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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User-Friendly RASCI Accountability Matrices

Right now, you’re probably thinking that’s a statement of opposites. Something dreamed up by a consultant to impress, or just to fill a blog page. But wait. What if I taught you to create order in procedural chaos in five minutes flat? ?Would you be interested then?

The first step is to create a story line ?

Let’s imagine five friends decide to row a boat across a river to an island. Mary is in charge and responsible for steering in the right direction. John on the other hand is going to do the rowing, while Sue who once watched a rowing competition will be on hand to give advice. James will sit up front so he can tell Mary when they have arrived. Finally Kevin is going to have a snooze but wants James to wake him up just before they reach the island.

That’s kind of hard to follow, isn’t it ?

Let’s see if we can make some sense of it with a basic RASCI diagram ?

Responsibility Matrix: Rowing to the Island
Activity Responsible Accountable Supportive Consulted Informed
Person John Mary Sue James Kevin
Role Oarsman Captain Consultant Navigator Sleeper

?

Now let’s add a simple timeline ?

Responsibility Matrix: Rowing to the Island
? Sue John Mary James Kevin
Gives Direction ? ? A ? ?
Rows the Boat ? R ? ? ?
Provides Advice S ? ? ? ?
Announces Arrival ? ? A C ?
Surfaces From Sleep ? ? ? C I
Ties Boat to Tree ? ? A ? ?

?

Things are more complicated in reality ?

Quite correct. Although if I had jumped in at the detail end I might have lost you. Here?s a more serious example.

rasci

?

There?s absolutely no necessity for you so examine the diagram in any detail, other to note the method is even more valuable in large, corporate environments. This one is actually a RACI diagram because there are no supportive roles (which is the way the system was originally configured).

Other varieties you may come across include PACSI (perform, accountable, control, suggest, inform), and RACI-VS that adds verifier and signatory to the original mix. There are several more you can look at Wikipedia if you like.

Why Spreadsheets can send the Pillars of Solvency II Crashing Down


Solvency II is now fast approaching and while it may provide added protection to policy holders, its impact on the insurance industry is not all a bed of roses. Expect insurance companies to restructure, increase manpower, and raise spending on actuarial operations and risk management initiatives. Those that cannot, will have to go. But what have spreadsheets got to do with all these?

Well, spreadsheets aren’t really the main casts in this blockbuster of a regulatory exercise but they certainly have a significant supporting role to play. Pillar I of Solvency II, which calls for improved supervision on internal control, risk management, and corporate governance, and Pillar II, which tackles supervisory reporting and public disclosure of financial and other relevant information, both affect systems that have high-reliance on spreadsheets.

A little background about spreadsheets might help.

Who needs an IT solution when you can have spreadsheets?

Everyone in any organisation just love spreadsheets; from the office clerk to the CEO. Because they’re so easy to use (not to mention they’re a staple in office computers), people employ them for processing numbers and as an all-around tool for planning, forecasting, reporting, complex modelling, market data analysis, and so on. They make such tasks faster and easier. Really?

You probably haven’t heard of spreadsheet hell

Unfortunately, spreadsheets do have certain shortcomings. Due to their inherent structure and lack of controls, it is so easy to commit simple errors like an accidental copy paste, an omission of a negative sign, an incorrect data input, or an unintentional deletion. Such shortcomings may seem harmless until your shareholders discover a multi-million discrepancy in your financial report.

And because spreadsheet errors can go undetected for a long time, they are constant targets of fraudsters. In other words, spreadsheets are high risk applications.

Solvency II Impact on Spreadsheet-based Financial and IT Systems

Regulations like Solvency II, are aimed at reducing risks to manageable levels. Basically, Solvency II is a risk-based system wherein a company?s capital requirements will depend on its measured riskiness. If companies want to avoid facing onerous capital requirements, they have to comply.

The three pillars of Solvency II have to be in place. Now, since spreadsheets (also known as User Developed Applications or UDAs) are high-risk applications with weak control features and prone to produce inaccurate reports, companies will have a lot of work to do to establish Pillars II and III.

There are at least 8 articles that impact spreadsheets in the directive. Article 82, for example, which requires firms to ensure a high level of data quality and accuracy, strikes at the very core of spreadsheets? weakness.

A whitepaper by Raymond Panko entitled ?Spreadsheets and Sarbanes-Oxley: Regulations, Risks, and Control Frameworks? mentioned that 94% of audited real world operational spreadsheets that were included in his study were found to have errors and that an average of 5.2% of all cells in the audited spreadsheets had errors.

Furthermore, many articles in the directive call for the enforcement of better documentation. This is one thing that’s very tedious and almost unrealistic to do with spreadsheets because just about anyone uses them. Besides, with different ‘versions? of the same data existing in different workstations throughout the organisation, it would be extremely difficult to keep track of them all.

Because of spreadsheets you now need an IT solution

It is clear that, with the growing number of regulations and the mounting complexity of tasks needed for compliance, spreadsheets no longer belong in this era. What you need is a server-based solution that allows for seamless collaboration, data reliability, data consistency, increased security, automatic consolidation, and all the other features that make regulation compliance more doable.

One important ingredient for achieving Solvency II compliance is sound data risk management. Sad to say, the ubiquitous spreadsheet will only expose your data to more risks.

More Spreadsheet Blogs


Spreadsheet Risks in Banks


Top 10 Disadvantages of Spreadsheets


Disadvantages of Spreadsheets – obstacles to compliance in the Healthcare Industry


How Internal Auditors can win the War against Spreadsheet Fraud


Spreadsheet Reporting – No Room in your company in an age of Business Intelligence


Still looking for a Way to Consolidate Excel Spreadsheets?


Disadvantages of Spreadsheets


Spreadsheet woes – ill equipped for an Agile Business Environment


Spreadsheet Fraud


Spreadsheet Woes – Limited features for easy adoption of a control framework


Spreadsheet woes – Burden in SOX Compliance and other Regulations


Spreadsheet Risk Issues


Server Application Solutions – Don’t let Spreadsheets hold your Business back


Why Spreadsheets can send the pillars of Solvency II crashing down

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Data Replication

Medical Data Form

These days, not many companies can continue to operate once their entire computer system goes down. All the information needed in daily operations are stored in databases while the interfaces that make use of them all come in the form of software applications.

Software applications can be rapidly reinstalled and configured for as long as the necessary programs are available. Data, however, cannot be reconstructed as quickly even with hard copies available. It is therefore necessary to store your data in a replicated setup so that when one section goes down, operations can proceed without interruption.

For instance, if a category 5 hurricane renders your main office useless, you can simply rent workstations elsewhere, connect to the Internet and continue with your usual transactions for as long as data is readily accessible.

So how do we ensure the accessibility and reliability of your data? Here’s what we’ll do:

  • Activate data replication on your database management system. If your DBMS does not support replication, we’ll migrate all your data to one that does.
  • If absolutely necessary, we can allow modernised systems to run parallel to your legacy systems and prepare both for full modernisation when you’re ready.
  • Implement fail-over technologies where applicable to provide for automatic switching to a backup data server or network from one that has just failed.

We can also assist you with the following:

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