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

Check our similar posts

Reduce Cost and Improve Productivity

Whether the economy is in a downturn or not, management will always aim for a more cost effective IT solution. If your current IT infrastructure is hurting your profitability, our expertise is both ‘tested and proven”.? Also “bleeding edge” solutions in the industry will enable us to find inexpensive alternatives for you.

For instance, have you started to wonder whether having a constantly growing number of servers, many of which are underutilised, is really the norm? Well, that used to be the case. However, with the advent of virtualisation and replication, that expensive exercise is steadily becoming a thing of the past.

By implementing solutions powered by these two technologies, organisations can now manage excess storage capacities and hardware resources by performing simpler processes at lesser costs. In addition to that, using the same pair of technologies, companies can also decrease the downtime suffered during maintenance and upgrades.

Thus, at the end of the day, not only do companies stand to reduce expenditures, they can also boost revenues as a result of increased productivity time.

Do we still have other IT solutions that tackle a different set of problems but arrive at the same outcome, i.e. reduced costs + improved productivity = higher profits? You bet we do.

Basically, this is how we’ll help your company arrive at the same winning formula:

  • Provide insights as to where and when changes have to be made. Oftentimes, initiatives to reduce cost and improve productivity are not preceded by the appropriate study especially as with regards to their impact on all departments in the organisation. This usually results in unnecessary duplication of resources, a sure way to increase costs instead.
  • Consolidate and automate. We’ll work within your budget in finding ways to consolidate your applications, hardware, storage, databases, and processes. Then we’ll integrate automation practices to simplify management and maintenance of all these assets. This will substantially free not only your IT infrastructure but also your IT staff, giving them more opportunities to innovate.
  • Create an innovative environment. One of the benefits you gain in having room to innovate is the potential to discover new ways to drive costs even further. A fraction of your savings can then be used to develop even better IT solutions, thus creating a productive cycle: IT solutions > savings and innovation > better IT solutions. Our role is to help you harness your potentials to keep that cycle running.
  • Work to reduce carbon footprint in all your procedures. By ensuring that energy consumption is brought to a minimum in every step you take, you can rest assured that costs have only one way to go – down. Check out our Energy Management Software ecoVaro.

Find out how we can increase your efficiency even more:

Contact Us

  • (+353)(0)1-443-3807 – IRL
  • (+44)(0)20-7193-9751 – UK
Saving Energy Step 1 ? Implementing a Management System

There has been much hype down the years regarding whether management is art or science. Thankfully, where people are concerned the pendulum has swung away from standard times in sweatshops in the west. However, when it comes to measuring physical things like harvest per square meter and the amount of energy consumed there is no substitute for scientific measurement, and this implies a system.

Managing energy cost and consumption down is like any other strategy. American engineer / statistician / management consultant W. Edwards Demming may have passed on in 1993. However he was as right as ever when he said:

  1. When people and organizations focus primarily on quality, this tends to increase and costs fall over time.
  1. However, when people and organizations focus primarily on costs, costs tend to rise and quality declines over time.

Demming believed that 90% of organizational problems arise from systems we put in place ourselves. This can be because we are so accustomed to them that we fail to notice when they are no longer relevant. The currently prevailing laissez faire towards energy is a case in point. What is managed improves and what is not, deteriorates. We know this. Let us take a look at how to apply this principle to energy management.

First, you need to get the subject out the closet and talk about it. How often do you do this is your boardroom, and how does energy rank against other priorities? Good governance is about taking up a position and following through on it. Here is a handy checklist you may like to use.

  • Do we use a consistent language when we talk about energy? Is it electricity, or carbon emitted (or are we merely fretting over cost).
  • How well engaged are we as a company? Looking up and down and across the organization are there points where responsibility stops.
  • How well have we defined accountability? Do we agree on key performance areas and how to report on them.
  • Are we measuring energy use at each point of the business? When did we last challenge the assumption that ?we’re doing okay?.
  • Have we articulated our belief that quality is endless improvement, or are we simply chasing targets because someone says we should.

A management system is a program of policies, processes and methods to ensure achievement of goals. The next blog focuses on tools and techniques that support this effort.

Mobile Security

Today’s advanced enterprises make extensive use of mobile devices in order for team members to exchange information, collaborate, and carry out business whenever and wherever they need to. BlackBerries, iPhones, Google Phones, and other smartphones as well as PocketPCs and PDAs are now allowed wireless remote access to the enterprise network.

As a result, they introduce additional vulnerabilities into the system.

  • Bluetooth exploits and unencrypted passwords can allow malicious individuals to gain access to private information.
  • Various wireless technologies that have substantially simplified the task of transferring data have provided openings for malicious code. In addition, the diversity of these wireless technologies combined with the constrained environments of these devices have made it difficult to come up with an all-in-one solution.
  • All PocketPCs, PDAs and smartphones can be synchronised with PCs and laptops, giving malware an entry point into computers and networks. Memory cards are guilty of this too.
  • VoIP, which are usually unencrypted, allow other people to perform unauthorised capture and recording of private conversations.

Mobile security is still an emerging discipline. Because of this, many organisations that allow members’ mobile phone access into the network don’t actually have a specific security policy for such devices.

That’s why we’re here to help. We’ll conduct a thorough evaluation of your security policies and systems in relation to mobile devices and seal gaps we spot along the way. If you don’t have the needed policies or if what you have needs an overhaul, we’ll set everything up (including the needed applications and infrastructure) for you.

Once we’ve got everything in place, you won’t have to worry about the vulnerabilities mentioned earlier. In addition to that, your organisation will already be capable of preventing the following:

  • Access to company information when the phone ends up in the hands of anyone other than the authorised user.
  • Being billed for phone usage due to virus activity
  • Unauthorised phone activity monitoring through spyware
  • Other disruptions caused by mobile-based malware

Other defences we’re capable of putting up include:

Ready to work with Denizon?

Contact Us Today