How To Get Started with your IT Compliance Efforts for SOX

There’s no question about it. For many of you top executives in the corporate world, all roads leading to a brighter future have to go through SOX compliance. And because the business processes that contribute to financial reporting (the crux of the Sarbanes-Oxley Act) are now highly reliant on IT systems, it is important to focus a good part of your attention there.

It is a long and arduous path to IT compliance, so if you don’t want your company to fall by the wayside due to inefficient utilisation of resources, it is important to set out with a plan on hand. What we have here are some vital information that will guide you in putting together a sound plan for SOX compliance of your company?s IT systems.

Why focus on IT systems for SOX compliance?

We’ll get to that. But first, let’s take up the specific portions of the Sarbanes-Oxley Act that affect information technology. These portions can be found in Section 302 and Section 404 of the act.

In simplified form, Section 302 grants the SEC (Securities and Exchange Commission) authority to come up with rules requiring you, CEOs and CFOs, to certify in each annual or quarterly financial report the following:

  • that you have reviewed the report;
  • that based on your knowledge, the report does not contain anything or leave out anything that would render it misleading;
  • that based on your knowledge, all financial information in the report fairly represent the financial conditions of the company;
  • that you are responsible for establishing internal controls over financial reporting; and
  • that you have assessed the effectiveness of the internal controls.

Similarly, Section 404, stated in simplified form, allows the SEC to come up with rules requiring you, CEOs and CFOs, to add an internal control report to each annual financial report stating that you are responsible for establishing internal controls over financial reporting.

You are also required to assess the effectiveness of those controls and to have a public accounting firm to attest to your assessment based upon standards adopted by the Public Company Accounting Oversight Board (PCAOB).

While there is no mention of IT systems, IT systems now play a significant role in financial reporting. Practically all of the data you need for your financial reports are stored, retrieved and processed on IT systems, so you really have to include them in your SOX compliance initiatives and establish controls on them.

Now that that’s settled, your next question could very well be: How do you know what controls to install and whether those controls are already sufficient to achieve compliance?

Finding a suitable guide for IT compliance

The two bodies responsible for setting rules and standards dealing with SOX, SEC and PCAOB, point to a well-established control framework for guidance – COSO. This framework was drafted by the Committee of Sponsoring Organisations of the Treadway Commission (COSO) and is the most widely accepted control framework in the business world.

However, while COSO is a tested and proven framework, it is more suitable for general controls. What we recommend is a widely-used control framework that aligns well with COSO but also caters to the more technical features and issues that come with IT systems.

Taking into consideration those qualifiers, we recommend COBIT. COBIT features a well thought out collection of IT-related control objectives grouped into four domains: Plan and Organise (PO), Acquire and Implement (AI), Deliver and Support (DS), and Monitor and Evaluate (ME). The document also includes maturity models, performance goals and metrics, and activity goals.

A few examples of COBIt’s detailed control objectives are:

DS4.2 – IT Continuity Plans
DS4.9 – Offsite Backup Storage
DS5.4 – User Account Management
DS5.8 – Cryptographic Key Management
DS5.10 – Network Security
DS5.11 – Exchange of Sensitive Data

By those titles alone, you can see that the framework is specifically designed for IT. But the document is quite extensive and, chances are, you won’t need all of the items detailed there. Furthermore, don’t expect COBIT to specify a control solution controls for every control objective. For example, throughout the control objective DS4 (Ensure Continuous Service), you won’t find any mention of virtualisation, which is common in any modern business continuity solution.

Basically, COBIT will tell you what you need to attain in order to achieve effective governance, management and control, but you’ll have to pick the solution best suited to reach that level of attainment.

Articles highly relevant to the one you just read:

Month End Accounting The Way It Should Be Today
Spreadsheet Woes ? Burden in SOX Compliance and Other Regulations
Spreadsheet Woes ? Limited Features For Easy Adoption of a Control Framework
How Internal Auditors Can Win The War Against Spreadsheet Fraud

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Solutions to Password Overload

If only technologists had their way, passwords and PINs would have long been replaced with more innovative (and admittedly, better) security solutions. But such is not the case. Those alternative solutions, which include biometrics, smart cards, and password fobs, effective as they may be, are just way too expensive to implement.

So although passwords and PINs may not be here to stay, they certainly won’t be going away soon either.

Why keeping passwords in memory is no longer possible

A couple of decades ago, it would have been nearly impossible to crack an eight-character password using brute force. Today, however, advancements in computing power are rendering the typical passwords of the past easily decipherable, forcing us to come up with passwords that are not only much longer, but also much more complex and hence difficult to recall.

For instance, memorable words like your favourite character (e.g. ‘skywalker’) may have been acceptable then, but not anymore. Today?s security systems will encourage you to insert numbers or even other keyboard characters as a means to once again counter brute force. Hence, ‘sk5%ywa936lker@#’ may be more acceptable.

Remembering that one alone can be pretty daunting.

To further complicate matters, the number of applications that require passwords for access is much greater than before even for a single end user. Ordinary end users have to keep track of passwords for their email account, network login, workstation login, online services, and so on.

The burden is even greater for your IT admins, who have to remember a larger collection of passwords that protect business critical systems and applications. Clearly, the team in charge of your IT security will need a way to manage all these passwords.

Password management solutions

Existing password management solutions typically come in the form of software applications that store passwords. Basically, all you need to remember are your login details for the app a.k.a. the ?master password?. Once you’ve gained access inside, you can then retrieve any password you stored there.

Some of these apps are installed in portable devices like Pocket PCs, PDAs, or smartphones, which you would normally take along with you. For as long as the device stays with you, your passwords will be in safe hands. What’s more, you can retrieve them anywhere you go.

But obviously, there’s a problem. What if the device gets misplaced or stolen? Although the person who ends up with your device may not be able to gain access into the app and your passwords, neither will you. A better solution would therefore be an app that can be accessed anywhere but is not susceptible to getting lost.

Web-based password manager

A web-based password manager fits the bill. You don’t have to take it with you, but still you can access it almost anywhere. A typical web-based password manager will have all your passwords stored in a centralised, highly secure location.

If you want, you can even use your mobile password manager along with the web-based one. Ideally, your web-based password manager would have a copy of all the end-user passwords as well as the master passwords of your organisation.

With an easy to access but highly-secure web-based password manager, you no longer have to come up with passwords that (ironically) are supposed to be easy to remember but hard to crack at the the same time.

Furthermore, password managers are ideal for keeping passwords that have to be changed every-now-and-then; a requirement that’s becoming all too common in organisations bent on enforcing more stringent controls.

Succeed at Transformation

Despite the pomp and fanfare associated with launching corporate transformation programs, in reality very few of them succeed. According to a recent report by McKinsey the success rate is pegged below 40%. In addition, the same research indicates that defensive transformations – those undertaken as part of crisis management – have lower chances of success than progressive ones – those launched to streamline operations and foster growth. However, adopting certain strategies, like setting clear and high goals, and maintaining energy and engagement throughout the implementation phase, can really boost the project’s success rate. A key aspect of business transformation is IT transformation. This can be attributed to the fact that significant business change is either driven or influenced by technological change.

So what is IT Transformation?

IT transformation is basically a holistic reorganisation of the existing technological infrastructure that supports the company’s mission critical functions. In essence, IT transformation is not all about effecting change for the sake of change but involves systematic steps that align IT systems to business functions. To appreciate this approach, it is important to explore current trends in the business world where human resource, finance and IT transformations are being carried out in unison. This is being done to develop strong corporate centres that are leaner, agile and more productive that enhance greater synergies across all business functions.

IT transformation inevitably results in major changes of the information system’s technology, involving both hardware and software components of the system, the architecture of the system, the manner in which data is structured or accessed, IT control and command governance, and the components supporting the system. From this scope of works it is evident that IT transformation is a huge project that requires proper planning and implementation in order to succeed.

Tips to Improve Success in IT transformations Projects

1. Focus on Benefits not Functionality

The project plan should be more focused on benefits that can be accrued if the system is implemented successfully rather than system functionality. The benefits should be in line with business goals, for instance cost reduction and value addition. The emphasis should be on the envisaged benefits which are defined and outlined during the project authorisation. The business benefits outlined should be clear, feasible, compelling and quantifiable. Measures should be put in place to ensure that the benefits are clearly linked to the new system functionality.

2. Adopt a Multiple Release Approach

Typically most IT projects are planned with focus on a big launch date set in years to come. This approach is highly favoured because it simplifies stakeholder expectation management and avoids the complexity associated with multiple incremental releases. However, this approach misses the benefit of getting early critical feedback on functioning of the system. In addition, the long lead times often result in changes in project scope and loss of critical team members and stakeholders. IT transformation projects should be planned to deliver discrete portions of functionality in several releases. The benefit of multiple release approach is that it reduces project risks and most importantly allows earlier lessons learnt to be incorporated in future releases.

3. Capacity of the Organisation to confront Change

As pointed out, IT transformations result in significant changes in business operations and functions. Hence it is important that all business stakeholders should be reading from the same script in regards to changes expected. In addition, key stakeholders should be involved in crucial project stages and their feedback incorporated to ensure that the system is not only functional but business focused.

How Energy Conservation saved Fambeau River Paper

Rising energy costs caught this Wisconsin paper mill napping, and it soon shut down because it was unable to innovate. Someone else bought it and turned it around by measuring, modifying, monitoring and listening to people.

The Fambeau River Paper Mill in Prince County, Wisconsin USA employed 13% of the city?s residents until rising energy costs shut it down in 2006. Critics wrote it off as an energy dinosaur unable to adapt. But that was before another company bought it out and resuscitated it as a fleet-footed winner.

Its collapse was a long time coming and almost inevitable. Wisconsin electricity prices had grown a third since 1997, the machinery was antiquated and the dependence on fossil power absolute. So what did the new owners change, and is there anything we can learn from this?

The key to understanding what suddenly went right was the new owners? ability to listen. They requested a government Energy Assessment that suggested a number of small step changes that took them where they needed to go in terms of energy saving. These included enhancements in steam systems and fuel switch modifications. However they needed more than that.

The second game changer was tracking down key members of the old workforce and listening to them too. This combination enabled them to finally hire back 92% of the original labour force under the same terms and conditions – and still make a profit (the other 8% had moved on elsewhere or retired). The combined energy savings produced a payback plan of 5.25 years. Three years into the project their capital investment of $15 million had already clawed back the following electricity savings.

  • Evaporator Temperature Control $2,245,000
  • Hot Water Heat Recovery $2,105,000
  • Paper Machine Devronisers $1,400,000
  • Increased Boiler Output $1,134,000
  • Paper Machine Modifications; $761,000
  • Motive Air Dryer $610,000
  • Accumulator Savings $448,000
  • Densified Fuels Plant $356,000

In terms of carbon dioxide produced, the Fambeau River Paper Mill?s contribution dropped from 1 ton to 600 pounds.

How well do you know where your company?s energy spend is concentrated, and how this compares with your industry average; could you be doing better if you innovated, and by how much? Get these questions answered by asking ecoVaro how easy it could be to get on top of your carbon metrics. This could cost you a phone call and a payback on it so rapid it’s not worth stopping to calculate.

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