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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How Energy Management Software Benefits Your Business

We’re in an era of price volatility in gas and electricity prices, coupled with greater scrutiny on the environmental impact of businesses in their day-to-day operations. According to the Department of Energy & Climate Change, the average SME can slash its energy bill by 18-25% simply by installing energy efficiency solutions in their facility.

Are you looking to improve energy use in your business? Prevent wastage, track consumption, identify opportunities to save on energy and reduce your carbon footprint while at it? It can be a daunting process to do it all manually. Taking those meter readings, preparing spreadsheets and combing through quotes and energy bills to validate them – this is not something you should be enduring in this day and age. Not when there are dedicated systems built for the task. That’s where Energy Management Software (EMS) comes in.

Importance Of Energy Management Software

Wasted energy = Wasted money

Failing to improve energy efficiency is costing SMEs loads of funds, with it coming to between £5,801 and £12,109 of missed annual savings for individual businesses. These are 18% – 24% of their energy costs. Where do you stand?

Take timers and thermostats for instance. When not properly set and controlled, or even simply forgetting to turn them down when not in the room, it can easily lead to unnecessary costs. How often do your staff forget to turn off the air conditioning when they leave the meeting rooms? Do you account for weekends or bank holidays when setting the controls of the AC? Mistakes like turning the temperature high on the thermostat to “quickly warm the room” are common, yet heating costs go up by about 8% with every 1°C rise.

There are installations that you can make to minimize wastage. For example, the Chinese Contemporary Arts Centre in Manchester is able to save £4,363 annually just by having a £100 timer installed to its heating system.

Some energy saving measures won’t even cost you a penny. For instance, did you know that you can save up to 30% of your heating costs simply by preventing cold air from entering the building? This means not keeping the doors just open for convenience. So how can you find points of weakness and areas of improvements in your facility? Install an EMS.

While businesses vary from one industry to the next, energy management basically boils down to:

Metering systems where the consumption is recorded
Determining how much energy can be saved by identifying opportunities for this
Implementing policies and changing existing systems to take advantage of these opportunities
Tracking progress after the improvements have been made

Benefits Of EMS For Your Business

Data Acquisition – Where accuracy and reliability matters

Energy data comes from different angles and formats. From the building automation systems and IoT devices that have been set up, bills sent in by the utility company to the spreadsheets needed to analyse them – what if you had it all from one point of reference? The EMS gives you a “bird’s eye view” of all your energy data from one interface. It collects the data from any system – and being cloud-based, is accessible from anywhere in the world.

The ecoVaro data loggers can be connected with the Wi-Fi network of the facility or function independently, depending on your specific requirements. They monitor readings 24/7, retaining the data even when they have been powered off. The end-to-end encryption assures you of the security of the information that is being obtained.

Integrating the EMS into the existing systems will simplify the data collection process, and even for the cases where there isn’t a direct method transferring the data into the system, the setup wizards that come with the EMS allow you to prepare the required data and import it.

Data Analysis: From consumption, energy leaks to areas of improvement

The first step is accurately collecting the data. The next step is making sense of it. The analysis modules with the EMS allow you to monitor the energy consumption of the facility in real-time.

The energy data is displayed in engaging graphics that are easy to understand at a glance. The dashboard setup, with its customised layout, enables you to monitor the performance of the specific information you want, toggling through usage and savings data, to the meters and sites that are being tracked. With the ecoVaro Energy Management Software, you get Consumption Charts, Regression Charts, Cusum Charts and Heatmaps right to the submeter level. This information can be broken down into 15-minute durations, with the daily, weekly and monthly consumption reports.

Getting everyone on board

Making changes to company-wide energy policies needs to have the different parties on board – from the energy manager in charge of crunching the numbers and presenting the information, the CFO of the business, the staff running day-to-day operations, all through to plant operators for those in industries. An easy mode of communication is needed, that will be understood and availed in reports that can be shared with the relevant parties in the organization. The graphical displays that come with the EMS enable actionable information to be displayed in a simplified manner – that way all members of the business or organization will be able to comprehend it.

Meet your Energy Goals

The baseline that is created in the EMS is used as a standard when assessing the impact of future changes to the energy consumption. Using the information that has been obtained, the management can set up energy saving policies and implement changes, and track KPIs (key performance indicators) along the way. For instance, the market research company DJS Research installed a timer switch that turns off their two water coolers when they aren’t in use. This action saves them £144 annually, and had already paid for itself within 35 days.

You will be in a position to assess the actions that provide your business with the best ROI over time, monitoring the progress and verifying the savings from one central dashboard. Cutting costs here will enable you to divert the funds to other areas of your business, including promotions, marketing, and product development.

For businesses in the energy sector- including electric, oil and gas plants, they specifically need carbon emission reports, to pinpoint areas where the building’s energy efficiency can be improved. ecoVaro EMS allows you to set alarms and KPIs in the facility for issues to be identified and resolved immediately they crop up.

Turn to ecoVaro

EMS systems are used across the board – from optimising energy use in hotel rooms and hospitals, mapping out usage patterns for those in the agriculture and supply chain niches, running facilities for utility providers, all through to increasing the efficiency of equipment operation for business in the food and beverage sector. Want to learn how you can cut down your energy bills and make your business more eco-friendly? EcoVaro’s team is ready to get you started.

Is the GDPR Good or Bad News for Business

The European Union?s General Data Protection Act (GDPR) is a new data authority coming into force on 25 May 2018. It replaces the current Data Protection Directive 95/46/EC, while extending the remit to include the export of personal data outside the EU. It aims to give EU citizens and residents living there more control over their personal information. It also hopes to make regulatory compliance simpler for participating businesses.

The Broad Implications for Business
The GDPR puts another layer of accountability on businesses falling within its remit. It requires them to implement ?comprehensive but proportionate governance measures? including recording how they make decisions. The long-term goal is to reduce privacy infringements. In the short run, businesses without good governance may find themselves writing new policies and procedures.

Article 5 of the European Union?s General Data Protection Act lays down the following guidelines for managing personal data. This shall be ?
? Processed transparently, fairly, and lawfully
? Acquired for specific, legitimate purposes only
? Adequate, relevant and limited to essentials
? Not used for any other, incompatible purpose
? However it may be archived in the public interest
? Kept up to date with all inaccuracies corrected
? Ring-fenced when the information becomes irrelevant
? Adequately protected against unauthorised access
? Stored in a way that prevents accidental loss
Furthermore, affected businesses shall appoint a ?controller responsible for, and able to demonstrate, compliance with the principles.?

Implementing Accountability and Governance
The UK Information Commissioner?s Office has issued guidelines regarding provisions to assure governance and accountability. These are along the lines of the ?don’t tell me, show me? management approach the office has generally been following. In summary form, a business, and its controller must:
? Implement measures that assist it to ensure demonstrated compliance
? Maintain suitable, relevant records of personal data processing activities
? Appoint a dedicated data protection officer if scale makes this appropriate
? Implement technologies that ensure data protection by design
? Conduct data protection assessments and respond to results timeously

Implementing the General Data Protection Act in Ireland
The Irish Data Protection Commissioner has decided it is unnecessary to incorporate the GDPR into Irish law, since EU regulations have direct effect. The office of the Commissioner is working in tandem with data practitioners, and industry and professional bodies to raise awareness in business through 2017. It has produced a document detailing what it considers the essentials for business compliance. Briefly, these pre-requisites are:
? Ensure awareness among key personnel, and make sure they incorporate the GDPR into their planning
? Conduct an early assessment of quality management gaps, and budget for additional resources needed
? Do an audit of personal data held, to determine the origin, the necessity to hold it, and with whom shared
? Inform internal and external stakeholders of the current status, and your future plans to implement the GDPR
? Examine current procedures in the light of the new directive. Could you ?survive? a challenge from a data subject?
? Determine how you will process requests for access to the data in the future from within and outside your organization
? Assess how you currently obtain customer consent to store their data. Is this “freely given, specific, informed and unambiguous”?
? Find how you handle information from underage people. Do you have systems to verify ages and obtain guardian consent?
? Implement procedures to detect, investigate, and report data breaches to the Data Protection Commissioner within 72 hours
? Implement a culture of always assessing the effect on individual privacy before starting new initiatives

So Is the GDPR Good or Bad for Business
The GDPR should be good news for business customers. Their personal data will be more secure, and they should see their rate of spam marketing come down. The GDPR is also good news for businesses currently investing resources to protect their clients? interests. It could however, be bad news for businesses that have not been focussing on these matters. They may have a high mountain to climb to come in line with the GDPR.
Disclaimer: This article is for information only and not intended as a comprehensive guide.

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A Small External Enterprise Development Team is Cheaper than Your Own

Time is money in the application development business. We have to get to market sooner so someone else does not gazump us, and pip us at the post. We increase the likelihood of this with every delay. Moreover, the longer your in-house team takes to get you through the swamp, the higher the project cost to you.

Of course, in theory this should not be the case. Why bring in a team from outside, and pay more to support their corporate structure? Even going for a contract micro team ought not to make financial sense, because we have to fund their mark-up and their profit taking. Our common sense tells us that this is crazy. But, hold that thought for a minute. What would you say if a small external enterprise development team was actually cheaper? To achieve that, they would have to work faster too.

The costs of an Enterprise Internal Development Team

Even if you were able to keep your own team fully occupied ? which is unlikely in the long term ? having your own digital talent pool works out expensive when you factor in the total cost. Your difficulties begin with the hiring process, especially if you do not fully understand the project topic, and have to subcontract the hiring task.

If you decide to attempt this yourself, your learning curve could push out the project completion date. Whichever way you decide to go, you are up for paying advertising, orientation training, technical upskilling, travel expenses, and salaries all of which are going to rob your time. Moreover, a wrong recruitment decision would cost three times the new employee?s annual salary, and there is no sign of that changing.

But that is not all, not all by far. If want your in-house team to keep their work files in the office, then you are going to have to buy them laptops, plus extra screens so they can keep track of what they are doing. Those laptops are going to need desks, and those employees, chairs to sit in. Plus, you are going to need expensive workspace with good security for your team?s base.

If we really wanted to lay it on, we would add software / cloud costs, telephony, internet access, and ongoing technical training to the growing pile. We did a quick scan on PayScale. The median salary of a computer programmer in Ireland is ?38,000 per year and that is just the beginning. If you need a program manager for your computer software, their salary will be almost double that at ?65,000 annually.

Advantages of R&D outsourcing

The case for a small externally sourced enterprise development team revolves around the opportunity cost ? or loss to put in bluntly ? of hiring your own specialist staff for projects. If you own a smaller business with up to 100 people, you are going to have to find work for idle digital fingers, after you roll out your in-house enterprise project. If you do not, you head down the road towards owning a dysfunctional team lacking a core, shared objective to drive them forward.

Compared to this potential extravagance, hiring a small external enterprise development team on an as-needed basis makes far more sense. Using a good service provider as a ?convenience store? drives enterprise development costs down through the floor, relative to having your own permanent team. Moreover, the major savings that arise are in your hands and free to deploy as opportunities arise. A successful business is quick and nimble, with cash flow on tap for R & D.