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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Authentication and Access Control

Threats to your data can come from external or internal sources.

  1. There are individuals who don’t have the authorisation but are driven by malicious intentions to gain access to certain information. This may refer to individuals who already belong to your organisation (but don’t have the necessary access rights) as well as those who don’t.
  2. There are individuals who have both the authorisation and, unfortunately, the malicious intentions over certain information.
  3. Finally, there are individuals who have the authorisation, no malicious intentions, but have accidentally exposed the information in question to those without the proper authority.

While curbing threats 2 and 3 would require other methods, threat #1 can be countered if the right authentication and access control systems are in place.

Here’s what we can do for you:

  • Work with your key personnel to determine who gets access to what.
  • Help you decide whether a single factor or a two-factor authentication (2FA) is appropriate for your organisation and recommend which factors are most suitable. Login methods may include but are not limited to the following:
    • biometric devices
    • Kerberos tickets
    • mobile phones
    • passwords
    • PKI certificates
    • proximity cards
    • smart cards
    • tokens
  • Install the necessary infrastructure needed for the factors chosen. For instance, if you opt to use biometrics, then biometric scanners will be installed. We’ll make sure that the authentication terminals are situated in places where achieving optimal traffic and work flow has been taken into consideration.

Other defences we’re capable of putting up include:

Could Kanban Be?Best for Knowledge Workers?

Knowledge Workers include academics, accountants, architects, doctors, engineers, lawyers, software engineers, scientists and anybody else whose job it is to think for a living. They are usually independent-minded people who do not appreciate project managers dishing out detailed orders. Kanban project management resolves this by letting them choose the next task themselves.

The word ?Kanban? comes from a Japanese word meaning ?billboard? or ?signboard?. Before going into more detail how this works let’s first examine how Japanese beliefs of collaboration, communication, courage, focus on value, respect for people and a holistic approach to change fit into the picture.

The Four Spokes Leading to the Kanban Hub

  1. Visualise the Workflow ?You cannot improve what you cannot see. The first step involves team members reducing a project to individual stages and posting these on a noticeboard.
  2. Create Batches ? These stages are further reduced to individual tasks or batches that are achievable within a working day or shift. More is achievable when we do not have to pick up where we left off the previous day.
  3. Choose a Leader the Team Respects – Without leadership, a group of people produces chaotic results. To replace this with significant value they need a leader, and especially a leader they can willingly follow.
  4. Learn and Improve Constantly ? Kaizen or continuous improvement underpins the Japanese business model, and respects that achievement is a step along the road, and not fulfilment.

The Kanban Method in Practice

Every Kanban project begins with an existing process the participants accept will benefit from continuous change. These adjustments should be incremental, not radical step-changes to avoid disrupting the stakeholders and the process. The focus is on where the greatest benefits are possible.

Anybody in the team is free to pull any batch from the queue and work on it in the spirit of collaboration and cooperation. That they do so, should not make any waves in a culture of respect for people and a holistic approach to working together. All it needs is the courage to step out of line and dream what is possible.

The Kanban Project Method ? Conclusions and Thoughts

Every engine needs some sort of fuel to make it go. The Kanban project management method needs collaboration, communication, courage, focus on value, respect for people and a holistic approach to work. This runs counter to traditional western hierarchies and probably limits its usefulness in the West.

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IT Systems Implementation

Are you ready to find out how your newly accepted IT system fares in the real world? Although a rigorous Acceptance testing process can spot a wide spectrum of flaws in a newly constructed IT system, there is no way it can identify all possible defects. The moment the IT system is delivered into the hands of actual end users and other stakeholders, it is effectively stepping out of a controlled and secure environment.

Thus, it is during this phase wherein issues having direct impact on the business can arise.

It is our duty to ensure that the Systems Implementation phase is carried out as thoroughly, professionally, and efficiently as possible.

Thoroughly, because we need to include all relevant data and other deliverables, eliminate hard-to-detect miscalculated results, and substantially reduce the probability of business and mission critical issues popping up in the future;

Professionally, because it is the best way to address the sensitive process of turning over a new system to users who have gotten used to the old one;

And efficiently, because we want to minimise the duration over which all stakeholders have to adapt to the new system and allow them to move on to the process of growing the business.

Preparation

Louis Pasteur once said, “Luck favours the mind that is prepared.”

While we certainly won’t leave anything to chance, we do put substantial weight on the Preparation stage of Systems Implementation. We’re so confident with the strategies we employ in Preparation, that we can assure you of an utterly seamless Deployment and Transition phase.

By this we mean that issues that may arise during Deployment and Transition will be handled smoothly and efficiently because your people will know exactly what to do.

Here’s how we will prepare your organisation for Deployment:

  • Identify all key players for the Systems Implementation phase and orient them on their specific roles. We’ll make sure they know what possible hitches may come their way and how to deal with them.
  • Identify all end users and their corresponding functions, then assign appropriate access rights.
  • Draw multi-layered contingency plans to capture and address each possible concern that may crop up during Deployment.
  • Prepare a systematic step-by-step procedure and checklist for the entire Deployment stage. Both of them should have been copied from a similar procedure and checklist used in the Acceptance testing phase.
  • Make all stakeholders understand the conditions required before Deployment can commence.
  • Set the appropriate environment so that all stakeholders know what to expect and when to expect them the moment Deployment commences.
  • Prepare Technical Services and Technical Support personnel for the gruelling mission ahead.
  • Make sure all communication processes are well coordinated so that everyone affected will know who to contact and how to get in touch with them when a problem arises.
  • Plan and schedule training sessions so that they can be conducted “just in time”. Training sessions conducted way ahead of Deployment are often useless because the trainees tend to forget about what they learned when the time comes to apply them. Similarly, training sessions conducted way after Deployment also become useless because trainees are seldom able to internalise instructions delivered during crash courses.

Deployment

There are two sets of issues to keep an eye on during Deployment:

  1. Issues directly related to the technology itself, e.g. application functionality and data integrity, and
  2. Issues emanating from the end users, i.e., their unwillingness to use the new system. One reason may be because they find the interface and procedures too confusing. Another would be due to other inconveniences that come with adapting to a new set of procedures.

Despite all the meticulous scrutiny employed during Acceptance testing, there are just some problems that are made obvious only during Deployment. Issues belonging to the first set are dealt with easily because of the plans and procedures we put in place during the Preparation stage. As an added measure, our team will be on hand to make sure contingency plans are executed accordingly.

While the second set of issues is often neglected by many IT consultancy companies, we choose to meet it head on.

We fully understand that end users are most sensitive to the major changes that accompany a new system. It is precisely for this reason why our training activities during Deployment are designed not only to educate them but also to make them fully appreciate the necessity of both the new system and the familiarisation phase they will need to go through.

The faster we can bring your end users to accept the new system, the faster they can refocus on your company’s business objectives.

Here’s what we’ll do to guarantee the smoothest Deployment process you’ve ever experienced.

  • Employ the procedure and checklist formulated during the Preparation stage.
  • Ensure all end users are well acquainted with any additional tasks they would need to perform (e.g. filling up manual logs).
  • Assess which legacy systems can still be used alongside the new technology and which ones have to be retired.
  • Supervise the installation and optimal configuration of all supporting hardware and software to make sure the likelihood of errors originating from them are brought to near-zero levels.
  • Supervise the installation and optimal configuration of the products themselves.
  • Carry out data migration tasks if necessary.
  • Organise and oversee parallel runs to check for data and report inconsistencies.
  • Conduct training sessions in a professional and well-timed manner to eliminate end-users’ feelings of agitation and to take advantage of memory absorption and retention duration as with regards to their assigned duties and responsibilities.

Transition

Do you often feel uneasy whenever the reins to a newly purchased IT system are handed over to you? Perhaps there are some issues that you feel haven’t been fully settled but, at the same time, find it too late to back out, having already invested so much time and resources.

Alright, so maybe the thought of “backing up” never crossed your mind. However, the concern of being “not yet ready” is raised by many organisations towards the tail end of most Deployment stages. This usually drags the Deployment stage into a never-ending process.

Our team of highly experienced specialists will make sure you reach this point with utmost confidence to proceed on your own.

To wrap up our comprehensive IT Systems Implementation offering, we’ll take charge of the following:

  • Verify that all deliverables, including training materials and other technical documentation, are accomplished and expected outcomes are realised.
  • Make sure all technical documentation are placed in a secure and accessible location.
  • Institute best practices to ensure the IT system becomes fully utilised and to reduce its exposure to avoidable risks.
  • Establish open communication lines with the Technical Support team to enable quick resolution of issues.
  • Ensure complete knowledge transfer has been fully achieved so that your people will spend less time calling Technical Support and more on operations contributory to business growth.

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