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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Risk Assessment

Risk assessment is a vital component in BC (Business Continuity) planning. Through risk assessment, your company may determine what vulnerabilities your assets possess. Not only that, you’ll also be able to quantify the loss of value of each asset against a specific threat. That way, you can rank them so that assets that are most likely to cripple your business when say a specific disaster strikes can be given top priority.

However, a poorly implemented risk assessment may also cost you unnecessary expenditures. Many risk assessors are too enthusiastic in pointing out risks that, at the end of the assessment, they tend to over-appraise even those having practically zero probability of ever occurring.

We can assure you of a realistic assessment of your assets’ risks and propose cost-effective countermeasures. These are the things we can do:

  • Identify your unsafe practices and propose the best alternatives.
  • Perform qualitative risk assessment if you want fast results and lesser interruptions on your operations.
  • Perform quantitative risk assessment if you want the most accurate depiction of your risks and the corresponding justifiable costs of each.
  • Conduct frequency and consequence analysis to identify unforeseen harmful events and determine their effects to various components of your organisation and its surroundings.

We can also assist you with the following:

2015 ESOS Guidelines Chapter 6 – Role of Lead Assessor

The primary role of the lead assessor is to make sure the enterprise?s assessment meets ESOS requirements. Their contribution is mandatory, with the only exception being where 100% of energy consumption received attention in an ISO 50001 that forms the basis of the ESOS report.

How to Find a Lead Assessor

An enterprise subject to ESOS must negotiate with a lead assessor with the necessary specialisms from one of the panels approved by the UK government. This can be a person within the organisation or an third party. If independent, then only one director of the enterprise need countersign the assessment report. If an employee, then two signatures are necessary. Before reaching a decision, consider

  • Whether the person has auditing experience in the sector
  • Whether they are familiar with the technology and the processes
  • Whether they have experience of auditing against a standard

The choice rests on the enterprise itself. The lead assessor performs the appointed role.

The Lead Assessor?s Role

The Lead Assessor?s main job is reviewing an ESOS assessment prepared by others against the standard, and deciding whether it meets the requirements. They may also contribute towards it. Typically their role includes:

  • Checking the calculation for total energy consumption across the entire enterprise
  • Reviewing the process whereby the 90% areas of significant consumption were identified
  • Confirming that certifications are in place for all alternate routes to compliance chosen
  • Checking that the audit reports meet the minimum criteria laid down by the ESOS system

Note: A lead assessor may partly prepare the assessment themselves, or simply verify that others did it correctly.

In the former instance a lead assessor might

  • Determine energy use profiles
  • Identify savings opportunities
  • Calculate savings measures
  • Present audit findings
  • Determine future methodology
  • Define sampling methods
  • Develop audit timetables
  • Establish site visit programs
  • Assemble ESOS information pack

Core Enterprise Responsibilities

The enterprise cannot absolve itself from responsibility for good governance. Accordingly, it remains liable for

  • Ensuring compliance with ESOS requirements
  • Selecting and appointing the lead assessor
  • Drawing attention to previous audit work
  • Agreeing with what the lead assessor does
  • Requesting directors to sign the assessment

The Environment Agency does not provide assessment templates as it believes this reduces the administrative burden on the enterprises it serves.

A Definitive List of the Business Benefits of Cloud Computing

When you run a Google search for the “benefits of cloud computing”, you’ll come across a number of articles with a good list of those. However, most of them don’t go into the details, which nevertheless might still suit some readers. But if you’re looking for compelling business reasons to move your company’s IT to the cloud, a peripheral understanding of what this technology can do for you certainly won’t cut it.

Now, cloud computing is not just one of those “cool” technologies that come along every couple of years and which can only benefit a particular department.?What we’re talking about here really is a paradigm shift in computing that can transform not only entire IT infrastructures but also how we run our respective organisations.

I hate to think that some people are holding back on cloud adoption just because they haven’t fully grasped what they’re missing. That is why I decided to put together this list. I wanted to produce a list that would help top management gain a deeper understanding of the benefits of the cloud.

Cloud computing is one bandwagon you really can’t afford not to jump into. Here are ten good reasons why:

1.?Zero?CAPEX and low TCO for an enterprise-class IT infrastructure

2. Improves cash flow

3. Strengthens business continuity/disaster recovery capabilities

4. Lowers the cost of analytics

5. Drives business agility

6. Ushers in anytime, anywhere collaboration

7. Enhances information, product, and service delivery

8. Keeps entire organisation in-sync

9. ?Breathes life into innovation in IT

10. Cultivates optimal environments for development and testing

Zero CAPEX and low TCO for an enterprise-class IT infrastructure

Most cloud adopters with whom I’ve talked to cite this particular reason for gaining interest in the cloud.

Of course they had to dig deeper and consider all other factors before ultimately deciding to migrate. But the first time they heard cloud services could give them access to enterprise class IT infrastructures without requiring any upfront capital investment, they realised this was something worth exploring.

A good IT infrastructure can greatly improve both your cost-effectiveness and your capability to compete with larger companies. The more reliable, fast, highly-available, and powerful it is, the better.

But then building such an infrastructure would normally require a huge capital investment for networking equipment, servers, data storage, power supply, cooling, physical space, and others, which could run up to tens or even hundreds of thousands of euros. To acquire an asset this costly, you’d have to take in debt and be burdened by the ensuing amortisation.

If you’ve got volumes of cash stashed in your vault, cost might not be a problem. But then if you really have so much savings, wouldn’t it be more prudent to use it for other sales-generating projects? An extensive marketing endeavour perhaps?

A capital expenditure of this magnitude and nature, which normally has to be approved by shareholders, can be regarded as a high financial risk. What if business doesn’t do well and you wouldn’t need all that computing power? What if the benefits expected from the IT investment are not realised??You cannot easily convert your IT infrastructure into cash.

Remember we’re talking about a depreciating asset. So even assuming you can liquidate it, you still can’t hope to sell it at its buying price. These factors are going to play in the minds of your Board of Directors when they’re asked to decide on this CAPEX.

Incidentally, these issues don’t exist in a cloud-based solution.

A cloud solution typically follows a pay-as-you-go utility pricing model where you get billed monthly (sometimes quarterly) just like your electricity. ?In other words, it’s an expense you’ll need to pay for?at the end of a period over which the service’s value would have already been realised. Compare that with a traditional infrastructure wherein you’ll have to spend upfront but the corresponding value will still have to be delivered gradually in the succeeding months or years.

demand expense traditional infrastructure

From the point of view of your CFO, what could have been a CAPEX to acquire an asset that depreciates with time (and consequently reduces your company’s net worth), becomes a flexible operating expense (OPEX).?Truly, it is an operating expense that you can increase, decrease, or even totally discontinue, depending on what the prevailing business conditions demand.

demand expense cloud infrastructure

People who think they have done the math in comparing cloud-based and traditional IT infrastructures claim that, although they see how cloud solutions transform CAPEX into OPEX, they really don’t see any significant difference in overall costs.

However, these people have only gone as far as adding up the expected monthly expenses of a cloud solution over the estimated duration of an equivalent IT infrastructure’s effective lifespan and comparing the sum with that IT infrastructure’s price tag. You won’t get a clear comparison that way.

You need to consider all factors that contribute to the infrastructure’s Total Cost of Ownership (TCO). Once you factor in the costs of electricity, floor space, storage, and IT administrators, the economical advantages of choosing a cloud solution will be more evident. Add to that the costs of downtime such as: interruptions to business operations, technical support fees, and the need to maintain expensive IT staff who spend most of their time “firefighting”, and you’ll realise just how big the savings of cloud adopters can be.

Still not convinced? Well, we’re still getting started.?On our next post, we’ll take a closer look at the additional benefits of paying under an OPEX model instead of a CAPEX model.

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