket. It will tell them whether to speed up a little, or slow down a bit so they deliver the effort the call rate demands. It will also advise the supervisor when to call up reserves.

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The Future of Cloud Backup and Recovery

We came across a post on Docurated that pulled together thirty-seven suggestions for the top cloud storage mistakes user companies make. Given that cloud storage seems to be the best backup solution for now at least, we decided to turn these ideas around to sense the direction cloud backup and recovery needs to take, if it is still to be relevant in say ten years? time.

Has Cloud Storage Largely Saturated the West?
It probably has. Outside of major corporates who make their own arrangements ? and SME?s that use free services by email providers ? the middle band of companies in Europe and America have found their service providers, although they may have never tested the recovery process, to see if it works.

The new gold rush in the cloud backup and recovery business is, or should be emerging markets in Asia, Africa, South America, and the Middle East. There, connectivity is brittler than over here. To be relevant in these fragile, more populous areas our cloud backup and recovery industry need to be more agile and nimble.

? It must provide a simpler service emerging commerce can afford, refresh its user interfaces in third world languages, have more accessible help, and be patient to explain how cloud storage works to newbies. In other words, it must source its call centre operators in the areas it serves.

? It must adapt to local connectivity standards, and stop expecting someone with ADSL broadband to keep up with cloud server networks running at up to 1GBPS compared to their 10MBPS at best. For user sourcing and retention purposes, these new cloud backup and recovery services must be the ones who adapt.

? It must facilitate disaster recovery simulations among its clients in calmer moments when things are going well. Are they backing up the right files, are they updating these, and are their brittle ADSL networks able to cope with their cloud service providers? upload and download speeds?

? It must develop lean and agile systems slim enough to accommodate a micro client starting out, but sufficiently elastic to transfer them seamlessly to big data performance. The Asian, African, South American, and Middle Eastern regions are volume driven, and individual economies of scale are still rare.

? It must not expect its users to know automatically what they need, and be honest to admit that Western solutions may be wrong-sized. Conversion funnels in the new gold rush are bound to be longer. Engagements there depend on trust, not elevator sales letters. Our competition in these countries already works this way.

? It must be honest and admit cloud storage is only part of the solution. To recruit and retain users it must step back to 1983, when Compuserve offered its customers 128k of disc space, and spent an amount of effort explaining how to filter what to put there.

Cloud Storage of Data is Only One Part of the Solution
Governance reports and stock certificates burn just as easily as do servers in a fire. We must not transfer bad habits to exciting new markets. We close this article with the thoughts of John Howie, COO of Cloud Security Alliance, as reported in the Docurated post we mentioned, and these apply across the globe, we believe.
There is no single most important thing to carry forward into the future of cloud backup and recovery. We must be mindful when moving data that this can be fragile too. We must also create layers of backup the way insurance companies re-insure, that make any one cloud backup and recovery business redundant if it happens.
We hold the trust of our customers in our hands but trust is delicate too. We must cease trying to make a pile of money quickly, and become more interested in ensuring that data transferred back and forth is synchronised. The cloud backup and recovery industry needs only one notorious mistake, to become redundant itself in the ten years we mentioned.

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Total Quality Management

Total Quality Management (TQM) is another business management approach that focuses on the involvement of all members of the organisation to participate in improving processes, products, services, and the culture in which they work in. It is important that every team member realises how each individual and each activity affects, and in turn is affected by, others.

With the use of combined quality and management tools, TQM also aims to reduce losses brought about by wasteful practices, a common concern in most companies. Using the TQM strategy, business would also be able to identify the cause of a defect, thereby preventing it from entering the final product.

Deming’s 14 Points

At the core of the Total Quality Management concept and implementation is Deming’s 14 points, a set of guidelines on quality as conceptualised by W Edwards Deming, one of the pioneers of quality. Deming’s 14 points are as follows:

  1. Create constancy of purpose for improving products and services.
  2. Adopt the new philosophy.
  3. Cease dependence on inspection to achieve quality.
  4. End the practice of awarding business on price alone; instead, minimise total cost by working with a single supplier.
  5. Improve constantly and forever every process for planning, production and service.
  6. Institute training on the job.
  7. Adopt and institute leadership.
  8. Drive out fear.
  9. Break down barriers between staff areas.
  10. Eliminate slogans, exhortations and targets for the workforce.
  11. Eliminate numerical quotas for the workforce and numerical goals for management.
  12. Remove barriers that rob people of pride of workmanship, and eliminate the annual rating or merit system.
  13. Institute a vigorous program of education and self-improvement for everyone.
  14. Put everybody in the company to work accomplishing the transformation.

But if you were to reduce to bare bones the TQM philosophy from Deming’s 14 points, it would all come down to two simple goals:

  1. To make things right the first time; and
  2. To work for continuous improvement.

As with all other quality management process, the end goal is to be able to offer products and services that meet and even exceed customer’s expectations.

Find out more about our Quality Assurance services in the following pages:

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