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

Align IT Investments With Organization Goals

While some organisation leaders loathe spending on IT, a growing number are already convinced of the necessity of investing in it. Unfortunately, a substantial fraction of those convinced to pursue IT investments are misguided as to which initiatives are really contributory to reaching their organisation’s goals.

In the end, many of their purchases either end up underutilised or become white elephants altogether. There are also those difficult to spot – IT purchases that do become integrated into daily operations but have little effect on the organisation’s growth, positioning, profitability, or efficiency.

If a purchase is to cost your company a fortune, then its positive impact on established company objectives should reflect accordingly. But how would you know it would? You can’t hope to foresee all its benefits especially if the IT solution is still quite new to you.

Our job is not only to identify the strengths of an IT system but also to determine whether these strengths are at all useful to your organisation’s thrusts.

Basically, here’s what we’ll do:

  • Conduct a rigorous analysis of your organisation to determine the specific and overall impact of certain IT solutions. We’ll be looking for areas where the effects of IT can result in the most rapid reduction of costs and, at the same time, drive the organisation in the direction of its established goals.
  • Propose cohesive best-of-breed solutions in line with the results of our analysis. Our familiarity with the IT landscape and our extensive selection of contacts in the industry will allow us to conduct insightful picks from a vast field of choices.
  • Establish best practices to make sure IT investments are optimally utilised.
  • Perform periodic reviews to ensure practices and processes are still in line with the established goals.

Find out how we can increase your efficiency even more:

Contact Us

  • (+353)(0)1-443-3807 – IRL
  • (+44)(0)20-7193-9751 – UK
Using Pull Systems to Optimise Work Flows in Call Centres

When call centres emerged towards the end of the 20th century, they deserved their name ?the sweatshops of the nineties?. A new brand of low-paid workers crammed into tiny cubicles to interact with consumers who were still trying to understand the system. Supervisors followed ?scientific management? principles aimed at maximising call-agent activity. When there was sudden surge in incoming calls, systems and customer care fell over.

The flow is nowadays in the opposite direction. Systems borrowed from manufacturing like Kanban, Pull, and Levelling are in place enabling a more customer-oriented approach. In this short article, our focus is on Pull Systems. We discuss what are they, and how they can make modern call centres even better for both sets of stakeholders.

Pull Systems from a Manufacturing Perspective

Manufacturing has traditionally been push-based. Sums are done, demand predicted, raw materials ordered and the machines turned on. Manufacturers send out representatives to obtain orders and push out stock. If the sums turn out wrong inventories rise, and stock holding costs increase. The consumer is on the receiving end again and the accountant is irritable all day long.

Just-in-time thinking has evolved a pull-based approach to manufacturing. This limits inventories to anticipated demand in the time it takes to manufacture more, plus a cushion as a trigger. When the cushion is gone, demand-pull spurs the factory into action. This approach brings us closer to only making what we can sell. The consumer benefits from a lower price and the accountant smiles again.

Are Pull Systems Possible in Dual Call Centres

There are many comments in the public domain regarding the practicality of using lean pull systems to regulate call centre workflow. Critics point to the practical impossibility of limiting the number of incoming callers. They believe a call centre must answer all inbound calls within a target period, or lose its clients to the competition.

In this world-view customers are often the losers. At peak times, operators can seem keen to shrug them off with canned answers. When things are quiet, they languidly explain things to keep their occupancy levels high. But this is not the end of the discussion, because modern call centres do more than just take inbound calls.

Using the Pull System Approach in Dual Call Centres

Most call centre support-desks originally focused are handling technical queries on behalf of a number of clients. When these clients? customers called in, their staff used operator?s guides to help them answer specific queries. Financial models?determined staffing levels and the number of ?man-hours? available daily. Using a manufacturing analogy, they used a push-approach to decide the amount of effort they were going to put out, and that is where they planted their standard.

Since these early 1990 days, advanced telephony on the internet has empowered call centres to provide additional remote services in any country with these networks. They have added sales and marketing to their business models, and increased their revenue through commissions. They have control over activity levels in this part of their business. They have the power to decide how many calls they are going to make, and within reason when they are going to make them.

This dichotomy of being passive regarding incoming traffic on the one hand, and having active control over outgoing calls on the other, opens up the possibility of a partly pull-based lean approach to call centre operation. In this model, a switching mechanism moves dual trained operators between call centre duties and marketing activities, as required by the volume of call centre traffic, thus making a pull system viable in dual call centres.

Contact Us

  • (+353)(0)1-443-3807 – IRL
  • (+44)(0)20-7193-9751 – UK
Operational Reviews

IT OPERATIONAL REVIEWS DEFINED
An IT operational review is an in-depth and objective review of an entire organisation or a specific segment of that organisation. It can be used to identify and address existing concerns within your company such as communication issues between departments, problems with customer relations, operating procedures, lack of profitability issues, and other factors that affect the stability of the business.
Operational reviews allow the organisation members to evaluate how well they are performing, given that they perform appropriately according to the procedures set by them, allocating their resources properly, and performing such tasks within time frame set and using cost-effective measures. More importantly, it also shows your company how well it is prepared to meet future challenges.
Simply put, the goals of an operational review are to increase revenue, improve market share, and reduce cost.

THE BENEFITS OF AN IT OPERATIONAL REVIEW
The main objective of IT operational reviews is to help organisations like yours learn how to deal with and address issues, instead of simply reacting to the challenges brought about by growth and change.
In such review, the information provided is practical from both a financial and operational perspective. Using these data, the management can then come up with recommendations, which are not only realistic, but more importantly, can help the organisation achieve its goals. The review recognises the extent to which your internal controls actually work, and enables you to identify and understand your strengths, weaknesses, opportunities and threats

To be more specific, let’s list down the ways wherein an effective operational review can contribute to the success of the organisation.

The review process can:
– assess compliance within your own organisational objectives, policies and procedures;
– evaluate specific company operations independently and objectively;
– give an impartial assessment regarding the effectiveness of an organisation’s control systems;
– identify the appropriate standards for quantifying achievement of organisational objectives;
– evaluate the reliability and value of the company?s management data and reports;
– pinpoint problem areas and their underlying causes;
– give rise to opportunities that may increase profit, augment revenue, and reduce costs without sacrificing the quality of the product or service.
Thus, each operational review conducted is unique, and can be holistic or specific to the activities of one department.

Our Operational Efficiencies cover the entire spectrum:

  • What to buy
  • Optimising what you’ve already bought e.g. underutilised servers, duplicate processes, poorly managed bandwidths
  • Making your team comfortable with the changes
  • Instilling Best Practices

UNCOVER WAYS TO DRIVE YOUR PROFITS UP, THROUGH OPERATIONAL REVIEWS

More Operational Review Blogs


Carrying out an Operational Review


Operational Reviews


Operational Efficiency Initiatives


Operational Review Defined

Ready to work with Denizon?