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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The Rights of Individuals Under The General Data Protection Regulation

The General Data Protection Regulation or GDPR is a European Union law reinforcing the rights of citizens concerning the confidentiality of their information, and confirming that they own it. We thought it would be interesting to examine the GDPR effective 25 May 2018 from an Irish citizen?s perspective. This article is a summary of information on the Data Protection Commissioner?s website, but as viewed through a businessperson?s lens.

How the Office Defines Data Protection

The Office believes that organisations receiving personal details have a duty to keep them private and safe. This applies inter alia to information that individuals supply to government, financial institutions, insurance companies, medical providers, telecoms services, and lenders. It also applies to information provided when they open accounts.

This information may be on paper, on computers, or in video, voice, or photographic records. The true owners of this information, the individuals have a right:

To make sure that it is factually correct
To the assurance that it is shared responsibly
That all with access only use it for stated purposes

Any organisation requesting personal information must state who they are, what the information is for, why they need to have it, and to whom else they may provide it.

Consumer Rights to Access Their Personal Information

Private persons have a right under the GDPR to a copy of all their information held or processed by a business. The regulation refers to such businesses as ?data controllers? as opposed to owners, which is interesting. They have to provide both paper and digital data, and ‘related information?.

Data controller fees for this are discretionary within limits. The request may be denied under certain circumstances. The data controller may release information about children to parents and guardians, only if it considers a minor too young to understand its significance. Other third parties such as attorneys must prove they have consent.

Consumer Rights to Port Their Data to Different Services

Since the personal information belongs to the individual, they have a right not only to access it, but also to copy or move it from one digital environment to another. The GDPR requires this be ?in a safe way, without hindrance to usability?. An application could be a banking client that wants to upload their transaction history to a third party price comparison website.

However, the right to data portability only applies to data originally provided by the consumer. Moreover, an automated method must be available for porting. Data controllers must release the information in an open format, and may not charge for the porting service.

Consumer Rights to Complain About Personal Data Abuse

Individuals have a right under the General Data Protection Regulation to have their information rectified if they discover errors. This right extends to an assurance that third parties know about the changes – and who these third party entities are. Data controllers must respond within one month. If they decline the request, they must inform the complainant of their right to further remedial action.

If a data controller refuses to release personal information to the owner, or to correct errors, then the Data Protection Office has legal power to enforce the consumer?s rights. The complainant must make full disclosure of the history of their complaint, and the steps they have taken themselves to attempt to set things right.

Further Advice on Getting Things Ready for 25 May 2018

The General Data Protection Regulation has the full force of law from 25 May 2018 onward, and supersedes all applicable Irish laws, regulations, and policies from that date. We recommend incorporating rights of data owners who are also your customers into your immediate plans. We doubt that forgetting to do so will cut much sway with the Data Commissioner. Remember, you have one month to respond to consumer requests, and only one more month to close things out subject to the matter being complex.

Green Business!

Carbon emissions reduction has evolved beyond simply good citizenship to being a business tool. Implementing ?green? initiatives is now a competitive weapon which defines real business opportunities and bottom line savings that can contribute significant financial value to the organisation while meeting demanding customer requirements for sustainable and low-carbon products.

Energy efficiency is a low cost resource for achieving carbon emissions reduction. Better energy efficiency simply translates to lesser carbon emissions and less energy usage which translates into saved costs.

Reduction of an organisations carbon footprint is each and everyone?s responsibility. Human activities are the key responsibility for the release of greenhouse gas emissions into the atmosphere. These include usage of electricity generated from fossil fuel, heating or driving.

At the corporate level, various measures can be instigated to increase energy efficiency. Some of these can be, having zone lighting with sensors to minimise unnecessary office lighting, timers on large IT equipment, promoting energy efficient behaviour in the office, asking staff to switch off and unplug appliances when not in use and minimising staff travel.
At the individual level; it is the small habits that count; cultivating the habit of switching off unnecessary lights, plugging out appliances that are not in use, using video conferencing or online chatting instead of having to travel to meetings, using public transport instead of taking a taxi/ personal car and using energy efficient cars.

All these initiatives assist organisations in their corporate social responsibility reports and play a role in sustainability rankings which is instrumental to customers who are increasingly considering sustainability rankings in investment decisions, while achieving the goal of cost reduction internally.

What is work force management?

For organisations to ensure they provide the right service. In order to do they need to assign the right employees with the right skills to the right job at the right time to meet demand.

Workforce Management Background

Workforce management (WFM) is a strategy used by companies to increase their efficiency and performance. It entails all activities aimed at maintaining a steady output, such as human resource management, forecasting, field service management, budgeting, scheduling, performance and training management, analytics, recruitment and data collection.

Workforce management utilizes a unique set of performance enhancing tools and software to bolster corporate management, workers, and other categories of managers and supervisors in the manufacturing team, distribution, transportation, and retail operators. This is sometimes called HRM systems, or part of ERP systems, or workforce asset management.

Unlike the conventional outlay that only needed staff scheduling to improve time management, workforce management is now all-inclusive and demand-oriented to optimize staff scheduling. Apart from focusing on demand-orientation and optimization, workforce management also incorporates:

Estimating the workload and resource utilisation
Job scheduling
Management of working times and accounts
Monitoring the process of workforce management

Each task should be clearly defined and performed efficiently based on set engineering standards and methods of optimizing each task as much as possible. Out of this framework and demand based forecasts, workers are scheduled and given tasks, performance measured, give feedback, and incentives computed and paid.

Workforce management is an entire scheme aimed at building the capacity of workers, increase productivity and client relations, and where possible reduce labour costs.

What is Mobile Workforce Management (MWM)

Mobile workforce management (MWM) is a software-based service used to oversee employees outside of the institution?s premises; MWM sometimes refers to the field teams. Mobile workforce management encompasses all activities done to monitor and schedule the field workforce.

The entire process includes procurement, management and using mobile devices, applications and computer software. Related support services like tracking, logging, dispatch, productivity management, and other types of communication are also to make it efficient.

Companies do not have the same needs and MWM firms need to fine-tune their software and devices to sufficiently bridge this gap. Some providers are suited only to a specific type of company because of specialization, like managing the electric grid. This experience makes the MWM company suited to provide applications that are relevant to the company for them to continue operating smoothly and efficiently.

With the increase in mobile devices, applications, secured wireless networks and virtual desktop, there comes a stream of opportunities for small and medium-sized businesses (SMB) and other ventures. Nevertheless, a mobile workforce needs better controls, security and support, as well as a functioning mobile workforce management strategy.

MMS (managed mobility services) is often used interchangeably with MWM, but they should not be confused. MWM is related to software and applications used by mobile and computer devices to manage on-field work while MMS focuses on enterprises, and is like a way of keeping in touch with the company, other employees, and linking the mobile while at work to servers and the database.

Benefits of Mobile Workforce Management

MWM allows the utilization of technology to drive productivity. Here are the top five advantages of MWM..

Customer focused. The customer is the backbone of any business. The team needs to keep in touch with up-to-date information about every interaction. In the end, better client relation makes sure that the customer is always happy.
Information has the power to build or destroy. A cloud-based system is easier to manage and can help with collection of data which is used to make business decisions. This can help cut costs, increase the workforce support, and identify areas where polishing needs to be done.
Improved efficiency. Mobile workforce management is majorly used in taskforce allocation. If the company adopts a cloud-based work force management system, allocation is done automatically saving a lot of time.
Increased revenue. Each business seeks to maximize the profit. With cloud-based mobile workforce management some operations like task management, data analysis, customer communication, reporting, and performance monitoring can be automated. This reduces the costs incurred for multiple applications and saves time.
Ease of communication. Communication is vital. Constant communication with customers drives sales rates and everyone loves that. Quick communication will help customers solve their problems faster and get instant feedback.

Additional WFM benefits

Other WFM benefits are:

Operations are made efficient as all complex processes are automated.
Employers learn more about worker engagement, productivity and attendance, allowing them to modify training, coaching and processes aimed at streamlining performance.
Automation and easy manipulation of data to improve HR, productivity and slash administrative costs.
It increases employee productivity by reducing absenteeism and late arrivals.
Boosts the morale of employees by encouraging transparency and facilitating manager-employee communication.
WFM analyzes market and schedule requirements to pick the right employee with the best set of skills for a certain task.

Companies which embrace workforce management and mobile workforce management have a higher operational efficiency. They have lower operational costs and limit manual work as much as possible